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ARCHIVED - Telecom Commission Letter addressed to Tom Woo (TELUS Communications Company)

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Ottawa, 25 January 2016

Our reference: 8740-T46-201508509

BY EMAIL

Mr. Tom Woo
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
10020-100 Street NW, Floor 30 SW
Edmonton, Alberta T5J 0N5
tom.woo@telus.com

RE: Tariff Notice 4381 – Radiotelephone Services

Dear Sir:

On 7 August 2015, the Commission received an application by TELUS Communications Company (TCC), under Tariff Notice 4381 (TN 4381), in which the company proposed to withdraw General Tariff items related to Radiotelephone Services.

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.

TCC is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 1 February 2016.

Any other party may file comments with respect to the responses of TCC to the attached interrogatories by 8 February 2016. TCC will have until 15 February 2016 to file its final reply.

Comments can be submitted electronically via the Commission’s website at www.crtc.gc.ca, by mail to Secretary General, CRTC, Ottawa, Ontario K1A 0N2, or by fax to 819-994-0218.

Sincerely,

Original signed by

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)

Requests for information

  1. Provide a list of exchanges affected by the withdrawal application and provide details as to whether these exchanges are regulated or forborne from regulation.

  2. Provide a breakdown of the following information :

    1. total number of residential and business customers subscribing to the Radiotelephone Services that TCC proposes to withdraw, as well as the number of channels used by residential and business customers; and
    2. total number of residential customers who use the services as their primary telephone service.

  3. Confirm what types of equipment (e.g., fixed phone installation, signal booster equipment) would be eligible for reimbursement under the proposed compensation plan.

  4. In Telecom Decision CRTC 2008-22, Mandatory customer contract renewal notification and requirements for service destandardization/withdrawal, 6 March 2008,the Commission noted that its determinations in that proceeding do not alter previous Commission rulings regarding the ILECs’ obligations in the provision of primary exchange service (PES) and the basic service objective (BSO).

    In Telecom Regulatory Policy CRTC 2011-291, Obligation to serve and other matters, 3 May 2011,the Commission noted that all Canadians, regardless of whether they live in forborne or regulated exchanges, are entitled to receive PES and set out ILECs’ obligations related to PES and the BSO.

    In its 7 August 2015 cover letter, TCC noted it had previously requested and received approval for the withdrawal of similar obsolete radio services. In one of these prior instances, Telecom Order 2008-206, 25 July 2008, the Commission approved TCC's proposal to withdraw Exchange Area Radio Service (EARS) based on TCC’s identification of reasonable alternatives and a satisfactory transition plan.

    Given the following:

    1. the similarity of the circumstances of the EARS service withdrawn in Telecom Order 2008-206 to the Radiotelephone services proposed to be withdrawn in TN 4381;
    2. the differences in the transition plan approved in Telecom Order 2008-206 compared with the transition plan proposed in TN 4381;
    3. the obligation to serve and the BSO requirements for voice services set out in Telecom Regulatory Policy CRTC 2011-291; and
    4. the fact that mobile satellite and cellular service are being identified as alternatives in areas that may include forborne or regulated exchanges,

    Explain why the transition plan proposed in TN 4381 should be considered satisfactory in meeting TCC’s obligations in the provision of primary exchange service. The company’s response is to address the following:

    • BSO and obligation to serve as set out in Telecom Regulatory Policy 2011-291
    • Amounts approved for the transition plan in Telecom Order 2008-206 compared to the amount proposed in the current application.
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