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Telecom Decision CRTC 2005-32
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Ottawa, 2 June 2005
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Accutel Conferencing Systems Inc. - Definition of terminal equipment revenues within the contribution regime
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Reference: 8695-A80-200401729
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In this Decision, the Commission determines that Accutel Conferencing Systems Inc. (Accutel) is providing a telecommunications conferencing service, not terminal equipment, and therefore it cannot deduct its conference bridge revenues as terminal equipment revenues within the revenue-based contribution regime. The Commission also determines that terminal equipment must be located on the customer's premises to be eligible for the terminal equipment deduction within the revenue-based contribution regime.
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The Commission directs Accutel to file revised 2002, 2003, 2004, and 2005 contribution reports with the Central Fund Administrator and revised 2002, 2003, and 2004 annual revenue reports with the Commission, within 30 days of the date of this Decision. Revised reports are only required for those periods specified above in which Accutel claimed its conference bridge revenues as a terminal equipment deduction.
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Background
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1.
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In Changes to the contribution regime, Decision CRTC 2000-745, 30 November 2000 (Decision 2000-745), the Commission introduced a revenue-based contribution regime. Under this regime, telecommunications service providers (TSPs) with $10 million or more of Canadian telecommunications service revenues are required to contribute towards the subsidization of high-cost residential telephone service in rural and remote areas of Canada, based upon their contribution-eligible revenues. Contribution-eligible revenues are calculated by subtracting Commission-approved deductions from Canadian telecommunications service revenues. One of the Commission approved deductions is revenue generated from the sale or rental of terminal equipment.
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2.
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With respect to the terminal equipment deduction, the Commission concluded in Decision 2000-745:
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Revenues generated from the sale or rental of terminal equipment are not contribution-eligible, as it would not be competitively equitable to make telecommunications service providers contribute when terminal equipment is also provided by non-telecommunications service providers.
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3.
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Following the release of Decision 2000-745, implementation working groups were established to work out the details of how the contribution regime would operate, including, among other things, the definitions required to ensure that all TSPs would report in a consistent manner.
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4.
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In Disputed issues submitted by the Contribution Collection Mechanism (CCM) Implementation Working Groups, Order CRTC 2001-221, 15 March 2001 (Order 2001-221), the Commission approved the following definition for the deduction of terminal equipment revenue:
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The Sale or Rental of Terminal equipment is defined as revenue generated by the transfer of title or specifically contracted use of any network addressable equipment, which is intended for use in conjunction with the provision of a telecommunications service. Equipment providing telecommunications services are items such as client premises routers, PBXs, handsets, stand-alone earth station equipment or other satellite-based end-user equipment and jointly-used teleport facilities. Ancillary services, including equipment installation, site preparation, programming, maintenance, customer training, engineering, design, technical support and related financing charges, are also considered a component of "Terminal Equipment Revenues" pursuant to Decision 2000-745 requirements.
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5.
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By letter dated 10 April 2001, Commission staff issued an interpretation of the definition of terminal equipment. In this letter, Commission staff clarified that the approved definition only applied to terminal equipment located at a customer's premises and that revenue generated from the sale or rental of terminal equipment on the telecommunication service providers' premises were contribution-eligible.
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Introduction
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6.
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On 28 March 2003, Accutel Conferencing Systems Inc. (Accutel) filed with the Commission its 2002 annual revenue report, which included a deduction on line D.9 (Terminal Equipment Revenues). Accutel submitted that conferencing equipment should not be contribution-eligible because it was not associated with a telephone switch, but was located in stand-alone business locations. Accutel also submitted that conferencing equipment was similar to stand-alone answering systems, call centre distribution systems, and integrated voice response units, in that the equipment was only interconnected to the telephone network through regular access lines.
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7.
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By letter dated 26 June 2003, in response to a Commission staff inquiry, Accutel submitted that its conferencing equipment met the Commission's definition of terminal equipment because the revenues are generated by the specifically contracted use of the equipment, the equipment was network addressable, the equipment was intended for use in conjunction with the provision of a telecommunications service, and the customer paid separate charges for the use of the equipment.
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8.
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By letter dated 8 December 2003, Accutel was advised that Commission staff was of the opinion that Accutel's terminal equipment deduction did not meet the definition approved by the Commission in Order 2001-221 because the equipment was located on Accutel's premises.
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Accutel's application
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9.
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On 1 March 2004, Accutel filed an application, pursuant to Part VII of the CRTC Telecommunications Rules of Procedure, in which it requested a Commission ruling with respect to whether terminal equipment revenue can ever be exempt from contribution when the equipment was not located on the customer's premises. Accutel indicated that its conferencing equipment was located on its premises in Toronto and in a separate co-location facility, also located in Toronto.
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Process
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10.
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The Commission received comments, dated 31 March 2004, from Saskatchewan Telecommunications (SaskTel). Accutel filed reply comments on 14 April 2004.
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11.
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On 16 July 2004, the Commission issued an interrogatory to Accutel. Accutel replied on 3 August 2004.
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Positions of parties
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Accutel
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12.
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Accutel submitted that Commission staff had misinterpreted Decision 2000-745 and Order 2001-221, as neither of these Decisions precluded the location of terminal equipment (for the contribution deduction) on the premises of a service provider or a third party.
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13.
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Accutel noted that it was in the business of providing telecommunications conferencing services to the public through the rental of ports on its centrally provisioned conferencing equipment and that the conferencing equipment, which consisted of conference bridges, allowed customers in separate locations to talk to each other in multi-party conversations by dialling into the conference bridge. Customers could either dial directly into the conference bridge using their own local or long distance service or, when requested by a customer, Accutel would arrange for toll-free access. The charges associated with the toll-free access were passed through to the customer as a separate item on the customer's bill.
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14.
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Accutel submitted that its conferencing equipment was network addressable terminal equipment that had a specified number of ports, each of which was capable of handling a single line. Each participant on a conference call required that a port be dedicated for its use for the duration of the call. Accutel charged its customers separately for the use of the conference bridge on a per-port, per-minute basis and, if requested, the access to the conference bridge.
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15.
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Accutel submitted that there are a number of ways in which conferencing services can be provided. For example, both electronic key systems and private branch exchange (PBX) systems, which can be purchased or leased from equipment vendors, can include conferencing features. In addition, larger businesses may purchase or lease the same type of conference bridges provided by Accutel. Accutel also submitted that it competed with all of these different types of conferencing services and equipment by offering its customers the ability to rent ports on its conference bridges for specific time periods, on an as needed basis, without the need for a large equipment investment.
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16.
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With respect to Decision 2000-745, Accutel noted that the Commission outlined the principles that a contribution collection mechanism should promote, including fairness, economic efficiency, competitive equity, technological neutrality, and ratepayer equity.
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17.
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Regarding technological neutrality, Accutel noted that the Commission stated that the selection of a given technology should not impact a company's contribution obligation, except to the extent that a company was able to reduce the amount it charged for a service.
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18.
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Regarding competitive equity, Accutel noted that the Commission had concluded in Decision 2000-745 that the revenues generated from the sale or rental of terminal equipment would not be contribution-eligible, as it would not be competitively equitable to make telecommunications service providers contribute when terminal equipment was also provided by non-telecommunications service providers.
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19.
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Accutel submitted that, since it competed with vendors and other terminal equipment suppliers who do not pay contribution on conferencing equipment or bridges, it would be inconsistent with the Commission's principle of competitive equity to charge contribution on the revenue Accutel generated from the lease of its conferencing equipment. In addition, if Commission staff's approach was taken, the lease of ports on centrally provisioned terminal equipment would be treated differently, for contribution purposes, than the lease of ports on precisely the same equipment located on the customer's premises.
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20.
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With respect to Order 2001-221, Accutel submitted that its conferencing equipment met the definition of terminal equipment approved in Order 2001-221. In particular, Accutel submitted that it contracted with its customers for their specific use of its conferencing equipment and the equipment was network addressable. In addition, when a customer was using the conferencing equipment, Accutel dedicated a specific number of ports for the customer's use for the amount of time requested by the customer.
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21.
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Accutel submitted that, while title of its conferencing equipment did not pass to the customer, in accordance with the Commission definition, the charges for use of this equipment were "revenues generated by. specifically contracted use of the network addressable equipment", in accordance with the second part of the approved definition. In addition, Accutel indicated that its conferencing equipment is used in conjunction with the provision of a telecommunications service, and that the conferencing equipment had no utility to Accutel's customers except in conjunction with a telecommunications service.
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22.
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With respect to the Commission staff letter of 10 April 2001, Accutel noted that it was intended to provide clarification following an informal request by a third party for an interpretation of the definition of terminal equipment set out in Order 2001-221. Therefore, it was not binding on the Commission and should not be endorsed by the Commission.
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23.
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With respect to Commission staff's 8 December 2003 opinion, Accutel noted that the only reason given by Commission staff for denying Accutel's deduction was the fact that the conferencing equipment was not located on the customer's premises.
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24.
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Accutel submitted that, based upon the principles of technological neutrality and competitive equity outlined in Decision 2000-745, Commission staff's interpretation would prejudice Accutel for its use of centrally provisioned conferencing equipment, while exempting its competitors for sale or lease of precisely the same equipment.
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25.
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Accutel also submitted that it was clear from the wording used by the Commission in Order 2001-221 that the definition of terminal equipment was never intended to be restricted to equipment located on a customer's premises. In particular, the use of the words "such as" does not limit the range of terminal equipment and, taken literally, Commission staff's interpretation would preclude mobile terminals from the exemption. Furthermore, the Commission's inclusion of "jointly-used teleport facilities" in its list of examples made it clear that terminal equipment does not have to be dedicated to a single customer's use or even located at a single customer's premises, as it was hard to imagine jointly-used teleport facilities being located on a customer's premises.
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26.
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Based upon the above reasons, Accutel concluded that Commission staff erred in its interpretation of Decision 2000-745 and Order 2001-221, and that it should be permitted to deduct the revenues it generated from the rental of ports on its telecommunications equipment in the calculation of its contribution-eligible revenues.
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SaskTel
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27.
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SaskTel noted that, since the inception of the contribution mechanism, there have been challenges to the contribution mechanism by individual companies requesting that the mechanism be modified to meet their particular circumstances. SaskTel also noted that it had opposed such proposals, as thinly veiled attempts to introduce special contribution-based treatment in the interest of one company or segment of the industry. SaskTel considered Accutel's application to be another attempt by a party to garner favourable treatment for itself at the expense of others and the integrity of the national subsidy fund, and requested that it be denied.
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28.
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SaskTel submitted that Accutel was not alone in the business of providing telecommunications conferencing services to the public in the manner it described, as SaskTel also provided conferencing services by means of a conference bridge, for which it charged for the conference bridge usage and, if applicable, message toll charges.
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29.
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SaskTel noted that, as per the Commission's determinations regarding the contribution treatment of revenues associated with centrally provisioned terminal equipment, SaskTel has included its conference bridge revenues as contribution-eligible, both in its annual revenue reports to the Commission and its monthly contribution reports filed with the Central Fund Administrator (CFA). SaskTel also understood that other companies providing conferencing services in a similar manner are also following these directives.
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30.
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SaskTel submitted that to allow Accutel to deduct its conferencing revenues would provide it with a "leg up" on other parties, like SaskTel, who also offer centrally located conferencing services.
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31.
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SaskTel was concerned that granting Accutel an exemption would result in other companies requesting similar treatment, which would result in a significant erosion of contribution-eligible revenues. SaskTel was also concerned that approving Accutel's application could bring into question the contribution-eligibility of other centrally provisioned telecommunications services, such as Centrex, and the sustainability of the national subsidy fund.
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Accutel's reply comments
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32.
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Accutel submitted that it was not trying to modify the contribution regime, as was suggested by SaskTel, as the company did not file a review and vary application. Rather, Accutel was requesting the Commission apply its decisions regarding the exemption of terminal equipment revenue within the contribution regime.
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33.
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With respect to SaskTel's comment concerning trying to get a "leg up" on its competitors, Accutel submitted that it was only trying to be treated in the same manner as its competitors who sell or lease conferencing equipment and get to exclude their rental payments from contribution-eligible revenue. In addition, Accutel noted that it had not commented on whether other TSPs would also be eligible for the deduction, as it would depend on how they structured their services. This would be similar to wireless terminal revenues, which are not deductible in bundled format, but are deductible in an unbundled format.
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34.
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With respect to SaskTel's comment concerning other centrally provisioned telecommunications services, Accutel considered this to be a scare tactic to encourage the Commission to deny the application. Accutel noted that when the Commission determined that terminal equipment should not be contribution-eligible, it did so for competitive equity reasons, not quantitative reasons. In addition, Accutel noted that Centrex service was not priced in a manner that isolated the terminal component from the local exchange element, and that the bulk of Centrex charges related to network access, not terminals.
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Commission interrogatory
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35.
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As noted earlier, the Commission issued an interrogatory to Accutel on 16 July 2004. Accutel was asked to provide a detailed explanation as to why it considered that it was providing terminal equipment, as opposed to a contribution-eligible telecommunications service that was provided through the use of a piece of terminal equipment.
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36.
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In its reply, Accutel noted that, because the definition of telecommunications services in section 23 of the Telecommunications Act (the Act) included the provision of terminal equipment, it was by definition providing a telecommunications service. Accutel also noted that the Commission decided for policy reasons that terminal equipment revenues should not be contribution-eligible because it would not be competitively equitable to make TSPs pay contribution when terminal equipment was also provided by non-TSPs.
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37.
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Accutel submitted that it did not provide a network to its customers, or otherwise switch or transport their communications, so this was not a case of providing a telecommunications service through the use of telecommunications equipment. Accutel also submitted that it was the use of the equipment itself that was charged to the customer, unlike Centrex service, which was part of a wider local communications service provided by a telephone company.
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38.
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Accutel stated that it competed against businesses that rented or sold equipment with conferencing features, these other businesses did not pay contribution, and competitive equity dictated that Accutel be treated equally. Accutel submitted that if it were leasing 100 percent of its ports to a single customer, then presumably there would be no question that it was engaged in the leasing of terminal equipment. Accutel noted that because it leased to multiple parties, it had to centrally provision the equipment. Accutel submitted that central provisioning and/or joint-use should not change the fact that it was providing terminal equipment. Accutel noted that joint-use teleport facilities are an example of centrally provisioned jointly-used facilities that the Commission had expressly identified as terminal equipment.
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Commission's analysis
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Policy objectives of Decision 2000-745
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39.
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In Decision 2000-745, the Commission determined that a national revenue-based contribution regime would best meet the criteria and principles of administrative efficiency, sustainability, collecting the appropriate amount to achieve the basic service objective, pricing flexibility for all market participants, fairness, ratepayer equity, economic efficiency, technological neutrality, and competitive equity.
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40.
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As identified in Decision 2000-745, there was a wide range of positions with respect to what services should be contribution-eligible. Proposals ranged from only long distance services to all telecommunications services, with some parties proposing that specific services should not be contribution-eligible.
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41.
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In Decision 2000-745, the Commission noted that applying contribution against the broadest possible range of telecommunications services would spread the contribution burden across various sectors of the marketplace, be competitively equitable, result in a lower revenue-percentage charge being applied to each service, and be more administratively efficient by eliminating the need for a detailed review and classification of all telecommunications services.
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42.
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The Commission then concluded that all TSPs, or groups of related TSPs, with $10 million or more of Canadian telecommunications service revenues would be required to contribute based upon their total Canadian telecommunications service revenues, less certain deductions approved by the Commission, one of which related to terminal equipment revenue. With respect to the terminal equipment deduction, the Commission determined that revenues generated from the sale or rental of terminal equipment would not be contribution-eligible, as it would not be competitively equitable to make TSPs contribute when terminal equipment is also provided by non-TSPs.
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43.
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The Commission is of the view that the objective of applying contribution against the broadest possible range of telecommunications services means that a TSP claiming a deduction must unequivocally demonstrate that it meets the definition approved by the Commission for that deduction.
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Whether Accutel's conferencing equipment meets the definition
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44.
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The Commission considers that Accutel is in the business of providing conferencing services to the public by allowing its customers, in separate locations, to talk to each other in multi-party conversations by dialling into the conference bridge. Customers can either dial into the conference bridge using their own local or long distance service or, when requested by the customer, Accutel will arrange for toll-free access. The charges associated with the toll-free access are passed through to the customer as a separate item on the customer's bill.
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45.
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The Commission notes that Accutel submitted that its conferencing equipment met the definition of terminal equipment approved in Order 2001-221 because the revenues were generated by "specifically contracted use" of the equipment, the equipment was "network addressable", the equipment was "intended for use in conjunction with the provision of a telecommunications service", and the customer paid separate charges for the use of the equipment.
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46.
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The Commission also notes that a central component of the approved terminal equipment definition is that the revenues in question are "generated by the transfer of title or specifically contracted use of any network addressable equipment which is intended for use in conjunction with the provision of a telecommunications service".
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47.
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The Commission is not persuaded that Accutel's conferencing service revenues are generated by the "specifically contracted use of any network addressable equipment". The Commission is of the view that Accutel's conferencing service revenues are just that - conferencing service revenues - and that the equipment by which these revenues are generated is incidental to the delivery of the service.
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48.
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Accutel noted that it charges its customers separately for their use of ports on the conference bridge and that the charges are based on the number of ports used and the length of time they are used. Accutel also noted that customers may call Accutel to book a conference call, or, alternatively, frequent customers may arrange with Accutel for the capability to book use of a conference bridge electronically, whenever they require it.
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49.
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The Commission disagrees with Accutel's argument that because it bills its customers on a per-port basis Accutel's customers specifically contract for the use of its conferencing equipment.
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50.
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The Commission is of the view that when a customer specifically contracts for the use of terminal equipment, the customer would have some degree of control over the operation of that equipment. In the case of Accutel, the Commission is not aware of any other indicator of customer control over the conferencing equipment, other than determining when the conference call starts and stops.
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51.
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The Commission notes, for example, that Accutel could change the type of equipment it uses to provide its service without having to consult or notify its customers. The Commission considers this to be a strong indication that the customers are contracting for the provision of conferencing services and not contracting for the use of the equipment.
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52.
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Moreover, the Commission is not convinced that Accutel's customers are being granted enforceable property rights or interests of any kind over Accutel's conference bridge equipment. The Commission considers that the presence of such rights or interests along with customer control over the equipment would coincide with a situation where the customer is specifically contracting for the rental of terminal equipment, just as transfer of title coincides with the sale of terminal equipment.
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53.
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For the above reasons, the Commission considers that Accutel is providing a telecommunications conferencing service to its customers and not terminal equipment.
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54.
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The Commission is of the opinion that competitive equity exists in the provision of telecommunications conferencing services because all TSPs are required to comply with Decision 2000-745 and telecommunications conferencing service revenues are contribution-eligible for all TSPs.
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55.
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The Commission is also of the opinion that competitive equity does not have to exist between companies providing a conferencing service and companies selling conferencing equipment because one is providing a service, while the other is selling equipment.
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56.
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The Commission considers that technological neutrality exists because a TSP that provides conferencing services is required to pay contribution on its conferencing service revenues, regardless of the technology it uses to earn the revenue.
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Customer premise versus service provider premise
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57.
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The Commission notes that Commission staff's 10 April 2001 letter was issued in response to an informal request to Commission staff for an interpretation of the terminal equipment deduction. The letter clarified that, in Commission staff's opinion, the approved definition applied only to terminal equipment located at a customer's premises. The letter, which was posted on the Commission's website, went on to state that for further clarification, revenues generated from the sale or rental of terminal equipment on the telecommunication service providers' premises were contribution-eligible.
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58.
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The Commission also notes that Accutel specifically requested a Commission ruling with respect to the issue of whether terminal equipment revenue can ever be exempt from contribution when the equipment is not located on the customer's premises, and that Accutel is the first TSP to request a Commission determination with respect to the treatment of service provider based terminal equipment. Furthermore, the Commission notes that the only comment received was against the application by SaskTel, a TSP who also provides conferencing services.
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59.
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The Commission notes that SaskTel indicated that it has been including its conferencing revenues as contribution-eligible in both its annual revenue reports filed with the Commission and its monthly contribution reports filed with the CFA. In addition, it was SaskTel's understanding that all other TSPs providing conferencing services were also following these directives.
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60.
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Accutel submitted that the wording contained in Order 2001-221 never intended to restrict the location of the terminal equipment to the customer's premises and that the use of the term "such as" does not restrict the range of terminal equipment. In addition, the inclusion of "jointly-used teleport facilities" makes it clear that terminal equipment does not have to be dedicated to a single customer's use or located at a single customer's premises, as it is hard to imagine jointly-used teleport facilities being located on a customer's premises.
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61.
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The Commission notes that it has been its long-standing position that terminal equipment must be located on the customer's premises in order for the equipment to be considered terminal equipment.
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62.
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In Attachment of subscriber-provider terminal equipment, Telecom Decision CRTC 82-14, 23 November 1982 (Decision 82-14), the Commission stated:
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The Commission is of the view that, in order for a given configuration of equipment to be considered as terminal equipment, it must be restricted to operate within a single building, or the portion thereof owned or leased by the subscriber, or between buildings or the portions thereof which are owned or leased by the subscriber provided these buildings are on continuous property as defined in Item 20 of Bell's General Tariff and are within the same exchange.
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63.
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In Interexchange competition and related issues, Telecom Decision CRTC 85-19, 29 August 1985, the Commission referred to the definition of terminal equipment contained in Decision 82-14 and then expanded the definition to include private user systems on non-continuous property.
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64.
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In Forbearance - Sale of terminal equipment by Canadian carriers, Telecom Decision CRTC 94-14, 4 August 1994, the Commission noted that, in Decision 82-14, it had established the regulatory treatment for the sale of new and in-place terminal equipment by the carriers then under its jurisdiction. The Commission went on to forbear from regulating terminal equipment under certain sections/subsections of the Act.
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65.
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The Commission notes that, while it forbore from regulating terminal equipment under certain sections/subsections of the Act, it did not change its definition of terminal equipment.
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66.
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In Review of regulatory framework, Telecom Decision CRTC 94-19, 16 September 1994, the Commission noted that the competitive terminal market comprised the sale, lease and maintenance of terminal equipment. The Commission considered that, for purposes of defining the market, there are two distinct market segments: (1) the Competitive Terminal - Multiline & Data (CT-MD) market, consisting of key systems, PBXs and data equipment; and (2) the single-line or Competitive Terminal - Other (CT-O) market, consisting of single-line telephones and accessories.
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67.
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The Commission notes that the types of terminal equipment it identified (key systems, PBXs and single-line telephones) would be located on the customer's premises, as opposed to the service provider's premises. The Commission also notes that, when a customer purchases a piece of equipment from a retailer, the customer would take the equipment with them and install it on the customer's premises, not the service provider's premises.
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68.
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The Commission notes that in Report to the Governor in Council: Status of Competition in Canadian Telecommunications Markets - Deployment/Accessibility of Advanced Telecommunications Infrastructure and Services, dated 27 September 2001 (the monitoring report), the Commission included the following definition in the Glossary of Terms and Acronyms:
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Terminal Equipment: Equipment located at the customer's premises, used for voice or data communications (e.g., telephone set).
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69.
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The Commission also notes that the above definition of terminal equipment was also included in its three subsequent monitoring reports issued on 20 December 2002, 27 November 2003, and 25 November 2004.
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70.
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While the definition of terminal equipment contained in the monitoring reports is not equivalent to a Commission finding resulting from a regulatory process, the Commission is of the view that it is another example of the Commission's long-standing position that terminal equipment must be located on the customer's premises in order for the equipment to be considered terminal equipment.
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71.
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The Commission notes that, as recorded in the minutes of one of the implementation working group conference calls dealing with the terminal equipment deduction held following the release of Decision 2000-745, Telesat Canada (Telesat) stated that it was an end to end service provider that has "earth station equipment", e.g., satellite (i.e., a phone in a suitcase or dish on someone's roof). This type of equipment can be provided by customers themselves, or it can be bought from a number of service providers. Telesat expects that its earth station equipment would fall under this framework.
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72.
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The Commission notes that the submission of the implementation working group with respect to the definition of terminal equipment included the term "satellite" in the list of equipment. Based upon the minutes of the implementation working group conference, the Commission considers the term "satellite" to mean a phone in a suitcase or dish on someone's roof and not a satellite in the sky.
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73.
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The Commission notes that, in Order 2001-221, it changed the submission of the implementation working group by approving a definition of terminal equipment that included the term "or other satellite-based end-user equipment", in place of the term "satellite".
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74.
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The Commission also notes that this approved modification prevented the deduction of service provider based satellite terminal equipment revenues.
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75.
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The Commission notes that, in Order 2001-221, it identified the following ancillary services to be components of terminal equipment revenues: equipment installation, site preparation, programming, maintenance, customer training, engineering, design, technical support, and related financing charges. The Commission is of the opinion that these ancillary services relate more to client premise based terminal equipment rather than service provider premise based terminal equipment.
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76.
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In light of the above, the Commission considers that the intention in Decision 2000-745 and Order 2001-221 was to allow a deduction only for terminal equipment that is located on the customer's premises and that terminal equipment not located on the customer's premises would be contribution-eligible.
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Commission's determinations
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77.
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The Commission determines that Accutel is providing a telecommunications conferencing service, not terminal equipment, and therefore it cannot deduct its conference bridge revenues as terminal equipment revenues within the revenue-based contribution regime. The Commission also determines that terminal equipment must be located on the customer's premises to be eligible for deduction as terminal equipment within the revenue-based contribution regime.
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78.
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The Commission directs Accutel to file revised 2002, 2003, 2004, and 2005 contribution reports with the CFA and revised 2002, 2003, and 2004 annual revenue reports with the Commission, within 30 days of the date of this Decision. Revised reports are only required for those periods specified above in which Accutel claimed its conference bridge revenues as a terminal equipment deduction.
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Secretary General
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This document is available in alternative format upon request, and may also be examined in PDF format or in HTML at the following Internet site: www.crtc.gc.ca
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Date Modified: 2005-06-02