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

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Ottawa, 28 January 2016

Our reference:  8661-T69-201507287


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

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 additional Commission staff interrogatories associated with this proceeding. Please submit your response, including rationale and any supporting information, by February 18, 2016. The following modifications to the proceeding timelines will be made to ensure that parties have sufficient time to comment on TCC’s response. Specifically, any party will have until March 3, 2016 to file their comments regarding TCC’s responses, to which TCC will have until March 17, 2016 to file its reply.

Yours sincerely,

Original signed by

Kay Saicheua
Director, Competition & Emergency Services Policy
Telecommunications Sector

c.c.: Adam Mills,; Union des consommateurs,; Public Interest Advocacy Centre,; Bell Canada,; MTS Inc.,; Saskatchewan Telecommunications,; Télébec, Limited Partnership,


Questions to TCC

1) In its application, TCC provided an economic study in support of its proposed rate increase to 9-1-1 public emergency reporting service. In this economic study, TCC indicated that changes were necessary as a result of, among other things, the Commission’s requirement to introduce in-call location update (ICLU) functionality pursuant to Telecom Decision 2013-12Footnote 24. TCC also indicated, however, that certain costs identified in the economic study were associated with general operational requirements, potentially related to the company’s decision to route its customers’ 9-1-1 calls through Bell Canada’s tandem switches in order to deliver 9-1-1 calls to public-safety answering points (PSAPs).

Provide any necessary revisions to the economic study that separately identify those costs that are causal to the introduction of ICLU functionality. In addition, separately identify any other revised costs that are causal to the general delivery of 9-1-1 service.

If TCC is of the view that the costs associated with implementing Internet Protocol (IP) functionality (e.g. IP data links) within their network is causal to the introduction of ICLU functionality, the company is to provide supporting rationale, and separately identifying those associated costs.

2) In its application, TCC proposed that the costs associated with implementing ICLU functionality, which is directly related to the provision of 9-1-1 service to mobile wireless subscribers, be borne by subscribers to the company’s wireline services.

Provide rationale to justify why the company’s wireline service subscribers should be responsible for the costs associated with implementing ICLU functionality.

3) Provide the average total monthly revenues expected to be collected from subscribers by TCC pursuant their proposed rate increase. In addition, provide the average total monthly revenues collected by TCC from subscribers for the provision of 9-1-1 service in 2008, pursuant to the revenue calculation formula established in Telecom Decision 2007-132.Footnote 3


Footnote 1

The application was subsequently revised, and resubmitted, on 13 and 16 July 2015.

Return to footnote 1

Footnote 2

CISC Emergency Services Working Group – Consensus report regarding the In-Call Location Update feature trial and implementation, Telecom Decision CRTC 2013-124, 14 March 2013.

Return to footnote 2

Footnote 3

Télébec, Limited Partnership and TELUS Communications Company - Local network interconnection and network component unbundling, Telecom Decision CRTC 2007-132, 20 December 2007.

Return to footnote 3

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