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ARCHIVED - Telecom Commission Letter Addressed to Philippe Gauvin (Bell Canada)

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Ottawa, 18 September 2015

Our reference:  8740-B2-201509910

BY EMAIL

Mr. Philippe Gauvin
Bell Canada
Senior Legal Counsel
Floor 19
160 Elgin St.
Ottawa, Ontario  K2P 2C4
bell.regulatory@bell.ca

RE:  Bell Canada Tariff Notice 7472 – Revisions to General Tariff items 70 – Rate Schedules for Primary Exchange (Local) Service and 680 – Local Link Package

Dear Sir:

On 27 August 2015, the Commission received an application by Bell Canada, under Tariff Notice 7472, in which it proposed revisions to its General Tariff (GT) item 70 – Rate Schedules for Primary Exchange (Local) Service (PES) and Item 680 – Local Link Package. Bell Canada proposed to introduce a 10-day grace period of at the beginning of a minimum contract period (MCP) during which a customer would be permitted to terminate the MCP without penalty and select another service. It also proposed to allow small business customers to waive termination charges if the customer migrates to another service in the final six months of an MCP.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.

Bell Canada is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 30 September 2015.

Sincerely,

Original signed by Robert Martin for

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Wendy McClintock, CRTC, 819-639-6211, wendy.mcclintock@crtc.gc.ca

Attach. (1)

ATTACHMENT

Request for information – Bell Canada Tariff Notice 7472

In its application, Bell Canada requested approval for proposed revisions to General Tariff (GT) items 70 – Rate Schedules for Primary Exchange (Local) Service (PES) and 680 – Local Link Package, to introduce a 10-day grace period of at the beginning of an MCP during which a customer would be permitted to terminate the MCP without penalty and select another service. It also proposed to allow small business customers to waive termination charges if the customer migrates to another service in the final six months of an MCP (collectively, the “benefits”). These benefits would only be offered to customers that consent to the terms and conditions of the MCP through oral consent, where an audio recording of the consent is retained by the carrier, or electronic confirmation via the Internet

GT items 70.2(h)(2) and 680.2(a) include six different ways a customer may consent to the MCP. The options are:

  1. accepting a signed document as customer confirmation;
  2. oral confirmation verified by an independent third party;
  3. electronic confirmation through the use of a toll-free number;
  4. electronic confirmation via the Internet;
  5. oral consent, where an audio recording of the consent is retained by the carrier; or
  6. consent through other methods, as long as an objective documented record of customer consent is created by the customer or by an independent third party.
  1. Explain, with supporting rationale, why the proposed benefits do not apply to all customers, regardless of how consent was provided.
  2. Will existing small business customers also have the option to waive termination charges if they have consented in one of the two specified ways, or is this offer only available to new customers?
  3. Will Bell inform all small business customers entering into an MCP that the benefits are only available to those who consent through options (4) or (5) above, and not to those who consent through options (1), (2), (3), or (6)? If so, explain how. If not, explain why.
  4. In its cover letter, Bell Canada states that “The grace period would allow small Business customers to trial the service and if it proves unsuitable, to cancel it without prejudice and select another of our services.”

    Is it Bell’s intention that customers must select another service within the initial 10-day grace period in order for the benefits to apply? Staff notes that this is not explicit in the proposed tariff wording for items proposed item 70.2(h)(4)a. or item 680.2(b)(1).

  5. Proposed tariff items 70.2(h)(4)a. and b., and 680.2(b)(1) and (2) apply only to small businesses customers, while existing items 70.2(h)(5) and 680.2(c). also deal with the application of termination charges, but apply to all business customers.

    Explain, with supporting rationale, all differences between the following items, including between the customers, MCPs, conditions, and termination charges to which these items apply:

    1. proposed item 70.2(h)(4)a. and b., and item 70.2(h)(5).
    2. proposed item 680.2(b)(1), and (2) and Item 680.2(c).
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