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Ottawa, 18 December 2009
Our Reference: 8740-T8-200910580
BY E-MAIL
Distribution
Re: TBayTel Tariff Notice 151 – Interrogatories
Dear Madams, Sirs:
On 24 July 2009, the Commission received an application by TBayTel under cover of Tariff Notice (TN) 151, in which the company proposed additions to TBayTel’s General Tariff – Section TB320, Wireless Access Service and revisions to the Company’ General Tariff Section TB 100, Section 9, 911 Public Emergency Reporting Service (911 service) pursuant to Commission-mandated requirements specified in Telecom Regulatory Policy 2009-40, Implementation of wireless Phase II E911 service (TRP 2009-40).
In its 24 July 2009 application, TBayTel did not provide cost studies in support of its proposed tariffs.
With respect to its 911 service tariff, TBayTel proposed to use the level of rate increase proposed by MTS Allstream in TN677A times a factor of two to account for the relationship between MTS Allstream’s and TBayTel’s customer base and cost levels. With respect to its Wireless Service Provider E911 (WSP E911) tariff, TBayTel proposed to use Sasktel’s proposed rates, as both SaskTel and TBayTel are to outsource this functionality to Bell Canada.
Commission staff notes that BayTel’s proposed rates are significantly higher than those of other ILECs for the same services except for SaskTel’s proposed WSP E911 service rates.
In their comments dated 29 September 2009 and 4 November 2009, Shaw and Rogers both asked the Commission to reject TBayTel’s 911 service proposed rates and to maintain the current 911 service rates or else request that TBayTel file an economic study to substantiate the need for their high proposed rates. In the case of the WSP E911 service, Rogers requested that TBayTel adopt Bell Canada’s WSP E911 service rate or file an economic study to justify its rates. TBaytel replied in a letter dated 3 December 2009 and submitted arguments in support of its proposed rates and requested that the Commission ignore Shaw and Rogers’ request to file an economic study.
Commission staff notes that TBayTel has information regarding its contracts with its third-party suppliers, which would make it possible for TBayTel to determine certain incremental costs associated with the additional service requirements mandated by the Commission in
TRP 2009-40.
In light of the above, Commission staff requests that TBaytel provide responses to the attached interrogatories concerning costs associated with its 911 and WSP 911 services by 13 January 2010. A copy should be served to all parties involved.
Yours sincerely,
Original signed by
Yvan Davidson
Senior Manager
Competitor Services and Costing
Telecommunications
c.c.: Marc Pilon, CRTC, marc.pilon@crtc.gc.ca
Attachment (1)
Distribution List
David.Wilkie@tbaytel.com ;Rob.Olenick@tbaytel.com ;bell.regulatory@bell.ca ; iworkstation@allstream.com ; regulatory.affairs@telus.com ; Dawn.hunt@rci.rogers.com ; Regulatory@sjrb.ca ; reglementa@telebec.com
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