Telecom Commission Letter Adressed to Tom Woo (TELUS Communications Company)

Ottawa, 28 March 2017

Our reference:  8740-T66-201612292

BY EMAIL

Mr. Tom Woo
Senior Regulatory Advisor
Telecom Policy & Regulatory Affairs
TELUS Communications Company
10-10020-100 Street NW
Edmonton, Alberta
Canada T5J 0N5
tom.woo@telus.com

RE: TELUS Communications Company Tariff Notices 516 and 516A – Annual Provincial AB/BC 9-1-1 Service Rates

Dear Sir,

On 1 December 2016 and 8 December 2016 respectively, the Commission received applications by TELUS Communications Company (TELUS) under Tariff Notice 516 (TN 516) and Tariff Notice 516A (TN 516A), in which TELUS proposed a revision to its General Tariff CRTC 21461, Item 203 – Provincial 9-1-1 Service. TELUS filed its applications as group A filings.

In its applications, TELUS proposed a 2017 Provincial 9-1-1 Service rate for each access to the public switched telephone network (PSTN) of $0.09 per month, and for each wireless telephone number of $0.05 per month. The company submitted that it had completed the recalculation of its service rates for 2017 in accordance with the Commission-approved methodology set out in Telecom Decision CRTC 99-17,  9-1-1 Service – Rates for Wireless Service Providers Centrex Customers and Multiline Customers/Manual Access to the Automatic Location Identification database, October 29, 1999 (Decision 99-17), and Telecom Order CRTC 2000-630,  Rates Modified for Province-Wide 9-1-1 Service, July 6, 2000 (Order 2000-630). In addition, TELUS submitted that the recalculation was in accordance with the weight-averaging approach approved in Telecom Order CRTC 2004-49, TELUS Communications Inc., Amalgamation of Provincial 9-1-1 Service, February 18, 2004.

The Commission received comments from Rogers Communications Canada Inc. (Rogers) and Freedom Mobile Inc. (Freedom Mobile) regarding TELUS’ 2017 monthly wireless telephone number portion of the Provincial 9-1-1 Service rates. Both Rogers and Freedom Mobile submitted that further to Decision 99-17, the wireless rate must be 50 percent of the PSTN Access rate and should therefore be $0.045 for 2017 rather than $0.05, as proposed by TELUS.

In response to the comments from Rogers and Freedom Mobile, TELUS submitted that its calculations resulted in 2017 integrated 9-1-1 network access and wireless access rates of $0.0919 per wireline PSTN access per month and $0.0460 per wireless telephone number per month, expanding to 4 decimal places. TELUS indicated that using accepted conventional rounding methods, it rounded these amounts to the nearest cent or two decimal places for billing purposes.

Commission staff notes that the provisions of Decision 99-17 and Order 2000-630 apply to TELUS, Bell Canada and MTS Inc., and that the rates approved by the Commission in Order 2000-630 for each PSTN Access were based on two decimal places. Staff has reviewed the methodology used since 2001 by TELUS, Bell Canada and MTS Inc. for the monthly wireless telephone number portion of the Provincial 9-1-1 Service rates, which must be 50 percent of the wireline 9-1-1 rate on a per telephone number basis.  This review has shown that, where the PSTN Access rate calculation resulted in an odd number, the wireless rate that has been filed by these companies has been rounded to three decimal places. An exception to this practice was the filing for 2016 in which TELUS rounded its monthly wireless telephone number portion of the Provincial 9-1-1 Service rates to two decimal places.

Commission staff considers that, given that the financial impacts of the wireless 9-1-1 service rates are significant, it is important that these rates accurately reflect the Commission’s determinations in Decision 99-17 that the 9-1-1 network access rates must be discounted by 50 percent for WSPs. Commission staff is of the view that setting the wireless 9-1-1 service rates rounded to three decimal places achieves this result. This approach is also consistent with the practice used over the past 16 years by the companies that were subject to Decision 99-17 and Order 2000-630.

Accordingly, TELUS is requested to file by 7 April 2017 a revised tariff page for Item 203 using a rate rounded to three decimal places for each wireless telephone number, effective 7 April 2017, for the year 2017.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

cc:  Edward Antecol, Freedom Mobile Inc., eantecol@freedommobile.ca
Howard Slawner, Rogers Communications Canada Inc., rci_gr@rci.rogers.com
Wendy McClintock, CRTC (819) 639-6211, wendy.mcclintock@crtc.gc.ca

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