ARCHIVED - Telecom Commission Lettre - 8663-C12-200717738

Letter

Ottawa, 20 June 2008

File No.:   8663-C12-200717738

By email

Distribution List

Re:   Follow-up to Telecom Decision CRTC 2007-125: CRTC Interconnection Steering Committee - Non-Consensus Report on a Functional Architecture for the Implementation of Nomadic VoIP 9-1-1 Service in Canada (Decision 2007-125)

The Commission is in receipt of letters from Cogeco Cable Inc, Quebecor Media Inc., Rogers Communications Inc. and Shaw Communications (collectively, the Access Service Providers (ASPs)) and Bell Aliant Regional Communications Limited Partnership (Bell Aliant), Bell Canada, Saskatchewan Telecommunications, and TELUS Communications Company (collectively, the Companies) dated 11 June 2008.

These letters are in response to interrogatories sent by the Commission and to requests for further responses to interrogatories from Cogeco Cable Inc. on behalf of the ASPs and from the Coalition of Internet Service Providers and Primus Canada (collectively as the VoIP service providers (VISPs)) on 4 June 2008.

The VISPs requested the ASPs to provide further responses to their interrogatories and for disclosure of information filed in confidence.   The ASPs in their response have disclosed the requested information and provided responses to the VISPs interrogatories.

The VISPs and ASPs requested the Companies to provide further responses to previous interrogatories and disclose certain cost information filed in confidence.  

In response to requests for further responses , t he Companies submitted in general that:

1. an adequate and complete response was already provided;   or
2. further clarifications have been provided; or
3. in some cases the requests for further responses amount to a different question being asked than what was posed in the original interrogatory; or
4. the suggested scenarios were not consistent with the Canadian i2 proposal, which is the subject of the proceeding, and the Commission in Decision 2007-125, had directed that interrogatories must strictly focus on the economic evaluations of the Companies and the large ASPs.   The Commission also specifically excluded interrogatories in relation to other VoIP 911 implementations; and
5. therefore, no further response was necessary.

With reference to ILECs(CRTC)14 May08-04, Primus Canada requested that the Commission direct the Companies to disclose all of the revised rates on the public record.   TELUS and Bell Canada and Bell Aliant submitted that the stated purpose of the current proceeding is to assess the economic viability of the Canadian i2 solution.   It is not to assess specific rates put forward by the Companies.   Bell Canada and Bell Aliant further submitted that the decision as to whether the Canadian i2 solution is economically viable is to be made solely by the Commission and not by Primus.   Bell   Canada and Bell Aliant further submitted that Primus has provided no reasons why the information filed in confidence in response to this interrogatory should be disclosed other than to refer to the deficiency process held earlier in this proceeding.

TELUS further submitted that it had provided the impacts of the per-user rate in accordance with the scenarios set out by the Commission and notes that such scenarios are not necessarily consistent with the rating approach used by TELUS and therefore the calculated rates are not necessarily reflective of the rate that would be proposed by TELUS.

Commission staff analysis and determination

Commission staff has reviewed the requests for disclosure by the various parties and the

responses to these requests by the Companies and ASPs.   Commission staff considers that the Companies and ASPs have provided adequate responses and provided further clarifications in their responses to the requests for further information.   Commission staff also notes that some of the requests for further responses are out of scope of this proceeding or are actually new questions.

With reference to ILECs (CRTC) 14May08-04, Commission staff considers that the primary purpose of this proceeding is to evaluate the economic viability of the Canadian i2 proposal, as well as to identify cost recovery proposals for the parties providing the various components of this service.  

Commission staff notes that the per-end-user rates for the base studies were disclosed on the public record following a Commission staff determination issued in a letter dated 24 April 2008.   Commission staff considers that it is important that parties have all the necessary information to properly evaluate the submissions.   Commission staff notes that the impacts of the different scenarios on the final rates provide valuable information on the sensitivity of the costs, but at a sufficiently aggregated level as to not cause harm to the Companies if disclosed.   Commission staff further notes that the disclosure of this information is consistent with the Commission staff's past determinations with respect to the information to be disclosed for services priced at Phase II costs plus a 15 percent mark-up.   This type of information has been disclosed in past proceedings.

Based on this assessment, Commission staff determines that the Companies are required to fully disclose the rates provided in response to ILECs(CRTC) 14May08-4.   In the case of Bell Aliant, it is to provide revised estimates as it has filed a revised cost study on 11 June 2008 .  

Yours truly,

Original signed by

Paul Godin
Director General
Competition, Costing and Tariffs
Telecommunications

cc. Marc Pilon (819) 997 4535

attach (1)

Distribution List

Cogeco Cable Inc.
Quebecor Media Inc.
Rogers Communications Inc.
Shaw Communications Inc.
Bell Canada
Bell Aliant
TELUS
MTSAllstream Inc.
SaskTel
Comwave
Primus Canada
Xittel Telecommunications Inc.
CAVP
Interested parties