ARCHIVED - Telecom Commission Letter Addressed to Stephen Schmidt (TELUS Communications Company)

Ottawa, 21 September 2015

Our reference:  8661-T69-201507287

BY EMAIL

Mr. Stephen Schmidt
Vice-President, Telecom Policy & Chief Regulatory Legal Counsel
TELUS Communications Company
215 Slater Street, 8th Floor
Ottawa, Ontario  K1P 0A6
regulatory.affairs@telus.com

Re:  Part I application to review the rates for 9-1-1 public emergency reporting service for TELUS

Dear Mr Schmidt:

On 23 June 2015,^{Footnote 1} the Commission received an application by the TELUS Communications Company (TCC) to increase the rates the company charges for 9-1-1 public emergency reporting service within its Quebec incumbent operating territory.

You will find attached Commission staff interrogatories associated with this proceeding. Please submit your response, including rationale and any supporting information, by 5 October 2015. The following modifications to the proceeding timelines will be made to ensure that parties have sufficient time to comment on TCC’s response. Specifically, parties will have until 19 October 2015 to file their comments regarding TCC’s responses, to which TCC will have until 2 November 2015 to file its reply.

Yours sincerely,

Original signed by
Kay Saicheua
Director, Competition & Emergency Services Policy
Telecommunications Sector

c.c.:  Union des consommateurs, union@consommateur.qc.ca; Public Interest Advocacy Centre, piac@piac.ca; Bell Canada, bell.regulatory@bell.ca; MTS Inc., iworkstation@mtsallstream.com; Saskatchewan Telecommunications, document.control@sasktel.com; Télébec, Limited Partnership, reglementa@telebec.com

Appendix

Questions to TCC

1. In Telecom Decision 2007-132,^{Footnote 2} the Commission directed TELUS Quebec to set its 9-1-1 rates based on one of two methods, either (a) at the level approved for Bell Canada and updated annually to reflect the changes operated to Bell Canada's retail 9-1-1 rate, or (b) based on company-specific costs supported by cost-justification, and subject to the annual recalculation using a modified formula. Subsequent to this decision, TELUS Quebec chose to adopt Bell Canada’s rates for 9-1-1 service.

Justify why TCC should be permitted to modify its choice and opt to use company-specific costs at this time.

2. In Telecom Decision 99-17,^{Footnote 3} later modified by Telecom Order 2000-630,^{Footnote 4} the Commission directed the incumbent local exchange carriers (ILECs) to calculate their 9-1-1 rates on an annual basis in accordance with a new revenue-neutral formula. Under this formula, 9-1-1 rates are determined by dividing 9-1-1 revenue (which does not change from year to year) by revised estimates of demand (total Network Access Service).  While this formula initially applied to large ILECs only, it was later extended to TELUS Quebec in Telecom Decision 2002-43.^{Footnote 5}

Given the above, demonstrate that TCC’s proposed 9-1-1 rate increase is revenue-neutral based on the revenue calculation established for the service in 2007. If the company’s proposal is not revenue neutral, explain why the Commission should make an exception for TCC from the revenue neutral requirement at this time.

3. In its application, TCC makes reference to a price ceiling for 9-1-1 rates. Provide examples where the Commission has found that 9-1-1 rates are subject to a price ceiling. 
4. Given that the CRTC’s current three year plan contemplates a comprehensive examination of next-generation 9-1-1 services in Canada, provide your views as why it is appropriate to consider TCC’s proposed changes to its 9-1-1 rates and calculation methodologies at this time, rather than adopt a more uniform approach for all providers by considering the broader costs and recovery model(s) required to support next generation 9-1-1 services in the context of this future proceeding?
5. Notwithstanding the changes to the company’s underling 9-1-1 service delivery, confirm that TCC will continue to be responsible from a legal and regulatory standpoint, for the provision of 9-1-1 services to its wholesale local service customers, rather than require these customers to enter into direct agreements with Bell Canada for 9-1-1 services.

Date modified:

2015-09-21