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Ottawa, 19 January 2010


Our Reference: 8740-T46-200914566


Mr. Hal Reirson
Senior Regulatory Advisor
TELUS Communications Company
10020-100 Street NW, Floor 21
Edmonton, Alberta T5J 0N5

RE: TCBC Tariff Notice 4334

Dear Mr. Reirson:

The Commission received an application by TELUS Communications Company (TELUS, or the company) under cover of Tariff Notice 4334, dated 30 October 2009, in which the company proposed revisions to its TELUS Communications (B.C.) Inc. General Tariff to withdraw item 238, V.H.F. Marine Public Radiotelephone Stations (Marine Radiotelephone Service), effective 1 March 2010.

TELUS is to provide responses to the attached interrogatories by 3 February 2010.

By letter, dated 8 January 2010, TELUS noted that comments from customers were still being posted on the Commission’s website and proposed to delay its reply comments until 22 January 2010.

Given the requirement to respond to the attached interrogatories, TELUS may file its reply comments coincident with its responses to the interrogatories.
Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager, Tariffs

c.c.: Joseph Cabrera, CRTC (819) 934-6352,

1. In its 30 October 2009 application to withdraw Marine Radiotelephone Service (MRTS), TELUS submitted that mobile satellite and cellular service were viable service alternatives to MRTS. In support of its application, the company provided pricing information for cellular and satellite services as well as maps showing the cellular services coverage of the British Columbia coast.

Commission staff notes that in several of the comments received, customers complained that satellite service was not dependable. For the MRTS serving area not covered by wireless services

a. Provide a discussion on the dependability of satellite service in comparison to MRTS service, especially in the context of inclement weather.

b. Identify any alternatives to satellite service and discuss their dependability.

2. In its application, the company referenced Withdrawal of service from certain marine public radiotelephone stations, Telecom Decision 2003-25, dated 25 April 2003, in which the Commission approved the withdrawal of MRTS in 23 locations. Specifically, the company noted the Commission findings in that decision that:

In this case, the company proposes to remove the remaining MRTS stations. In addition, several customers commented that the Coast Guard emergency radio service was not always reachable from any location.

a. Identify whether removal of the remaining MRTS stations would impact radio-to-radio communications, with explanations.

b. Provide a discussion of the potential impact of removal of the remaining MRTS stations on customer’s ability to communicate directly with the Coast Guard and on boating safety

3. Provide a discussion of potential replacement technologies that TELUS could deploy if directed to continue to provide MRTS or a similar service.


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