Telecom Commisssion Letter addressed to Richard Biron (Sogetel inc.)

Ottawa, 30 April 2019

Our reference: 8663-L2-201811224

BY EMAIL

Mr. Richard Biron
Vice-President, Business Development
Sogetel inc.
111 12-Novembre St.
Nicolet, QC J3T 1S3
Richard.biron@sogetel.com

RE:  Implementation plan for local competition for the Courcelles and Lambton exchanges filed by 9315-1884 Québec inc.

Dear Mr. Biron:

The Commission received an application from 9315-1884 Québec inc. dated December 21, 2018, in which the company requested approval of its implementation plan for local competition, including local number portability, within the Courcelles and Lambton exchanges in Quebec (implementation plan). The company filed the application under Telecom Decision 2006-14Footnote1  and in response to a signed official expression of interest from Telus Communications inc. (Telus), indicating that the latter wanted to provide local services as a competitive local exchange carrier (CLEC) in those exchanges.

In order to complete Commission staff’s analysis of the application, 9315-1884 Québec inc. is requested to provide answers to the following questions by May 7, 2019.

Interested parties have until May 14, 2019 to file interventions regarding the response from 9315-1884 Québec inc. to the Commission, by sending copies to 9315-1884 Québec inc.

9315-1884 will have until May 22, 2019 to file with the Commission its reply to any intervention, by sending copies to the intervenors to which 9315-1884 Québec Inc. replies.

Questions

In the implementation plan filed by 9315-1884 Québec inc., the company proposed, among other things, to use the existing local switching and interconnection facilities in Lac-Etchemin belonging to Sogetel inc. (Sogetel) for serving the Courcelles and Lambton exchanges as well as the terms and conditions and systems/resources in place at Sogetel previously approved by the Commission.Footnote2 The Commission did not receive any intervention from Sogetel, and the latter was not copied in the application from 9315-1884 Québec inc.

  1. According to the application filed by 9315-1884 Québec inc., the latter is the incumbent local exchange carrier (ILEC) serving the Courcelles and Lambton exchanges.  According to information from Commission staff, the exchanges in question were previously served by La Compagnie de Téléphone de Courcelles inc. and La Compagnie de Téléphone de Lambton inc., which were apparently purchased by Sogetel. In light of the above,
    1. Confirm whether Sogetel purchased La Compagnie de Téléphone de Courcelles and La Compagnie de Téléphone de Lambton, previously serving the Courcelles and Lambton exchanges, and, if so, on what date;
    2. Confirm how 9315-1884 Québec inc. became the ILEC in the Courcelles and Lambton exchanges;
    3. Indicate whether 9315-1884 Québec inc. is a division of Sogetel or a separate legal entity;
    4. Explain the organizational structure of 9315-1884 Québec inc. and its relationship with Sogetel for the provision of telecommunication facilities and services in the Courcelles and Lambton exchanges; 
    5. Indicate what company name 9315-1884 Québec inc. presents to customers for providing telecommunication services in the Courcelles and Lambton exchanges. Specify (i) the name of the company’s website and provide the link to it; (ii) the name that the company uses for billing its subscribers and for communications intended for them via mail or email; and (iii) the company’s name shown in email addresses.
  2. If applicable, submit copies of agreements between 9315-1884 Québec inc. and Sogetel regarding the local competition implementation plan for the Courcelles and Lambton exchanges further to Telus’ expression of interest, including local number portability and the associated costs.
  3. In its reply letter to Telus, dated February 19, 2019, 9315-1884 Québec inc. confirmed that [translation] “the costs of Sogetel inc.’s services will not be charged to TELUS as part of using the Lac-Etchemin interconnection”.
    In Telecom Regulatory Policy 2011-291,Footnote3 the Commission indicated that, among other things, small ILECs serving 3,000 or fewer network access services (NAS) will have their local competition implementation costs reimbursed, over a period of three years, by the new entrants. Explain, with justification,
    1. why 9315-1884 Québec inc. believes that Telus would not be required to reimburse the implementation costs in question and,
    2. whether you believe that the implementation cost recovery mechanism proposed by 9315-1884 Québec inc. is consistent with the above decision and, if so, why and how.
  4. At paragraphs 18 to 20 of its application, 9315-1884 Québec inc. suggested that the Commission use the same approach as the one it used in Telecom Decision 2018-250Footnote4 regarding Sogetel’s implementation of local competition for Iristel, for calculating the amount of the local service subsidy by including recovery of 9315-1884 Québec inc.’s ongoing costs based on the phase-out, as detailed in Telecom Regulatory Policy (TRP) 2018-213.Footnote5
    In TRP 2018-213, the Commission determined that as of June 26, 2018, it would no longer accept new applications for lost NAS subsidy or new applications for the recovery of ongoing costs from the local service subsidy regime associated with local competition or WNP.
    Explain, with justification, whether you believe that the ongoing cost recovery mechanism proposed by 9315-1884 Québec inc. is consistent with this decision and, if so, why and how.

Sincerely,

Original signed by

Philippe Kent
Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c. Stephen Schmidt, Telus, regulatory.affairs@telus.com
John Mackenzie, Telus, john.mackenzie@telus.com
Danny Moreau, CRTC, danny.moreau@crtc.gc.ca
Sylvie Beaudoin, CRTC, Sylvie.beaudoin@crtc.gc.ca

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