Telecom Commission Letter addressed to Ms. Marie-Josée Boivin (DMTS, a division of Bell Canada)

Ottawa, 11 January 2019

Our reference: 8740-D3-201808461

BY EMAIL

Ms. Marie-Josée Boivin
Senior Specialist – Regulatory Affairs
DMTS, a division of Bell Canada
87 Ontario West, Floor 3
Montreal, Quebec  H2X 1Y8
bell.regulatory@bell.ca
mjboivin@telebec.com

RE:  DMTS Tariff Notice 73 – Local competition Implementation – Related Tariffs

Dear Ms. Boivin:

On 5 October 2018, the Commission received an application by DMTS, under Tariff Notice (TN) 73, proposing changes to its General Tariff, CRTC 25370, related to the implementation of local competition.

The company filed the application in connection with an earlier Part 1 application regarding its implementation plan for facilities-based local competition.

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.

DMTS is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 18 January 2019.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector
c.c.: Danuba Musgrave, CRTC, danuba.musgrave@crtc.gc.ca

Attach. (1)

Requests for information

Question 1:

In TN 73, DMTS submitted that for the new services in sections 940, 950, 960 and 970, the proposed rates are either referenced to existing rates in the DMTS General Tariff 25370 or are based on existing rates for similar services from both NorthernTel’s General Tariff 25510 and Bell Canada’s Access Services Tariff 7516.

In Telecom Regulatory Policy 2013-160 Footnote1 , the Commission established service basket 5 for competitor services, and determined that the initial rates for these services are to be established by matching Commission-approved rates for the same service, with supporting rationale.  The rationale must address the appropriateness of the proposed small incumbent local exchange carrier (ILEC) rates in light of rates in an adjacent large ILEC territory for the same service.

Explain, with rationale, why DMTS is proposing to use the rates of NorthernTel rather than those of Bell Canada for most of the section 940 rate elements, given that NorthernTel is not an adjacent large ILEC whereas Bell Canada is an adjacent large ILEC.– In particular, provide the rationale for basing the proposed DMTS section 940.4.04 a) ‘Traffic Imbalance – Table 1’ rates on NorthernTel section N200.15.4.04 a) rates, which are higher than those of Bell Canada Item 105.4(d)(1) for the same service.

Question 2:

In section 960, DMTS is proposing a Local Service Request (LSR) Rejection Charge for each rejected LSR in excess of the following threshold percentages of the customer's total number of LSRs per month.

  1. A monthly LSR rejection rate threshold of 10.4% until 12 December 2018 and a threshold of 8% thereafter apply to each service provider that submits more than 500 LSRs in a month unless at least 75% of the LSRs it submits in that month relate to business services.
  2. A monthly LSR rejection rate threshold of 20.8% until 12 December 2018 and a threshold of 16% thereafter apply to each service provider that submits 500 or fewer LSRs in a month and to each service provider where at least 75% of the LSRs it submits in that month relate to business services.

In Telecom Regulatory Policy 2012-523 Footnote2 , the Commission determined that the lower threshold will be set at 12.8 percent on the date that the tariff is first approved by the Commission. That rate will decrease to 10.4 percent one year after the tariff is approved, and 8 percent two years after the tariff is approved. Further, the Commission determined that the higher threshold is to be set at twice the threshold for LECs that submit large volumes of LSRs. Accordingly, the higher threshold will be set at 25.6 percent on the date that the tariff is first approved by the Commission, decreasing to 20.8 percent one year after the tariff is approved and 16 percent two years after the tariff is approved.

Explain, with rationale, how DMTS has determined the dates and rejection rates in relation to its LSR rejection rate thresholds, given that the tariff has not been approved by the Commission.

Please provide an amended application revising section 960 to comply with the Commission’s requirements set out in Telecom Regulatory Policy 2012-523, based on a proposed effective date 15 calendar days after the filing of the amended application.

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