Telecom Commission Letter Addressed to Distribution List

Ottawa, 2 November 2016

Our references: 8640-B2-201606534 and 8640-T66-201608606

BY EMAIL AND MAIL

Distribution List

Re: Bell Canada and TELUS Communications Company – Applications for forbearance from the regulation of pay telephone access line service – Request for information

Dear Sir/Madam:

The Commission received a Part 1 application from Bell Canada, dated 23 June 2016, requesting that the Commission refrain from exercising its powers and performing its duties under sections 24, 25, 27, 29, and 31 of the Telecommunications Act (the Act) in relation to the provision of pay telephone access line (PAL) service by Bell Canada (including the former Bell Aliant Regional Communications, Limited Partnership, or Bell Aliant) and Télébec, Limited Partnership, in Ontario, Quebec, and Atlantic Canada (collectively, the Bell Companies).

The Commission also received a Part 1 application, dated 15 August 2016, from TELUS Communications Company (TCC), requesting that the Commission refrain from exercising its powers and performing its duties under sections 24, 25, 27, 29, and 31 of the Act in relation to the provision of PAL service by TCC. In addition, TCC requested that the Commission regulate competitive pay telephone service providers (CPTSPs) under section 24.1 of the Act to require them to comply with the provisions in TCC’s tariff with respect to registration and consumer safeguard provisions.

Pursuant to paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, the Commission may require a party to provide information, particulars or documents that it considers necessary to enable the Commission to reach a full and satisfactory understanding of the subject matter of the proceeding.

Bell Canada, TCC, and their wholesale PAL customers are requested to provide comprehensive answers, including any supporting information, to the attached questions with respect to the above-noted forbearance applications.

Responses to the attached requests for information are to be filed with the Commission, serving a copy on all those listed in the distribution list, by 28 November 2016.

Any party to these proceedings (i.e., Bell Canada, TCC, or PIAC) may file interventions on the responses to the requests for information with the Commission, serving a copy on all those listed in the distribution list, by 8 December 2016.

As set out in section 39 of the Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Yours sincerely,

Original signed by

Sheehan Carter
A/Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c. Jean-François Roof, CRTC, (819) 639-4387, jean-françois.roof@crtc.gc.ca
Laurie Ventura, CRTC, (819) 819-997-4589, laurie.ventura@crtc.gc.ca
PIAC, Geoff White, gwhite@piac.ca; John Lawford, jlawford@piac.ca

Distribution List

Bell Canada, Phillippe Gauvin, bell.regulatory@bell.ca
Telus Communications Company, Stephen Schmidt, regulatory.affairs@telus.com;
All registered CPTSPs


Questions for the CPTSPs:

  1. Does your company subscribe to pay telephone access line service from Bell Canada, Télébec, and/or TCC, and if so, from which company?

    If the answer to question 1 is “yes,” please proceed to question 2:

    If the answer to question 2 is “no,” please proceed to question 3:

  2. Identify how many pay telephones you operate in each of the following Rate Band groups served by Bell Canada, Télébec, and/or TCCFootnote 1 .
    Rate Band groups
    A, B, C, or D E, F, or G
    Bell Canada (include Bell Aliant Rate Bands)
    Telebec
    TCC
  3. In its application, Bell Canada submits that business local exchange access services provide CPTSPs with the same functionalities as PAL service, and that PAL service is less feature-rich than a standard business line. Bell Canada also submits that PAL is essentially a wholesale resold business local exchange access service that should no longer be rate regulated since CPTSPs can enter into commercial negotiations with Bell Canada for the provision of PAL or source access lines from another provider in exchanges where business local exchange access service is not rate regulated.

    In its application, TCC submits that any CPTSP that wishes to lease a PAL can obtain the same functionality via a business line, including from TCC, or wireless access. TCC also submits that in a business local exchange that has been granted forbearance – that is, where rates are no longer regulated – business lines may also be obtained from other facilities-based competitors, such as competitive local exchange companies (CLECs) and cable companies. TCC further submits that in most local exchanges, whether rates are regulated or not, CPTSPs may also obtain a dial tone for their payphones through wireless access by using a SIM card instead of PAL service.

    Indicate whether you use either of the following in order to provide pay telephone access to your customers. If so, indicate the number of lines or cards, as applicable:

    1. standard business lines
    2. SIM cards
  4. If you use either of the options in question 3, explain why you use that service instead of PAL service in order to provide pay telephone service to your customers.
  5. Explain your future expansion plans with respect to providing pay telephone access to customers, and in which of the following areas would you consider expanding your service:
    1. Non-high cost service areas, represented by Rate Bands A, B, C and/or D
    2. High-cost service areas, represented by Rate Bands E, F and/or G

Questions for Bell Canada:

  1. In paragraph 59 of its application, Bell Canada requests forbearance with respect to the provision of PAL service by NorthernTel, Limited Partnership. However, there is no other reference to NorthernTel in the application, and the applicable NorthernTel tariff is not identified at paragraph 59. Clarify whether the application requests forbearance with respect to PAL service provided by NorthernTel and, if so, the tariff item that includes the service.
  2. How many pay telephone access lines do Bell Canada (including the former Bell Aliant) and Télébec (and NorthernTel, if applicable) provide in their operating territories in Ontario, Quebec, and Atlantic Canada? Provide the total number and a breakdown by exchange.
  3. Provide a current list of Bell Canada’s (including the former Bell Aliant) and Télébec’s (and NorthernTel’s, if applicable) PAL service customers and indicate the number of lines provisioned, by customer.

Questions for TCC:

  1. How many pay telephone access lines does TCC provide in its operating territory? Provide the total number and a breakdown by exchange.
  2. Provide a current list of TCC’s PAL service customers and indicate the number of lines provisioned, by customer.

Footnotes

Footnote 1

Rate Bands and associated pay telephone access line rates are set out in the companies’ tariffs as follows: Bell Canada General Tariff 6716 for items 60.1, 60.2, and General Tariff 6716 for item 70.2.(h); Bell Aliant General Tariff 21491 items 200.2 and 205.2; Télébec General Tariff 25140 items 2.1.6 and 2.1.7.1.a)[Télébec’s monthly rate is fixed at 81.5% of the monthly rate for an individual business line.], and TCC Carrier Access Tariff 21462 item 216.3.

Return to footnote 1

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