ARCHIVED - Telecom Order CRTC 2012-376

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Ottawa, 11 July 2012

TELUS Communications Company – Digital Network Access service tariff amalgamation

File numbers: TCC Tariff Notices 429, 429A, and 429B
TCI Tariff Notices 640 and 640A
TCBC Tariff Notices 4352 and 4352A

1. The Commission received three applications by TELUS Communications Company (TCC), dated 9 April 2012, all of which were amended on 2 May 2012 and one of which was subsequently amended on 6 June 2012. In its applications, TCC proposed revisions to amalgamate its Alberta and British Columbia Digital Network Access (DNA) tariffs into its General Tariff (GT).¹ Specifically, the company proposed to

• introduce TCC GT item 500 – Digital Network Access; and
• remove TCC GT item 520 – OCN Digital Network Access, former TELUS Communications Inc. (TCI) GT item 500 – Digital Network Access, and former TELUS Communications (B.C.) Inc. (TCBC) GT item 447 – Digital Network Access (DNA).

2. TCC submitted that the proposed amalgamation would, among other things, (i) consolidate and align common definitions, (ii) correct cross-references, (iii) remove the requirement for customers to purchase separate accesses for voice and data services, and (iv) involve the withdrawal of certain rate elements that are no longer used.

3. TCC requested that the proposed revisions take effect on 23 July 2012.

4. The Commission received comments, dated 9 May 2012, from MTS Inc. and Allstream Inc. (collectively, MTS Allstream).² The public record of this proceeding is available on the Commission’s website at www.crtc.gc.ca under “Public Proceedings” or by using the file numbers provided above.

Should the Commission approve TCC’s application?

5. MTS Allstream generally supported TCC’s proposal, but requested that

• TCC confirm that no additional charges would result, particularly from TCC’s proposed new wording to describe where link rates apply;
• TCC’s proposed definition of DS-0 be revised to eliminate what appeared to be a contradiction regarding service speeds; and
• TCC’s amalgamated tariff include the existing lists of the company’s wire centres in Alberta and British Columbia, indicating the applicable DNA rate band for each wire centre.

Rate increases

6. In reply, TCC confirmed that it was not proposing to increase charges or rates for any DNA service component. However, TCC stated that it had reflected its recently filed proposed 2012 price cap rate changes in its proposed tariff revisions.³

7. The Commission considers that TCC’s reply has addressed MTS Allstream’s concern about rate increases. The Commission also considers that TCC’s proposed changes to its tariff items dealing with link rates would reduce customer confusion since information on all link rates would be found in one location.

Definition of DS-0

8. In response to MTS Allstream’s request for TCC to revise its definition of DS-0, TCC argued that its proposed plain-language definition would help avoid the confusion caused by previous definitions. The Commission notes that in TCC’s proposed revisions, the company identified the specific service speeds that would be provided in certain circumstances, which was not clear in its GT for British Columbia.

9. The Commission notes that as part of TCC’s proposed tariff item 500, the company defines DS-0 as a channel capable of digital transmission at a rate of 56 kilobits per second (Kbps). The Commission also notes that elsewhere in TCC’s proposal, the company indicates that certain services are capable of delivery at speeds of up to 64 Kbps. The Commission considers that there is no inconsistency and that the proposed definition does not preclude higher speed capacities in certain circumstances. The Commission also considers that MTS Allstream’s proposal to define DS-0 as a higher service speed could impose a new condition of service on TCC. Accordingly, the Commission considers that TCC’s proposed revised definition is acceptable.

Wire centre lists

10. Regarding the lists of wire centres and associated DNA rate bands, TCC submitted that it has proposed to retain this information in its Alberta and British Columbia GTs and to provide a related cross-reference in its proposed amalgamated tariff. The Commission considers that since this information will continue to be publicly available in TCC’s Alberta and British Columbia GTs, the company does not need to duplicate it in its amalgamated tariff.

Rate element withdrawal

11. The Commission notes that there were no comments on TCC’s proposal to withdraw certain rate elements. The Commission also notes that

• the services corresponding to some of these rate elements have no customers and are not available to new customers since they are grandfathered; and
• the services corresponding to the remaining rate elements have no customers and alternative service configurations are available at lower rates.

12. The Commission considers that TCC’s proposal complies with the requirements set out in Mandatory customer contract renewal notification and requirements for service destandardization/withdrawal, Telecom Decision CRTC 2008-22, 6 March 2008, in which the Commission revised its procedures for dealing with applications to destandardize and/or withdraw tariffed services.

13. Accordingly, the Commission considers that TCC’s proposal to withdraw certain rate elements is acceptable.

Requirement for separate voice and data accesses

14. The Commission considers that TCC’s proposal to remove the requirement for customers to purchase separate accesses for voice and data services would benefit customers by reducing their costs.

Conclusion

15. In light of the above, the Commission considers that TCC’s proposal to amalgamate its Alberta and British Columbia DNA tariffs into its GT is reasonable, and that the changes will benefit customers and simplify the company’s tariffs.

16. Accordingly, the Commission approves on an interim basis TCC’s proposal, effective 23 July 2012.

Secretary General

Date modified:

2012-07-10