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Ottawa, 19 July 2011
File No.: 8740-A2-201110601
BY E-MAIL
Ms. Lori MacLean
Regulatory Co-ordinator
Eastlink
6080 Young St., Suite 801
Halifax, Nova Scotia B3K 5M3
lori.maclean@corp.eastlink.ca
RE: Amtelecom Limited Partnership Tariff Notice 65 – All Feature Pack bundle
Dear Madam:
On 8 July 2011, the Commission received an application by Amtelecom Limited Partnership (Amtelecom), under cover of Tariff Notice 65 (TN 65), in which the company proposed 1) to introduce a new residential bundle, namely All Features Pack bundle; and 2) to offer its Call Trace feature at no charge. The company indicated that its application was filed as a Group B tariff filing.
Commission staff notes that Section 22(2) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure sets out the information that applicants must include in their applications, and that Section 8 provides that the Commission may return an application or close a file that does not meet these requirements. Commission staff also notes that pursuant to Approval processes for tariff applications and intercarrier agreements, Telecom Information Bulletin CRTC 2010-455, 5 July 2010 (Information Bulletin 2010-455), Group B filings must be made by filing, among other things, any supporting documentation required by the practice of the Commission.
Commission staff notes that the Commission has sometimes deemed it acceptable for small ILECs to propose rates for new services in the fourth basket, pursuant to Decision 2001-756 and as reiterated in Decision 2006-14 , based on rates that the Commission has already approved for another ILEC for the same service instead of submitting cost data. Additionally, the Commission directed that such applications should reference when and where the Commission approved the rate. Commission staff notes that the company did not provide this information in support of the proposed rate for the All Features Pack bundle.
Further, the company should provide additional justification in regard to its proposal not charge for Call Trace feature, including:
- when the changes to Amtelecom’s billing and provisioning systems will be effective or, if these changes have already been implemented, the date these changes took effect.
- if the changes to its billing and provisioning systems are already implemented, whether any Amtelecom’s subscribers have used its Call Trace feature since the company implemented these changes and have been subsequently billed.
- an estimate of the costs required to upgrade Amtelecom billing and provisioning systems to allow the company to bill for its Call Trace feature.
- an estimate of the annual revenues associated with Amtelecom Call Trace feature for the last three years.
Because Amtelecom’s application does not comply with the Commission requirements pertaining to tariff applications described in Information Bulletin 2010-455, nor with Decisions 2001-756 and 2006-14, this file is closed. The company may file a new application providing all the required information under the cover of a new tariff notice.
Yours sincerely,
Original signed by
Suzanne Bédard
Senior Manager, Tariffs
Telecommunications
cc: Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca
Regulatory framework for the small incumbent telephone companies, Decision CRTC 2001-756, 14 December 2001, and Revised regulatory framework for the small incumbent local exchange carriers, Telecom Decision CRTC 2006-14, 29 March 2006
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