Telecom Commission Letter Addressed to Independent Telecommunications Providers Association
Ottawa, 19 November 2018
Our reference: 1011-NOC2018-0214
Mr. Jonathan Holmes
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
c.c.: Christine Brock, CRTC, (873) 353-5852, firstname.lastname@example.org
9315-1884 Québec inc., email@example.com
Brooke Telecom Co-operative Ltd., firstname.lastname@example.org
Bruce Telecom, email@example.com
CityWest Telephone Corporation, firstname.lastname@example.org
Cochrane Telecom Services of the Town of Cochrane, email@example.com
CoopTel, coop de télécommunication, firstname.lastname@example.org
Execulink Telecom Inc., email@example.com
Gosfield North Communication Co-operative Limited, firstname.lastname@example.org
Hay Communications Co-operative Limited, email@example.com
Huron Telecommunications Co-Operative Limited, firstname.lastname@example.org
Lansdowne Rural Telephone Company Ltd., email@example.com
Mornington Communications Co-operative Limited, firstname.lastname@example.org
Nexicom Inc., email@example.com
North Frontenac Telephone Corporation Ltd, firstname.lastname@example.org
North Renfrew Telephone Company Limited Trade, email@example.com
Quadro Communications Co-operative Inc., firstname.lastname@example.org
Roxborough Telephone Company Limited, email@example.com
Sogetel inc., firstname.lastname@example.org
Tuckersmith Communications Co-operative Limited, email@example.com
Wightman Telecom Ltd., firstname.lastname@example.org
WTC Communications, email@example.com
Requests for information addressed to Independent Telecommunications Providers Association (ITPA)
- Refer to paragraphs 22 to 28 of Bell Canada et al.’s
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.
- Provide, with supporting rationale, the ITPA's views on this approach.
- 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.
- Based on this approach, reproduce tables similar to Tables 6 and 7 of Bell Canada et al.'s intervention, with supporting calculations and assumptions.
- 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.
- Bell Canada et al.,
Telus Communications Inc. (TCI)
and Saskatchewan Telecommunications (SaskTel)
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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