ARCHIVED - Telecom Commission Letter Addressed to Mr. W.N. (Bill) Beckman (Saskatchewan Telecommunications)

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Ottawa, 27 October 2017

Our reference: 1011-NOC2017-0092, 1011-NOC2017-0112


Mr. W.N. (Bill) Beckman
Senior Director, Regulatory Affairs
Saskatchewan Telecommunications
2121 Saskatchewan Drive
Regina, Saskatchewan  S4P 3Y2

Re: Saskatchewan Telecommunications’ procedural request to merge three proceedings and to conduct an oral public hearing

Dear Mr. Beckman:

This letter is in response to a procedural request from Saskatchewan Telecommunications (SaskTel), dated June 26, 2017, to combine the following three proceedings and to hold an oral public hearing in Saskatchewan, on the combined proceeding:

  1. Phase-out of the local service subsidy regime;Footnote1
  2. Development of the Commission’s broadband funding regime;Footnote2 and
  3. A future proceeding to review the price cap and local forbearance regimes.

SaskTel argues that the matters, which are the subject of these three proceedings, should be considered at the same time because they address related policies. SaskTel also explains that holding a public hearing in Saskatchewan would allow Canadians most likely to be impacted by the results of the phase-out proceeding to be heard.

More specifically, SaskTel argues that combining the price cap/forbearance review and the local subsidy phase-out proceeding would allow discussion of the local service rates to take place in conjunction with discussion of the phase-out. SaskTel maintains that retail rates in high-cost serving areas (HCSAs) would need to increase significantly to cover their costs should local voice subsidy be removed; therefore, combining the proceedings would allow for the rates to be set at the same time as the subsidy is phased out.

Thirteen parties responded to SaskTel’s procedural request. All parties, except for the Independent Telecommunications Providers Association (ITPA) and TELUS Communications Company (TCC), oppose SaskTel's request for a number of reasons. Parties such as Bell Canada, OpenMedia and Rogers Communications Canada Inc. expressed concern that approving the request would add procedural complexity and expense, cause unnecessary delays in implementing the new policies, and would risk conflating or overlooking issues. These parties further noted that the current process provides opportunity for comment, and nothing precludes parties from commenting on cross impacts in their submissions.

By contrast, the ITPA and TCC argue that the issues are interrelated, and as such, this would ensure a more cohesive decision and reduce risks of implementing regulatory policies that are contradictory. Only TCC supports the proposal for an oral public hearing, adding that hearings should take place in Alberta and British Columbia, in addition to Saskatchewan.

In its reply, SaskTel revised its original request, and proposes to combine:

Commission’s analysis and determinations

First, there are no overlapping issues that exist regarding the local service subsidy and broadband fund proceedings. While the monies to support the two funds are from the same source, the National Contribution Fund (NCF), these are two separate funding regimes with different policy objectives. The Commission already allocates the NCF to separate pools, local service subsidy and video relay service, and will do so in the future for the broadband fund.

Second, while there may be overlaps between the local service subsidy and price cap/forbearance proceedings, combining the two would make for a cumbersome and unmanageable process. Many issues to be examined in the price cap/forbearance proceeding would not be relevant to the phasing-out of local service subsidy and the review of rates in HCSAs (e.g., pricing constraints for business and competitor services in the price cap regime, or the competitor presence test in the forbearance regime). A combined proceeding would therefore be inefficient given the scale and scope of the discussion and the multitude of issues to be examined.

Lastly, the Commission often conducts separate proceedings to review distinct regulatory regimes, while still considering cross impacts as a matter of course. The current proceeding on the phase-out of the local service subsidy provided sufficient opportunity for parties to comment on any possible cross impacts and on the timing of implementation in relation to the price cap/forbearance review. Many parties, including residents from Saskatchewan, provided their views to the Commission on such issues. The Commission will consider these concerns in its determinations on the local subsidy phase-out proceeding.

In light of the above, the Commission denies SaskTel’s procedural request to merge the aforementioned proceedings and to conduct an oral public hearing in Saskatchewan.


Original signed by

Scott Hutton,
Acting Secretary General

c.c.: Julie Cook,

attach:  Distribution List

Distribution List

9315-1884 Québec,
3C Information Solutions Incorporated,
Alberta Association of Municipal Districts and Counties,
Alberta SouthWest Regional Alliance,
All Nations Trust Company,
Amtelecom Telco GP Inc.,
Association of Manitoba Municipalities (AMM),
BC Broadband Association,
BC Libraries Cooperative,
Bell Canada,
Blue Sky Economic Growth Corp (Blue Sky Net),
Bragg Communications Inc. (Eastlink),
British Columbia Broadband Association (BCBA),
Brooke Telecom Co-operative Ltd.,
Bruce Telecom,
Canadian Cable Systems Alliance Inc. (CCSA),
Canadian Network Operators Consortium Inc.,
Canadian Telecommunications Contribution Consortium Inc.,
CityWest Telephone Corporation,
Cochrane Telecom Services of the Town of Cochrane,
Cogeco Communications Inc.,
Columbia Basin Broadband Corporation (CBBC),
CoopTel, coop de telecommunication,
Corridor Communications Inc. (CCI),
County of Warner (AB),
Cree Nation Government and Eeyou Communications Network,
Déry Télécom inc.,
Government of Nunavut,,
Government of the Northwest Territories,
Eeyou Communications Network,
English-Language Arts Network (ELAN),
Execulink Telecom Inc.,
Fédération des chambres de commerce du Québec (FCCQ),
Federation of Canadian Municipalities (FCM),
Fédération québécoise des municipalités,
First Mile Connectivity Consortium,
Galaxy Broadband Communications Inc.     EORN/EOWC,
Gosfield North Communication Co-operative Limited,
Government of Manitoba,
Government of Newfoundland and Labrador,
Government of Yukon,
Groupe Maskatel LP,
Hay Communications Co-operative Limited,
Huron Telecommunications Co-Operative Limited,
Independent Telephone Providers Association,
Inuvialuit Regional Corporation,
Kativik Regional Government (KRG),
Lansdowne Rural Telephone Company Ltd.,
Lemalu Holdings Ltd. O/A MCSNet,
Manitoba Telecom (MTS Inc.),
Ministère de l'Économie de la Science et de l'Innovation/ Ministère de la Culture et des Communications
Ministry of Technology, Innovation and Citizens of Province of British Columbia
Mornington Communications Co-operative Limited,
MRC de Mékinac,
MRC de Témiscouata,
National Campus and Community Radio Association (NCRA-ANREC),
National Pensioners Federation & Public Interest Advocacy Centre (NPF-PIAC),
Nexicom Telecommunications, a Division of Nexicom Inc.,
Nexicom Telephones, a Division of Nexicom Inc.,
North Frontenac Telephone Corporation Ltd.,
North Renfrew Telephone Company Limited Trade,
NorthernTel Limited Partnership,
Northwestel Inc.,
Nunavut Economic Forum Coalition,
Nunavut Library Association,
NWT Association of Communities,
One Nation Networks, a Division of WiBand Communications Corp.,
Ontario Ministry of Infrastructure on behalf of various parties,
O.N.Tel Inc.,
People's Tel Limited Partnership,
Powell River Regional District,
Prince Township (ON),
Province of Nova Scotia, Department of Business,
Quadro Communications Co-operative Inc.,
Québecor Média,
Rogers Communications Canada Inc.,
Roxborough Telephone Company Limited,
Saskatchewan Association of Rural Municipalities (SARM),
Saskatchewan Telecommunications (SaskTel),
School of Library and Information Studies, University of Alberta,
Service Alberta,
Shaw Communications Inc.,
Sogetel inc.,
Southwestern Integrated Fibre Technology Inc. (SWIFT),
SSi Micro Ltd.,
Strathcona County (AB)
TCPub Media Inc.,
TekSavvy Solutions Inc.,
Télébec, société en commandite,
Telesat Canada,
TELUS Communications Company,
Tuckersmith Communications Co-operative Limited,
Union des consommateurs,
Ville de Rimouski (district Sainte-Blandine/Mont-Lebel),
West Parry Sound SMART Community Inc.,
Wightman Telecom Ltd.,
WTC Communications,
Xplornet Communications Inc.,

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