ARCHIVED - Telecom Commission Letter Addressed to Michelle Duguay (TELUS Communications Company)

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Ottawa, 24 February 2015

Our reference: 8740-T69-201411702


Ms. Michelle Duguay
Senior Advisor, Regulatory Affairs
TELUS Communications Company
6 Jules-A.-Brillant Street, R 0622
Rimouski, Quebec G5L 7E4

Re: Tariff Notice 610 – Public emergency reporting service

Dear Madam:

On November 14, 2014, the Commission received an application by the TELUS Communications Company (TCC) under cover of Tariff Notice 610 (TN 610), in which it proposed amendments to sections 2.25, 9-1-1 Service, and 2.30, Wireless Service Provider (WSP) Enhanced 9-1-1 Service, of its General Tariff; and section 1.05, Local Network Interconnection and Component Unbundling of its Access Services Tariff. These amendments include the elimination of the carrier’s tariffs for the 9-1-1 service to competitors, as this service is provided and billed by Bell, as well as revised retail 9-1-1 rates.

Under paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, the Commission may require a party to provide information or documents that it considers necessary.

TCC is requested to provide, within 10 business days of the date of this letter, comprehensive answers to the questions attached in Appendix 1, including rationale and any supporting information.

The Commission intends to dispose of this application, along with any subsequent revisions, by the end of April.

Sincerely yours,

Original signed by

Michel Murray
Dispute Resolution and Regulatory Implementation
c.c.: Jean-François Roof, CRTC, 819-639-2538, jean-franç

Appendix 1


Retail 9-1-1 service

  1. Please explain TELUS’s reasons for connecting to Bell’s tandem switches rather than continuing to connect directly to the emergency call centre.

  2. In section 1.1 of its report on the economic evaluation, TCC indicated that the purpose of the economic study was to support the costs associated with setting up a new 9-1-1 service on its Quebec territory, and that the change in service provision was made necessary, among other things, by the introduction of the In-Call Location Update feature, in accordance with the Commission’s directive in Telecom Decision 2013-124.

    In Telecom Decision 2013-124, the Commission directed wireless carriers and incumbent local exchange carriers to make the necessary changes to the networks, systems and processes to support the provision of the location update feature for 9-1-1 calls made from a wireless device.

    Indicate whether the costs filed in support of the proposed monthly retail rate of $0.2508 per access line include the costs associated with the location update feature for 9-1-1 calls made from a wireless device. If so, i) indicate separately the monthly cost per access line, which is recovered through the proposed monthly rate of $0.2508, and ii) explain why it is appropriate to recover that cost through the 9-1-1 call service rate billed to retail clients of TCC’s wireline service.

  3. In section 6.4.2 of its report on the economic evaluation, TCC indicated that expenditures in the  “equipment” cost component are associated with the need for a digital infrastructure for connections between TCC local switches and Bell Canada 9-1-1 tandem switches.

    Please give a more detailed description of the cost components and the hypotheses and methodology used to estimate the cost in question.

  4. In section 7 of its report on the economic evaluation, TCC indicated that the causal costs of third-party acquisition included the costs billed by Bell Canada for routing 9-1-1 calls from TCC local switches to the emergency call centre (ED), through Bell Canada tandem switches. TCC stated that it would no longer be connecting directly to the ED.

    Please provide a list of cost components billed by Bell Canada and a description of the functions of each component, including the costs associated with each.

  5. In section 6.1 of its report on the economic evaluation, TCC justified the use of a 25% markup by the fact that the service in question is classified as a public service.

    With supporting rationale and references to the regulatory framework in effect, including the Commission’s conclusions in Telecom Order 2009-226, explain why it is appropriate to price the TCC retail 9-1-1 service using a 25% markup despite the rate freeze for social services and public safety services.

9-1-1 service to competitors

  1. Telecom Decision CRTC 2005-4 established, among other things, the rate for local interconnection services, including 9-1-1 services. In section 107 of the decision, the Commission “considers that, in the event that a service is not provided directly by the Companies, proposed tariffs should still include the service by making reference to another ILEC tariff or by identifying the specific pass-through charge.”

    In Telecom Order 2013-505, the Commission ordered Wightman Telecom Ltd to issue tariff pages as part of a new application to enable an ILEC to obtain 9-1-1 services directly from Bell Canada.

    1. In light of these decisions, please explain how it would be appropriate for TELUS to completely delete section 2.25.01d.2).
    2. What are the options available for 9-1-1 services for a new CLEC wishing to operate on TELUS territory?
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