ARCHIVED - Telecom Commission Letter addressed to Glenn Grubb (Huron Telecommunications Co-operative Limited)

Ottawa, 29 September 2015

Our reference: 8740-H4-201509309

 BY EMAIL

Mr. Glenn Grubb
General Manager
Huron Telecommunications Co-operative Limited
60 Queen Street
Ripley, ON  N0G 2R0
regulatory@hurontel.on.ca

RE:  Tariff Notice 39 – Introduction of Access Services Tariff

Dear Sir:

On 21 August 2015, the Commission received an application by Huron Telecommunications Co-operative Limited (HuronTel), under Tariff Notice 39 (TN 39), in which the company proposed to introduce its Access Service Tariff.
In Telecom Regulatory Policy 2013-160, the Commission stated the following:

...the Commission finds it appropriate that the initial rates for small ILECs’ competitor services assigned to basket 5 be established by matching Commission-approved rates for the same service, with supporting rationale. The supporting rationale must address the appropriateness of the proposed small ILEC rates in light of rates in an adjacent large ILEC territory for the same service. Once rates for the services assigned to basket 5 are established, rate changes will be permitted if a small ILEC provides a cost study or other evidence that demonstrates that costs have changed.

Commission staff notes that HuronTel has not explained the basis for its proposed rates, as required by the Commission in Telecom Decision 2013-160 and reminds HuronTel to provide the required rationale for its proposed rates in future applications.

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.

HuronTel is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 13 October 2015.

Approval processes for tariff applications and intercarrier agreements, Telecom Information Bulletin CRTC 2010-455, 5 July 2010, specifies that every page of any proposed new or amended tariff page must show the tariff notice (TN) number at the bottom centre of the page.

HuronTel’s proposed tariff pages in its application are missing this number. When submitting revised tariff pages to address the attached request for information, the company is to include the TN number as required.
Sincerely,

Original signed by Robert Martin for

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications sector

c.c.: Jean-François Roof, CRTC, 819-639-2537, jean-francois.roof@crtc.gc.ca

Attach. (1)

Request for information

1. Identify which ILEC’s rates have been used for the proposed Item 100.4.1 – Termination of CLEC Intra LIR Traffic, and provide HuronTel’s justification for the proposed rates.
2. Proposed rates are not specified for item 100.4.2.1 – Local Transit Service.^{Footnote 1} Provide proposed rates for Local Transit Service with justification.
3. HuronTel proposes three notes that refer to Ontario Independent Service Tariff 25611 for item 100.4.2.2 – Toll Transit Service. Confirm whether the rates for this service are to be based on those in the OIST. If not, provide proposed rates with justification. If so, provide a simplified reference to the OIST section, or correct the references.
4. In Telecom Regulatory Policy CRTC 2012-523 (TRP 2012-523), the Commission directed that, for LECs that do not provide Access to OSS Service, the higher Local Service Request (LSR) Rejection Charge threshold for LECs that submit small monthly volumes of LSRs to a given company – that is, 500 or fewer in a month – is to be set at twice the threshold for LECs that submit large volumes of LSRs. The higher threshold was set at 25.6 percent on the date that the tariff is first approved by the Commission, decreasing to 20.8 percent one year after the tariff is approved and 16 percent two years after the tariff is approved.

Item 200.4.1.5 of the proposed Access Service Tariff proposes a single LSR rejection rate threshold of 16 percent. Moreover, Item 200.4.1.6 proposes a monthly rate of $70.00.

1. Confirm whether HuronTel provides Access to OSS Service.
2. Provide proposed revisions to item 200.4.1.5 so that it is consistent with the determinations in TRP 2012-523.

5. HuronTel has not proposed to provide Basic Listing Interchange File (BLIF) service in its tariff.  Confirm whether this service will be provided to competitors through the OIST. If so, include the relevant OIST tariff reference in its proposed tariff. If not, provide a proposed tariff item, including a proposed rate with supporting rationale.
6. HuronTel is proposing to use the same tariff number for its Access Services Tariff as it uses for its General Tariff – that is, CRTC 25410.

Does HuronTel intend to

1. Include the proposed Local Network Interconnection and Local Number Portability tariffs as new sections in its General Tariff?, or
2. Establish a new and separate Access Services Tariff?

If a., HuronTel should submit revised tariff pages to indicate that Local Network Interconnection and Local Number Portability are new sections of the General Tariff, including revised table of content and index pages, as appropriate. Numbering of the new section and tariff items should be consistent with HuronTel’s General Tariff numbering.

If b., the company should resubmit its proposed tariff under a new CRTC tariff number.

Date modified:

2015-09-29