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ARCHIVED - Telecom Commission Letter Addressed to Counsel to Public Interest Advocacy Centre (PIAC)

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Ottawa, 19 November 2018

Our reference:  1011-NOC2018-0214

BY EMAIL

Mr. John Lawford
Counsel to Public Interest Advocacy Centre
Public Interest Advocacy Centre
1 Nicholas Street, suite 1204
Ottawa, ON K1N 7B7
piac@piac.ca

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

Dear Mr. Lawford:

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.

Sincerely,

Original signed by

John Macri
Director, Policy Framework
Telecommunications Sector

c.c.: Christine Brock, CRTC, (873) 353-5852, christine.brock@crtc.gc.ca

Attach (1)

Requests for information addressed to Public Interest Advocacy Centre (PIAC)

  1. At paragraph 22 of its intervention, PIAC stated that the stand-alone home phone service is $44.44 per month with Bell Canada in Ontario, without any of the features consumers consider standard.
    1. Specify which service, referred to above, is being offered by Bell Canada in its Ontario serving territory at $44.44 per month.
    2. Provide a detailed description of this service and what the rate includes (e.g. 911 or municipal fees).
  2. At paragraph 23 of Bell Canada et al.’s) Footnote2 intervention and paragraph 39 of Telus Communications Inc.’s (TCI’s), the companies requested flexibility to increase rates for residential primary exchange service in regulated high cost serving areas to the highest approved rate of $38.34. If the Commission were to set the price ceiling at a lower level, such as $35, with the flexibility to gradually increase it over the years, provide PIAC’s views on what would be the impact on the customers. What conditions should the Commission impose to attain such a revised price ceiling?
  3. Bell Canada et al.,) Footnote3 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 incumbent local exchange carrier (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.

    4. Comment, with supporting rationale, on whether PIAC considers that the competitor presence tests as proposed by the companies would be sufficient to protect the interests of users.

  4. TCI)Footnote6 and Bell Canada et al.) Footnote7 proposed that the Commission eliminate the obligation for ILECs to provide stand-alone local residential primary exchange service in forborne exchanges, considering the relatively few numbers of stand-alone subscribers and the presence of sufficient competition in those exchanges.

    5. Provide PIAC’s views as to whether this proposal would be sufficient to protect the interests of users.

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