Telecom Procedural Letter Addressed to the Distribution List

Ottawa, 13 July 2017

Our reference:  1011-NOC2017-0092

BY EMAIL

Distribution

Re:  Phase-out of the local service subsidy regime, Telecom Notice of Consultation 2017‑92Footnote1 – Requests for information

Dear Madam, Sir:

Pursuant to paragraph 31 of Telecom Notice of Consultation 2017-92, attached are requests for information from the Commission.

Responses to these requests for information are to be filed with the Commission by 10 August 2017. The responses must be received, not merely sent, by that date.

Sincerely,

Original signed by

John Macri
Director,Policy Framework
Telecommunications Sector

c.c.:  Christine Brock, CRTC, (819) 997-4557, christine.brock@crtc.gc.ca
attach (1)

Distribution List

9315-1884 Québec, richard.biron@sogetel.com
Brooke Telecom Co-operative Ltd., geoff@brooketel.ca 
Bruce Telecom, bart.cameron@brucetelecom.com
CityWest Telephone Corporation, Donovan.Dias@cwct.ca 
Cochrane Telecom Services of the Town of Cochrane, smitch@cochranetel.ca
CoopTel, coop de télécommunication, mrocheleau@cooptel.coop
Execulink Telecom Inc., ian.stevens@execulink.com 
Gosfield North Communication Co-operative Limited, rob.petruk@gosfieldtel.ca
Groupe Maskatel LP, jgrenier@maskatel.qc.ca
Hay Communications Co-operative Limited, a.lawrence@hay.net
Huron Telecommunications Co-Operative Limited, grubb@hurontel.on.ca 
Independent Telephone Providers Association, jonathan.holmes@itpa.ca
Lansdowne Rural Telephone Company Ltd., wagrier@1000island.net
Mornington Communications Co-operative Limited, knaylor@mornington.ca
Nexicom Telecommunications, a Division of Nexicom Inc., pdowns@nexicomgroup.net
Nexicom Telephones, a Division of Nexicom Inc., pdowns@nexicomgroup.net
North Frontenac Telephone Corporation Ltd, davesmith@frontenac.net,
North Renfrew Telephone Company Limited Trade, moverton@nrtco.net
O.N.Tel Inc., tracy.cant@ontera.ca
Quadro Communications Co-operative Inc., john.deheer@quadro.net
Roxborough Telephone Company Limited, roxboro@ontarioeast.net 
Sogetel inc., richard.biron@sogetel.com
Tuckersmith Communications Co-operative Limited, rob@tccmail.ca 
Wightman Telecom Ltd., rfigliuzzi@wightman.ca 
WTC Communications, steve@wtccommunications.ca


ATTACHMENT

Requests for information addressed to each small incumbent local exchange carrier (ILEC)

  1. For each of the years 2014 to 2016, provide the company’s average monthly revenues, per high cost serving area (HCSA) band and sub-band, associated with the provision of broadband Internet access services at a minimum download speed of 1.5 megabits per second (Mbps). Explain the methodology used and show all calculations. Where the broadband Internet service is provided as part of a bundle, impute the unbundled revenue for the broadband service component.
  2. For each of the years 2014 to 2016, provide the company’s average monthly revenues, per HCSA band and sub-band, associated with the provision of broadband Internet access services at a minimum download speed of 5 Mbps. Explain the methodology used and show all calculations. Where the broadband Internet service is provided as part of a bundle, impute the unbundled revenue for the broadband service component.
  3. As of December 31, 2016, provide, per band and sub-band, the number of subsidized network access services (NAS) for which the customer subscribes only to standalone primary exchange service (PES) (i.e. the customer subscribes only to PES and no other telecommunications service).
  4. In its intervention, Saskatchewan Telecommunications (SaskTel) submitted that it is able to identify those customers without access to reliable Internet and that it, or any other ILEC, can demonstrate to the Commission that certain subscribers do not have this access.
    1. Provide the company's views on how (e.g. methodology, frequency of reports) the Commission should, for the purpose of removing subsidy, collect information on the subsidized NAS do not have access to  "reliable broadband Internet service" based on the Commission's preliminary view set out in Telecom Notice of Consultation 2017-92 (NOC 2017-92 preliminary view).
    2. Provide the company’s views on how the Commission should collect information on the subsidized NAS do not have access to “reliable broadband Internet service” if the NOC preliminary view was modified to include fixed wireless technology.
  5. Some parties (e.g. Union des consommateurs, First Mile Connectivity Consortium) suggested that the Commission could require telecommunications companies to demonstrate that they are capable of meeting the 50 Mbps download and 10 Mbps upload level of service before proceeding with the removal of the local voice subsidy.

    Indicate in which subsidized exchanges the company offers broadband Internet access service at speeds of 50 Mbps download and 10 Mbps upload. For each of these exchanges, provide the number of NAS that have access to broadband Internet access service at those speeds.

  6. Parties such as Bell Canada et al.Footnote2 , SaskTel and TELUS Communications Company have suggested that, if the local service subsidy is removed, they should have the flexibility to raise residential rates in HCSAs in order to cover costs for continuing the obligation to serve.
    1. Alternatively, if subsidy is removed and ILECs are not granted pricing flexibility, then should there be specific compensation for the obligation to serve? Explain with supporting rationale.
    2. If yes, how would this compensation be calculated? Would the compensation be for having the obligation in and of itself, or for actual situations requiring the obligation to be met? Explain with supporting rationale.
  7. Provide your views on each of the following separate scenarios for implementation and include a proposed timeline, noting important milestones and key considerations.
    1. Allow the local service subsidy to be phased out “organically” as customers move to other services, and technology and coverage improve.Footnote3
    2. Phase out of the local service subsidy over the first five years of contributions to the broadband funding mechanism.
    3. For NAS still receiving subsidy:
      1. Eliminate subsidy immediately where broadband Internet access service at speeds of at least 50 Mbps download and 10 Mbps upload is currently available;
      2. Establish a phase out plan and cut-off date for the removal of subsidy where it is determined that there is reliable broadband Internet access service; and
      3. Establish a phase out plan and cut-off date for the removal of subsidy where it is determined that broadband Internet access service is either unreliable or non-existent.
  8. In its intervention, Shaw Cablesystems G.P. (Shaw) stated that “situations have arisen where [incentives for ILECs to apply for local forbearance] are absent.” In their interventions, both Shaw and Rogers Communications Canada Inc. proposed different approaches that the Commission could use to examine, on an ongoing basis, key information on the HCSA exchanges that remain subsidy-eligible to determine which of these exchanges may qualify for forbearance.

    Should the Commission implement a process to collect information and assess whether an exchange qualifies for forbearance? If so, explain how the process or mechanism would be implemented.

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