Ottawa, 25 April 2005
Ms. Janet Yale
Executive Vice-President
Corporate Affairs
TELUS
12th Floor
45 O'Connor Street
Ottawa , Ontario
K1P 1A4
Re: TELUS' Streamlining Proposals
This is to follow-up to a meeting that you had with my predecessor in which you requested a review of 17 of the 25 CRTC regulatory filing requirements that apply to TELUS.
Each of your proposals has been reviewed and I am pleased to advise you that many have been accepted. Attached is a table which details what action has been or is being taken with respect to each individual proposal.
The streamlining initiatives that have already been implemented should lead to substantial reductions in the workload associated with filing requirements. We estimate that the savings flowing from those initiatives represent approximately 70% of the savings associated with TELUS' requests, excluding the quality of service reports which are still required pursuant to Telecom Decisions CRTC 2005-17 and 2005-20. These reports are important safeguards with respect to the quality of services provided to competitors and to consumers.
The actions already taken to streamline regulatory filings include those relating to the CRTC monitoring survey input. You asked us to examine ways to streamline data collection next year, once the five-year Governor-in-Council mandated process ends. I am pleased to report that rather than waiting until next year, as part of our annual review of this process, this year we eliminated 20% of the data collection forms and reduced the amount of data collected on another 40%. As well, starting this year, we are treating most data forms as having been filed in confidence, thus eliminating the need for respondents to claim confidentiality on each form. We have also made software changes which will facilitate importing data directly into the CRTC data collection forms, thus reducing completion time.
The Commission has also reduced the filing frequency, from quarterly to annual, of three reports (911 ALI, Affordability, and Network Outages). As well, the annual reports associated with the Service Extension and Service Improvement Programs have been merged.
I am also pleased to advise that public processes relating to five of your requests are ongoing and these may lead to further workload reductions. I note that Commission staff issued a letter on 11 February 2005 asking for comments on proposals to reduce the regulatory requirements applicable to international licensees. These streamlining proposals go considerably further than what was requested by TELUS. I also note that, by letter dated 6 April 2005 , staff is inviting comments on whether the Commission should forbear from the requirement to file four types of agreements for approval under section 29 of the Telecommunications Act (the Act).
The actions that are summarized in the attached table exemplify the Commission's commitment to reducing regulation whenever possible. Other recent initiatives include Telecom Circular CRTC 2005-06, released today, in which the Commission introduced a streamlined process for retail tariff filings. Other examples include Telecom Decision CRTC 2005-18, issued on 29 March 2005 , in which the Commission forbore from regulating approximately 800 interexchange private line routes, and the Commission's adoption of the expedited process for certain Part VII applications.
The Commission welcomes any additional suggestions you might have that can further reduce regulatory workload while continuing to fulfill the Canadian telecommunications policy objectives set out in the Act.
cc R. French
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Filing Requirement
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TELUS Request and CRTC Action
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1
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CRTC Monitoring Survey Input
(Annual)
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Request: Streamline data collection after 2005, once the five-year Governor-in-Council mandated process ends.
Action : For 2005 Report - Eleven data forms were eliminated and the amount of information requested was reduced on a further 18 data forms. Three data forms were added to capture data related to VOIP, Bundling and Out-of-territory revenues. As well, a simplified way to claim confidentiality of data submitted was introduced, as well as other mechanisms to facilitate data form completion (Completed: February 2005).
It is anticipated that a further review will take place next year after the five-year mandated process ends.
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2
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911 Manual Access to ALI
(Quarterly)
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Request : Reduce frequency from quarterly to annual or on a request basis.
Action: The Commission issued Telecom Circular CRTC 2005-05 on 4 April 2005 reducing the filing frequency to an annual basis. Additional reports may be requested if required.
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3
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IXPL Routes
(Semi-annual)
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Request : Change semi-annual reporting requirement to identify routes where competitors are providing IXPL service to a quarterly requirement and initiate audit or inspection of competitors to verify compliance.
Action : Staff letter, dated 15 September 2004, required IXPL service providers to provide additional information in their October 2004 reports. Based on these reports, the Commission issued Telecom Decision CRTC 2005-18 on 29 March 2005 forbearing from regulating nearly 800 additional IXPL routes.
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4
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Affordability Monitoring
(Quarterly)
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Request : Reduce the filing of quarterly affordability monitoring reports to an annual requirement.
Action : Issued Telecom Decision CRTC 2004-73 on 9 November 2004 reducing the frequency to annual.
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5
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Service Extension & Service Improvement Program
(Annual)
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Request :
(a) Merge the tracking and reporting of SEP and SIP into one report ;
(b) TELUS filed an application to discontinue SEP and Alberta ILS program so that SIP is the standard program (TN 147)
Action :
Request (a): By staff letter dated 17 May 2004, SEP and SIP reports were merged.
Request (b) was denied because some residential customers would be adversely affected (Telecom Order CRTC 2005â€"75 issued 23 February 2005).
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6
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International Class A/B License Update
(Annual)
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Request : Eliminate filing agreements with foreign telecommunications service providers.
Action : Companies are only required to file lists of agreements with foreign telecommunications service providers (Telecom Decision CRTC 98-17 dated 1 October 1998, at paragraph 338).
In a related matter, by letter dated 11 February 2005, staff proposed to reduce the regulatory requirements relating to international licensees that would, among other things, eliminate the requirement to file lists of agreements.
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7
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Payphone Location Report
(Annual)
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Request : Eliminate the annual report identifying locations of all pay telephone removals and reasons why.
Action : Annual report still required. In the proceeding leading to Telecom Decision CRTC 2004-47 issued 15 July 2004, consumers argued for quarterly reports. In that decision, the Commission reaffirmed the need for annual reporting.
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8
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Quality of Service-Retail
(Quarterly)
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Request : Reduce frequency from quarterly to annual or on a request basis.
Action : Quarterly reports still required. These reports will be used to assist with monitoring the rebate program as per Telecom Decision CRTC 2005-17 issued 24 March 2005.
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9
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Quality of Service Exception - Retail
(Monthly in certain circumstances)
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Request : Reduce frequency from monthly to quarterly or on a request basis.
Action : Monthly reports still required. These reports are only required if the ILEC has been below standard 3 consecutive months or 7 out of 12 consecutive months. The need for such reports was examined in the proceeding leading to Telecom Decision CRTC 2005-17 and the Commission concluded that monthly reports are still required.
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10
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Quality of Service-Competitor Services
(Quarterly)
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Request : Reduce frequency from quarterly to annual.
Action : Quarterly reports still required. The frequency of such reports was examined in the proceeding leading to Telecom Decision CRTC 2005-20 issued 31 March 2005 and the Commission concluded that quarterly reports are still required.
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11
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Quality of Service-Network Outage
(Quarterly)
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Request : Reduce frequency from quarterly to annual.
Action: The Commission issued Telecom Circular CRTC 2005-05 on 4 April 2005 reducing the filing frequency to an annual basis. Additional reports may be requested if required.
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12
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Transit Agreement between LECs
(Per agreement)
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Request : Remove the requirement to file section 29 Transit agreements between LECs for Commission approval. Telus proposed to instead file a brief standard form letter indicating that an agreement has been entered into and that the terms of the industry standard MALI have been adopted.
Action : Absent forbearance, these agreements must be filed pursuant to section 29 of the Act. By letter dated 6 April 2005, staff is calling for comments on whether forbearance is appropriate.
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13
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Carrier Services Agreement
(Per agreement)
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Request: To discontinue filing these agreements. Telus proposed to instead submit a letter indicating that a CSG Agreement has been entered into and that the terms of the arrangement follow the industry standard model. Telus stated that CSG agreements do not fall under section 29 and that all material aspects of interconnection are addressed in the ILECsâ€T tariffs.
Action : CSG Agreement falls within section 29 of the Act because it sets out terms and conditions associated with interconnection of services and facilities between ILECs and interexchange carriers, and the management and operation of the ILECâ€Ts facilities e.g., through network planning provisions. Absent forbearance, these agreements must be filed pursuant to section 29 of the Act. By letter dated 6 April 2005, staff is calling for comments on whether forbearance is appropriate.
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14
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Agreement for CLEC-IXC Interconnection
(Per agreement)
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Request: To discontinue filing these agreements for Commission approval. Telus proposed to instead submit a letter indicating that a standard agreement has been entered into. Telus stated that the agreement does not fall under section 29 and that all material aspects of interconnection are addressed in the CLECâ€Ts tariff.
Action: Agreement for CLEC-IXC Interconnection falls under subsections 29(a) and (b) of the Act. Absent forbearance, these agreements must be filed pursuant to section 29 of the Act. By letter dated 6 April 2005, staff is calling for comments on whether forbearance is appropriate.
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15
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Agreement for Local Interconnection between LECs
(Per agreement)
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Request : To discontinue filing these agreements for Commission approval. Telus proposed to instead file a brief standard form letter indicating that an agreement has been entered into between carriers and that the terms of the industry standard MALI have been adopted.
Action: These agreements fall under section 29 of the Act. Absent forbearance, these agreements must be filed pursuant to section 29 of the Act. By letter dated 6 April 2005, staff is calling for comments on whether forbearance is appropriate.
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16
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Swap of Telecommun- ications Facilities
(Per agreement)
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Request : To discontinue filing these agreements for Commission approval.
Action : Agreements still required because of anti-competitive concerns.
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17
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Joint Use of Telecom Facilities
(Per agreement)
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Request : To discontinue filing these agreements for Commission approval.
Action : Agreements still required because of anti-competitive concerns.
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18
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Phase II Costing monitoring
(Annual/as required)
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TELUS did not suggest any change.
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19
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CNAC report
(Annual)
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TELUS did not suggest any change.
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20
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Telecommunication Fees
(Annual)
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TELUS did not suggest any change. However, in order to streamline data collection, telecom fee information was combined with the annual data collection exercise that is used to prepare the monitoring report.
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21
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Contribution Revenue Requirement
(Annual)
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TELUS did not suggest any change. However, in order to streamline data collection, contribution collection information was combined with the annual data collection exercise used to prepare the monitoring report.
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22
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Price Cap deferral Account
(Annual)
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TELUS did not suggest any change.
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23
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Price Cap Compliance
(Annual)
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TELUS did not suggest any change.
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24
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Total Subsidy Requirement
(Annual)
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TELUS did not suggest any change.
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25
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Annual Ownership
(Annual)
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TELUS did not suggest any change.
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Date Modified: 2005-04-25