ARCHIVED - Telecom Commission Letter - 8740-T78-200804668

Letter

Ottawa, 25 June 2008

File No.: 8740-T78-200804668

By E-mail

Mr. Allen Mercier
Director - Regulatory
Telebec, Limited Partnership
7151, Jean-Talon Street East
Anjou, Quebec
H1M 3N8  
reglementa@telebec.com

Dear Mr. Mercier:

RE:   Tariff Notice 366 - 9-1-1 Public Emergency Reporting Service

On 27 March 2008, the Commission received an application by Telebec, Limited Partnership, under the cover of Tariff Notice 366, in which the company proposed tariffs for its 9-1-1 Public Emergency Reporting Service (PERS) as directed by the Commission in Telebec, Limited Partnership and TELUS Communications Company - Local network interconnection and network component unbundling , Telecom Decision 2007-132, 20 December 2007.

On 5 May 2008 , the Commission received the company's responses to interrogatories dated 21 April 2008 .   To assist the Commission in disposing of this application, the company is requested to provide responses to additional interrogatories set out in Appendix 1 within 15 days of receipt of this letter.

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager, Tariffs
Telecommunications

cc:    Henri Jacques, CRTC, (819) 953-4945, henri.jacques@crtc.gc.ca

Appendix 1
Page 1 of 1

Telebec's TN 366:   9-1-1 Emergency Service

Refer to the company responses dated 5 May 2008 , to Commission interrogatories dated 21 April 2008 .

1.    Refer to the response to Question 1 part b) where it is indicated that the monthly DS-0 and DS-1 circuit costs for the 9-1-1 service were estimated based on Telebec's General Tariff, item 8.5.1.4.2 discounted by 25%.   Additionally, in the response to question 1 part c), Télébec indicated that the Commission provided a minimum mark-up of 25% in setting Telebec's rates.   Staff considers that the approach adopted by Telebec to estimate Phase II DS-0 and DS-1 circuit costs for its 9-1-1 service, by removing the mark-up from an approved rate when the service specific mark-up has not been identified is inconsistent with Phase II costing methodology.   The Company is to provide revised DS-0 and DS-1 circuit costs for its 9-1-1 service consistent with Phase II costing methodology or provide evidence on the mark-up included in the rates for its General Tariff, item 8.5.1.4.2.

2.   Refer to the response to Question 3 Table 2 and justify with supporting rationale the need for additional cost elements indicated below associated with the management and administration of its 9-1-1 service for wireless customers. The response should justify with supporting rationale the need for:

a)   Additional contract management associated with the administrative activities carried out with municipalities and response centres. The response should address why the contract management costs identified in Question 1 part f) associated with the management of the contractual agreement with Bell Canada would not have included wireless customers.

b)   Additional internal resources required to manage circuits between Bell 's 9-1-1 response centres and the various PSAPs located in the company's serving area. The response should address why the internal resource costs identified in Question 1 part f) associated with Telebec users, competitive local exchange carriers, and wireless service providers would not have included wireless customers.

3.   With respect to Telebec's 9-1-1 service explain if the DS-0 and DS-1 circuit costs for routing 9-1-1 calls made by Videotron customers in Telebec's territory are included in its 9-1-1 costs study.   Additionally, the response should address Videotron's statements in paragraph 11 to 13 of its 22 April 2008 submission regarding how it routes directly to Bell Canada 9-1-1 calls made by its customers within the traditional territory of Telebec .