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

Ottawa, 13 July 2017

Our reference:  1011-NOC2017-0092

BY EMAIL

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

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

Dear Mr. Schmidt:

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)


ATTACHMENT

Requests for information addressed to TELUS Communications Company (TCC)

  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, SaskTel submitted that it is able to identify those customers without access to reliable Internet and that it, or any other incumbent local exchange carrier (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., Saskatchewan Telecommunications and TCC 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.Footnote2
    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.

  9. In response to the Commission’s requests for information dated 13 April 2017, Bell Canada et al. provided information, including maps or postal codes, identifying exchanges that potentially could qualify for forbearance from the regulation of local exchange service. The company has been identified as a competitive independent facilities-based telecommunications service provider in one or more of these exchanges. Refer to responses to requests for information Bell ILECs(CRTC)13Apr17-1 TNC2017-92, Attachment 1, Bell ILECs(CRTC)13Apr17-1 TNC2017-92, Attachment 2, Bell SILECs(CRTC)13Apr17-1 TNC2017-92 Attachment, and Bell SILECs(CRTC)13Apr17-2 TNC 2017-92, Attachment.

    Confirm whether the company is a competitive independent facilities-based telecommunications service provider offering local exchange services in each exchange identified that potentially qualify for forbearance.

    For each of these exchanges:

    1. If the company is a fixed-line service provider:
      1. Provide the total network access services (NAS) that the company is capable of serving using its own wireline facilities to provide local exchange services. If this information is not available, provide the total number of households capable of being served with local exchange services, based on the six-character postal code information or maps provided by the ILEC; and
      2. Indicate whether the company is capable of covering at least 75% of the exchange with local exchange service or provide an estimate of the percentage of the exchange that it is capable of serving.
    2. If the company is a wireless service provider, indicate whether the company’s wireless service is capable of covering at least 75% of the exchange or provide an estimate of the percentage of the exchange that it is capable of serving.
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