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

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Ottawa, 22 May 2015

Our reference: 8740-T69-201411702


Michelle Duguay
Senior Advisor, Regulatory Affairs
TELUS Communications Company
6 Jules-A-Brillant Street, R 0611
Rimouski, Quebec  G5L 7E4

Re: Tariff Notice 610/610A – Public Emergency Reporting Service

Dear Ms. Duguay:

On 14 November 2014, 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. On 17 March 2015, the Commission received from TCC an amendment, TN 610/A. The company indicated that its application qualified as a Group B tariff filing.

The purpose of this letter is to inform you that this file will be closed.

The amendments proposed by TCC included the elimination of the company’s tariffs for the
9-1-1 service to competitors (since this service is now provided and billed by Bell) and revised retail 9-1-1 rates.

The company noted that in Telecom Decision 2007-132, entitled Télébec, Limited Partnership and TELUS Communications Company – Local network interconnection and network component unbundling, the Commission ordered TCC to file for approval, within 90 days of that decision, revised retail 9-1-1 rates that are set at the level approved for Bell Canada’s retail 9-1-1 rate, updated annually to reflect the changes made to Bell Canada's retail 9-1-1 rate, or that are based on the company’s own costs, supported by cost justification and subject to annual recalculation using the modified formula.

TCC chose to file retail 9-1-1 rates set at the level approved for Bell Canada, but in its current application, it filed an economic study for the rates to be based on the company’s own costs.

On 28 February 2015, the Commission sent TCC a request for information to obtain further details regarding, in particular, the company’s cost structure for the 9-1-1 emergency service and the reasons for its proposed rate increase. 

On 17 March 2015, the Commission received from TCC a reply to the request for information, as well as the amendment revising the economic study for the retail 9-1-1 service. TCC also revised section 2.25 of its General Tariff and section 1.05.04(c) of the Access Services Tariff to refer competitors and wireless service providers (WSPs) directly to Bell Canada to obtain 9-1-1 emergency service.

Rates for 9-1-1 service have been frozen since 1 January 1998, pursuant to Telecom Decision
97-9. This policy was confirmed in the most recent price cap framework decision, i.e. Telecom Decision 2007-27. 

Furthermore, according to the provisions of Telecom Decision 2008-17 and subsequent decisions, 9-1-1 service is classified as a service in the “public good” category and therefore, incumbent local exchange carrier (ILECs) must provide 9-1-1 to competitors and WSPs operating in their territory through a wholesale service. Although ILECs can obtain the service from a third party, they are expected to include the service in their proposed tariffs by referring to the tariff of another ILEC or by indicating the specific pass-through charge.

Staff considers that TCC’s application should not be subject to a tariff amendment process, given the significant policy issues raised by the application, in particular the revision of the rates frozen following a change in the service’s cost structure and the requirement for ILECs to provide 9-1-1 emergency service to competitors within their territory.

Staff notes that TCC has the option of filing a new application, pursuant to Part 1 of the Canadian Radio-Television and Telecommunications Commission Rules of Practice and Procedure, to address the policy issues that are outside the scope of this TN.

In conclusion, the file for TN 610/610A will be closed.


Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector
c.c.: Michelle Dupuis,
Jean-François Roof, CRTC, 819-639-2537,

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