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ARCHIVED - Telecom Commission Letter Addressed to Mr. Dallas Yeulett (Northwestel)

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Ottawa, 25 July 2018

Our reference: 8661-N1-201800863

ABRIDGED

BY EMAIL

Mr. Dallas Yeulett
Senior Manager, Regulatory Compliance
Northwestel
P.O. Box 2727
Whitehorse, Yukon Y1A 4Y4
regulatoryaffairs@nwtel.ca

Re:  Part 1 application requesting ratification of Special Services Tariff (SST) rates

Dear Sir:

On 11 May 2018, 6 June 2018 and 25 June 2018, the Commission received responses to Requests for Information (RFI) from Northwestel pertaining to the Part 1 application noted above.

Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Northwestel is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 1 August 2018.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c.: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca

Attach. (1)

Requests for information

Pursuant to subsection 25(4) of the Telecommunications Act (the Act), the Commission may ratify the charging of a rate by a Canadian carrier otherwise than in accordance with a tariff approved by the Commission if it is satisfied that the rate was charged because of an error or other circumstance that warrants the ratification.

  1. In its Part 1 application, for SST 753 the company identified amounts for the ratification request totaling $14,887,400.71 for the period May 2013 through February 2017. In the company’s 25 June 2018 RFI response, it revised the rate ratification amount to #_____#Footnote1 for SST 753.

    2. In the company’s 11 May 2018 RFI response, Northwestel indicated in Attachment 2 that the monthly rate charged for billing months May 2013 to June 2014 was $317,683.34. Commission staff notes that this monthly rate was approved under TN 895, effective 9 May 2013 in Telecom Order 2013-236.

    1. As the monthly rate of $317,683.34 was an approved rate, explain why Northwestel appears to have included the May 2013 to June 2014 amounts charged in the company’s ratification request.
    2. If the monthly rate of $317,683.34 for the period May 2013 to June 2014 was incorrectly included in the rate ratification request for SST 753, please provide the correct amount that is being requested for SST 753 rate ratification.
  2. In its Part 1 application, for SST 756 the company identified that for the period 4 October 2016 to 8 February 2017, the customer was billed $141,955 per month prior to that rate being approved. In the company’s 11 May 2018 RFI response, the company indicated in Attachment 5 that the monthly rate from October 2016 to February 2017 for ratification purposes was $13,896.33 and that therefore, the amount of the rate ratification request was $156,565.36. In the company’s 25 June 2018 RFI response, it included a ratification amount of #_____#Footnote2 .
    1. As Northwestel is requesting rate ratification for the period 4 October 2016 to 8 February 2017, explain why Northwestel has included the monthly rate of $13,896.33 for SST 756 instead of the monthly rate of $141,955.00 that was charged otherwise than in accordance with the approved tariff.
    2. If the monthly rate of $13,896.33 for the period 4 October 2016 to 8 February 2017 was incorrectly included in the rate ratification request for SST 756, please provide the correct amount that is being requested for SST 756 rate ratification.
  3. In its 11 May 2018 RFI response, section C 2), Northwestel stated that the underlying services for four of the SSTs in question were sold through the company’s affiliate, ARDICOM, and that this complicated the exercise of ensuring that correct processes were followed. Northwestel further noted that in certain cases, the affiliate made incorrect interpretations of the tariffed SST, resulting in inadvertent inconsistencies between what was provided and what was tariffed in the case of SSTs 748 and 776. In addition, the company stated that SSTs 752 and 753 were also impacted by the affiliate relationship, as certain service requests were not always handled through standard processes, contributing to the errors.

    4. Northwestel indicated that the company is working with ARDICOM to ensure that, between the two companies, there are appropriate checkpoints and steps to ensure that changes made on a going forward basis are only done consistent with an approved tariff, and that all requests for changes must flow through Northwestel’s updated standard processes and procedures, which requires regulatory approval.

    1. Confirm whether all of the process improvements set out in Section B of the 25 June 2018 RFI response now apply to ARDICOM.
    2. If there are any differences in the process improvements that apply to ARDICOM, please describe them and their anticipated impact on ARDICOM’s compliance with all of its regulatory obligations.
  4. Northwestel filed its 25 June 2018 RFI response in confidence with the Commission, but did not file an abridged version for the public record.  The company is requested to file an abridged version of its 25 June 2018 RFI response.
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