Telecom Commission Letter addressed to Philippe Gauvin (Bell Canada) and Howard Slawner (Rogers Communications Canada Inc.)

Ottawa, 24 September 2019

Our reference: 8650-S191-201904483

BY EMAIL

Mr. Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19
160 Elgin St.
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Mr. Howard Slawner
Vice President - Regulatory Telecom
Rogers Communications Canada Inc.
350 Bloor Street East
Toronto Ontario M4W 0A1
rwi_gr@rci.rogers.com

Re:    SDI Telecom – Part 1 Application to allow competitive payphone service providers to use business lines from any competitive local exchange carrier, and to receive reports and compensation for toll-free calls

Dear Sirs,

On 5 June 2019, SDI Telecom (SDI) filed with the Commission the above referenced Part 1 Application, raising issues related to compensation for toll-free calling.

To assist staff in its analysis of the application, Bell Canada and Rogers Communications Canada Inc. (RCCI) are to provide responses to the attached requests for information (RFIs) by 4 October 2019.

Interested parties may file comments in response to the RFIs by 9 October 2019. Bell Canada and RCCI may file reply comments by 11 October 2019.

Sincerely,

Original signed by

Philippe Kent
Director, Policy
Telecommunications Sector

c.c.:  Curtis Eagan, CRTC, 819-953-4947, curtis.eagan@crtc.gc.ca
Allstream Inc., iworkstation@mtsallstream.com
Primus Telecommunications Canada Inc., regulatory@primustel.ca
CGI Inc., b.dube@cgi.com

Attach (1)

Requests for Information

Questions for Bell Canada

Question 1

In Telecom Decision 2013-299, the Commission set a default compensation rate for toll-free calls of $0.80 per call and that the rate would “be payable to the competitive payphone service providers by the long distance carriers and will apply in cases where the parties involved have not agreed on the charging of another rate.”

Based on the record of this application, SDI did not agree to the charging of another rate for toll-free calls made from its pay phones using Bell Canada’s regular business line service, and Bell Canada is refusing to compensate SDI the above-mentioned $0.80 rate for toll-free calls.

Explain why the Commission’s determinations in Telecom Decision 2013-299 should not apply to Bell Canada in SDI’s case.

Question 2

In Order 2000-538, the Commission directed all interexchange carriers (IXCs) to compensate competitive pay telephone service providers who provide access to the IXC's toll-free services and to provide sufficient billing information to a payphone service provider so that it can bill the IXCs.

If the Commission were to determine that SDI should be compensated for providing access to an IXC’s toll-free services using regular business lines, will Bell Canada produce a toll-free report with sufficient billing information to SDI so that it can bill the IXCs, as per Order 2000-538? If not, explain why not.

Question for RCCI

In Telecom Decision 97-8, the Commission considered that Competitive Local Exchange Carriers (CLECs) are not simply customers of Incumbent Local Exchange Carriers (ILECs) but are carriers equal in stature to the ILECs in the local exchange market.

In Order 2000-538, the Commission directed all IXCs, including ILECs and CLECs, to compensate competitive pay telephone service providers who provide access to the IXC's toll-free services and to provide sufficient billing information to a payphone service provider so that it can bill the IXCs.

Explain why RCCI believes it should not have to produce a toll-free report with sufficient billing information to SDI so that it can bill IXCs, as per Order 2000-538.

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