ARCHIVED - Telecom Commission Letter Addressed to Suzanne Morin (Bell Aliant) and Philippe Gauvin (Bell Canada)

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Ottawa, 25 August 2014

Our references: 8661-B54-201408105


Ms. Suzanne Morin
General Counsel - Regulatory & Privacy Chief
Bell Aliant
160 Elgin Street, 19th floor
Ottawa, Ontario,  K2P 2C4

Philippe Gauvin
Senior Counsel – Regulatory Law & Policy
Bell Canada
160 Elgin Street, 19th floor
Ottawa, Ontario,  K2P 2C4

RE: In-Call Location Update – Request to make interim the monthly rate for WSP E9-1-1 Phase II service

Dear Madam / Sir:

On 15 August 2014, the Commission received a letter from Bell Aliant and Bell Canada (the companies) in which the companies requested that the Commission make the monthly rate for Wireless service provider enhanced 9-1-1 (WSP E9-1-1) Phase II service interim, effective immediately on the basis that the rate is no longer just and reasonable. This request follows Telecom Order CRTC 2013-646, in which the Commission approved on a final basis, Tariff Notices 455 and 7402.

The companies submitted that a proper cost study to support this request will not be available until the second half of 2015 when all the costs will be finalized. However, the companies submitted that they have sufficient evidence at this time to demonstrate that the existing rate is too low.

The companies submitted that the actual cost associated with implementing In-Call Location Update (ICLU) have already significantly exceed their forecast and, by the time ICLU implementation has been completed in 2015, that additional costs relative to the total costs originally projected are expected to be significantly higher . Accordingly, the companies submitted that the currently monthly rate per wireless telephone number for WSP E9-1-1 Phase II service is not sufficient to permit appropriate recovery of these additional costs and is no longer just and reasonable.

Commission staff notes that the rate that the companies now wish to be made interim was given final approval as recently as in December 2013. Commission staff further notes that based on the information provided by the companies, if their request were to be approved, the rate would necessarily remain interim for a considerable period of time given that a proper cost study will not be available until the second half of 2015. 

Because making rates interim introduces an element of uncertainty as to what the eventual final rate will be for the period in question, there must be sufficient evidence on the record to justify such a course of action.  Generally, such decisions are made on the basis of cost studies duly filed with the Commission. In this case, however, the only evidence put forward are assertions by the companies that costs have increased. In Commission staff’s view, the companies’ assertions fail to meet the necessary evidentiary threshold to justify consideration of the companies’ application. Further, as noted above, the rate that the companies now seek to be made interim was finalized as recently as December 2013, which further militates against consideration being given to the companies’ application.

In light of the above, no further action will be taken with respect to the companies’ application and the file has been closed.


Original signed by

Lyne Renaud
Director, Competitor Service & Costing
Telecommunications Sector

c.c.:  B.Natraj (Nat Natraj), CRTC, 819-953-5081,

C. Seidl, CRTC,819-956-4480,

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