ARCHIVED - Telecom Commission Letter addressed to Richard Biron (Sogetel Inc.)
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Ottawa, 23 October 2015
Our reference: 8657-S4-201505273
BY EMAIL
Mr. Richard Biron, Counsel
Sogetel Inc.
Téléphone Milot Inc.
111, du 12-Novembre Street
Nicolet, Québec J3T 1S3
affaires_reglementaires@sogetel.com
RE: Application by Sogetel regarding quality of service regulation
Dear Sir:
On 1 June 2015, the Commission received an application under Part 1 of the CRTC Rules of Practice and Procedure by Sogetel Inc. (hereinafter “Sogetel”), on its own behalf and on that of its subsidiary Téléphone Milot inc. (hereinafter “Milot”), to increase the network access service (NAS) limit set for the regulation of quality of service through complaints.
The two small incumbent local exchange carriers (ILECs) informed the Commission that they wished to merge for administrative reasons. Following the merger, the merged entity would exceed the 25,000 NAS limit established for the regulation of quality of service through complaints.Footnote 1 It would therefore be subject to the same quality of service monitoring procedures as large ILECs.Footnote 2 According to Sogetel and Milot, it would be unfair to subject the merged entity to the large ILEC regime. Sogetel and Milot therefore request that the Commission increase to 30,000 the NAS limit established for regulating quality of service through complaints.
No other company or party submitted comments regarding the application by Sogetel and Milot. The Commission did not receive clear and convincing evidence to support the request to increase the limit to 30,000 NAS. The Commission considers that it would not be appropriate to amend the general rule concerning the NAS limit, which opens the door to a less onerous framework for quality of service regulation (through complaints), in response to the unique situation of Sogetel and Milot.
However, the Commission considers that, given the specific circumstances of the entity formed by the merger of Sogetel and Milot, it would be reasonable to grant that entity an exemption from the application of the regime for non-forborne markets for ILECs with over 25,000 NAS. Thus, the framework for regulating quality of service through complaints that is applicable to small ILECs will continue to apply to the entity formed by the merger of Sogetel and Milot. The Commission will continue to monitor the NAS of the merged entity to determine whether the exemption should continue to apply.
Sincerely,
Original signed by Luc Bégin for/
John Traversy
Secretary General
Footnotes
- Footnote 1
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Small ILECs with fewer than 25,000 NAS must submit the following information for the previous calendar year to the Commission on the 31st of March of each year: the number of customers to whom service was not provided within 10 days from the date of the customer’s request; the total number of initial out-of-service trouble reports not cleared within 24 hours; the number of customers who reported trouble with their service; the number of customers who reported that their listing in the white pages was either omitted or erroneous; and the number and nature of written or verbal complaints addressed to officers and/or department heads of the telephone company and/or the Commission. See Regulatory framework for the small incumbent telephone companies, Decision CRTC 2001-756, 14 December 2001, for more details.
- Footnote 2
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The retail quality of service regime for non-forborne markets, for ILECs with more than 25,000 NAS, includes the following indicators and standards: installation appointments met – urban/rural areas (90% or more); out-of service trouble reports cleared within 24 hours – urban areas (80% or more); out-of-service trouble reports cleared within 48 hours – rural areas (80% or more); and repair appointments met – urban/rural areas (90% or more). These ILECs must file quarterly quality of service reports and monthly exception reports. See Follow-up to Telecom Decision 2008 105 – Retail quality of service regime in non-forborne markets for ILECs with over 25,000 NAS, Telecom Regulatory Policy 2009-304, 25 May 2009, for more details.
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