Telecom Commission Letter Addressed to Independent Telecommunications Providers Association

Ottawa, 19 November 2018

Our reference:  1011-NOC2018-0214


Mr. Jonathan Holmes
Executive Director
Independent Telecommunications Providers Association
29 Peevers Cres.
Newmarket, ON L3Y 7T5  

Re: Review of the price cap and local forbearance regimes, Telecom Notice of Consultation 2018-214 Footnote1 – Requests for information

Dear Mr. Holmes:

Pursuant to paragraph 39 of Telecom Notice of Consultation 2018-214, attached are requests for information from the Commission.

Responses to these requests for information are to be filed with the Commission by 19 December 2018. The responses must be received, not merely sent, by that date.


Original signed by

John Macri
Director,Policy Framework
Telecommunications Sector
c.c.: Christine Brock, CRTC, (873) 353-5852,

Attach (1)

Distribution list:

9315-1884 Québec inc.,
Brooke Telecom Co-operative Ltd., 
Bruce Telecom,
CityWest Telephone Corporation,   
Cochrane Telecom Services of the Town of Cochrane,
CoopTel, coop de télécommunication,
Execulink Telecom Inc., 
Gosfield North Communication Co-operative Limited,
Hay Communications Co-operative Limited,
Huron Telecommunications Co-Operative Limited, 
Lansdowne Rural Telephone Company Ltd.,
Mornington Communications Co-operative Limited,
Nexicom Inc.,
North Frontenac Telephone Corporation Ltd,
North Renfrew Telephone Company Limited Trade,  
Quadro Communications Co-operative Inc.,
Roxborough Telephone Company Limited, 
Sogetel inc.,
Tuckersmith Communications Co-operative Limited, 
Wightman Telecom Ltd., 
WTC Communications,

Requests for information addressed to Independent Telecommunications Providers Association (ITPA)

  1. Refer to paragraphs 22 to 28 of Bell Canada et al.’s Footnote2 intervention where they proposed to increase rates for regulated residential primary exchange services (PES) to the highest approved rate of $38.34. These increases would be phased in over time with annual increases limited to the lesser of i) 1/3 of the difference between the existing rate and the regulated target price or ii) $2.50 for the large incumbent local exchange carriers (ILECs) and $4.00 for the small ILECs. Bell Canada et al. also proposed that following a three-year transition period, the rate element constraint would be either i) inflation for those rates that would be at the proposed price ceiling or ii) $2.50 (large ILECs) and $4.00 (small ILECs) for the rates that would require a longer transition period, until all regulated rates are aligned at the price ceiling.

    Assume that Bell Canada et al.’s proposal above is adopted with the following changes:

    • the price ceiling is set at $35.00 rather than $38.34;
    • the maximum allowable increase per year is $1.50 for all ILECs: and
    • the rate element constraint for rates at $35.00 and over is inflation.
    1. Provide, with supporting rationale, the ITPA's views on this approach.
    2. Provide the ITPA's views on whether the price ceiling for stand-alone PES in forborne areas should be allowed to increase in the same manner to $35.00.
    3. Based on this approach, reproduce tables similar to Tables 6 and 7 of Bell Canada et al.'s intervention, with supporting calculations and assumptions.
  2. In the event that the ITPA’s Part 1 application to review and vary the determinations in Phase-out of the local service subsidy regime, Telecom Regulatory Policy CRTC 2018-213, 26 June 2018 is denied, provide evidence and explain with supporting rationale i) why the ITPA members should be compensated for the elimination of local subsidy and ii) what the ITPA considers would be appropriate compensation for the elimination of the local voice subsidy.
  3. Bell Canada et al., Footnote3 Telus Communications Inc. (TCI) Footnote4 and Saskatchewan Telecommunications (SaskTel) Footnote5 proposed that, given the extensive adoption of wireless services and since mobile wireless service is now a basic telecommunications service, the Commission should modify the local forbearance framework, specifically the residential and business competitor presence tests. They submitted that the tests should be modified to grant local forbearance if, in addition to the ILEC, there are other independent facilities-based telecommunications service providers, whether wireline or wireless service providers, offering local exchange services and capable of serving at least 75% of the number of residential local exchange service lines that the ILEC is capable of serving in a particular exchange.

    Provide the ITPA’s views as to whether the proposed competitor presence tests would be appropriate for local forbearance purposes in its members’ territories. Indicate, with supporting rationale, any modifications that would be necessary to address any special considerations in its members’ operating territories.

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