Telecom Commission Letter addressed to Distribution List

Ottawa, 12 April 2017

Our reference: 8640-B2-201606245

BY EMAIL

RE: Bell Canada – Application for forbearance from the regulation of billing and collection service – Request for information

Madam, Sir:

The Commission received a Part 1 application from Bell Canada, dated 14 June 2016, in which the company requested that the Commission forbear from regulating the billing and collection service (BCS) provided by the company and its affiliates (collectively, the Bell companies) throughout its operating territory.Footnote1

Pursuant to paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure and section 37 of the Telecommunications Act, 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, as well as the competitive local exchange carriers (CLECs) and BCS wholesale customers included in the distribution list are requested to provide comprehensive answers, including any supporting information, to the attached questions with respect to the forbearance application by 12 May 2017.

Any party may file interventions on the responses to the requests for information with the Commission, and serve copies on all other parties by 26 May 2017. Any party may file reply comments with the Commission, and serve copies on all other parties by 2 June 2017.

As set out in section 39 of the Telecommunications 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.

Sincerely,

Original signed by Laurie Ventura for

Kay Saicheua
Director, Competition and Emergency Service Policy
Telecommunications Sector

c.c.: Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca 
Jeremy Lendvay, CRTC, 819-997-4946, jeremy.lendvay@crtc.gc.ca
PIAC, jlawford@piac.ca, gwhite@piac.ca
CNOC, regulatory@cnoc.ca

Distribution list:
Phillippe Gauvin, Bell Canada, bell.regulatory@bell.ca
Stephen Schmidt, TCC, regulatory.affairs@telus.com
Eastlink, regulatory.matters@corp.eastlink.ca
Québecor, regaffairs@quebecor.com
Shaw, regulatory@sjrb.ca
Cogeco, telecom.regulatory@cogeco.com
Rogers, rwi_gr@rci.rogers.com
Caztel, presidente@caztel.com; stephen.abbott@caztel.com
Distributel, regulatory@distributel.ca
Fastrack and Triton, gfietz@tritonglobal.ca
Telehop, brovet@rovetlaw.com 
Yak, yakregulatory@globalive.com
MTS Inc, regulatory@mts.ca
Saskatchewan Telecommunications document.control@sasktel.com

Questions for Bell Canada:

  1. Refer to paragraph 20 of Bell Canada’s application where the company has listed the BCS tariffs for which it is seeking forbearance.
    1. Confirm that Bell Canada’s forbearance application does not apply to billing and collection arrangements provided to local authorities for the collection of 9-1-1 municipal charges from its end-users.
    2. Bell Canada is requesting forbearance from the regulation of the Bell companies' BCS throughout its operating territory. Explain why Bell Canada is seeking forbearance for its CLEC tariff, given that the company’s CLEC tariff does not apply within the Bell companies’ incumbent operating territory.
  2. Refer to paragraph 49 of Bell Canada’s application where the company provides the number of its BCS wholesale customers in Ontario and Quebec, and associated revenues.
    1. Provide the names of the BCS wholesale customers served by the Bell companies in all areas covered by the application (i.e. in Ontario, Quebec, New Brunswick, Nova Scotia, Prince Edward Island, and Newfoundland and Labrador).
    2. For the entire operating territory described in the application, and for each of the years 2010 to 2016, provide a breakdown, for each of the BCS wholesale customers identified in a) above, of: (i) the revenues associated with BCS, and (ii) the number of eligible calls processed through BCS.
  3. Refer to paragraph 22 of Bell Canada’s reply dated 22 August 2016, where the company provides the percentage of “our total BCS calls” that were related to collect and bill-to-third calls for the time period over which this information was readily available (i.e. 13.5 months at the time Bell Canada filed its reply).
    1. Indicate for which of the Bell companies this percentage applies.
    2. Confirm whether this percentage refers to the number of calls the Bell companies processed for their BCS wholesale customers.
      1. If so, provide, for the time period over which this information is now readily available (i.e. that 13.5 months and any month after that period), a monthly breakdown of eligible calls processed through BCS for each of the following categories: casual dial-around toll calls, 900 service calls, collect calls, and bill-to-third calls.
      2. If not, explain what this percentage refers to.
  4. Refer to paragraph 15 of TCC’s intervention, where TCC indicates that the regulatory status of BCS must depend on the eligible service that each BCS transaction supports. If the Commission were to forbear from regulating only a subset of BCS-eligible services, provide your view, with supporting rationale on:
    1. the ability of the Bell companies to distinguish BCS transactions based on the eligible service supported; and
    2. the need to request that the CISC Business Process Working Group review and amend the guidelines and processes associated with BCS to accommodate the provision of BCS depending on the service for which BCS is being provided.
  5. With respect to the Bell companies’ retail wireline long distance services, for each of the years 2010 to 2016, provide the number of
    1. your retail wireline long distance service customers; and
    2. long distance calls originating from your retail wireline long distance service customers (i.e. excluding long distance calls made to the companies’ BCS wholesale customers).

Questions for Eastlink, Québécor, Rogers, and Cogeco

  1. Refer to paragraph 15 of TCC’s intervention where TCC indicates that the regulatory status of BCS must depend on the eligible service that each BCS transaction supports. If the Commission were to forbear from regulating BCS only for a subset of BCS eligible services, provide your view, with supporting rationale on:
    1. the ability of your company to distinguish BCS transactions based on the eligible service supported; and
    2. the need to request that the CISC Business Process Working Group review and amend the guidelines and processes associated with BCS to accommodate the provision of BCS depending on the service for which BCS is being provided.
  2. Provide the names of your BCS wholesale customers in the operating territory defined in the application.
  3. For each of the years 2010 to 2016, and for each of the BCS wholesale customers identified in 2) above, provide a breakdown of (i) the revenues associated with BCS, and (ii) the number of eligible calls processed through BCS in the operating territory defined in the application.
  4. For each of the years 2015 and 2016, provide a breakdown of BCS calls processed by your company for your BCS wholesale customers in the operating territory defined in the application, for each of the following categories: casual dial-around toll calls, 900 service calls, collect calls, and bill-to-third calls.
  5. With respect to your retail wireline long distance services, for each of the years 2010 to 2016, provide the number of
    1. your retail wireline long distance service customers; and
    2. long distance calls originating from your retail wireline long distance service customers (i.e. excluding long distance calls made to your company’s BCS wholesale customers).

Questions for Caztel, Distributel, Fastrack and Triton, Telehop, and Yak:

Note: While the information below is also requested regarding TCC’s application to forbear from the regulation of BCS (reference 8640-T66-201608408), responses must be filed separately on the record of both Bell Canada’s application and TCC’s application.

  1. For each of the years 2010 to 2016, and for each of the BCS-eligible wireline services (i.e. casual dial-around toll calls, 900 service calls, collect calls, and bill-to-third calls), provide a breakdown of
    1. your annual revenue per eligible service;
    2. the annual number of calls made per eligible service; and
    3. the annual number of individual customers per eligible service.

    Provide the information for each BCS eligible wireline service in the table below (one table per service):

      Revenue # of calls # of customers
    2010      
    2011      
    2012      
    2013      
    2014      
    2015      
    2016      
  2. In addition to using BCS, does your company accept alternative payment methods (e.g. bills sent directly from your company, debit/credit cards, preauthorized debit payments, gift cards) for BCS-eligible wireline services? If so, for each of the years 2010 to 2016 and for each alternative payment method, provide a breakdown of
    1. the annual revenues associated with each alternative payment method;
    2. the annual number of calls processed through each alternative payment method; and
    3. the annual number of customers that chose to use each of your alternative payment methods.

    Provide the information for each alternative payment option in the table below (one table per payment method):

      Revenue # of calls # of customers
    2010      
    2011      
    2012      
    2013      
    2014      
    2015      
    2016      
  3. If your company accepts any alternative payment methods for BCS-eligible wireline services, indicate whether your company imposes any limitation on the use of these alternatives (e.g. minimum number of calls to be made, or minimum amount to be spent monthly). If so, specify what these limitations are and why they are imposed.
  4. If your company does not accept any alternative payment methods for BCS-eligible wireline services, explain why not.

Questions for MTS, SaskTel, Shaw

  1. Refer to paragraph 15 of TCC’s intervention, where TCC indicates that the regulatory status of BCS must depend on the eligible service that each BCS transaction supports. If the Commission were to forbear from regulating BCS only for a subset of BCS eligible services, provide your view, with supporting rationale on:
    1. the ability of your company to distinguish BCS transactions based on the eligible service supported; and
    2. the need to request that the CISC Business Process Working Group review and amend the guidelines and processes associated with BCS to accommodate the provision of BCS depending on the service for which BCS is being provided.
  2. With respect to your retail wireline long distance services, for each of the years 2010 to 2016, provide the number of
    1. your retail wireline long distance service customers; and
    2. long distance calls originating from your retail wireline long distance service customers (i.e. excluding long distance calls made to your company’s BCS wholesale customers).

Questions for TCC

  1. Refer to paragraph 15 of TCC’s intervention where TCC indicates that the regulatory status of BCS must depend on the eligible service that each BCS transaction supports. If the Commission were to forbear from regulating BCS only for a subset of BCS-eligible services, provide your view, with supporting rationale, on the ability of your company to distinguish BCS transactions based on the eligible service supported.
  2. With respect to your retail wireline long distance services, for each of the years 2010 to 2016, provide the number of
    1. your retail wireline long distance service customers; and
    2. long distance calls originating from your retail wireline long distance service customers (i.e. excluding long distance calls made to your company’s BCS wholesale customers).
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