Telecom - Commission Letter addressed to Marielle Wilson (Bragg Communications Inc.)

Ottawa, 14 January 2022

Our reference: 8740-P1-202107565, 8740-A2-202107573

BY EMAIL

Marielle Wilson
Vice President, Regulatory
Bragg Communications Inc.
6080 Young Street, Suite 801
Halifax NS  B3K 5L2
regulatory.matters@corp.eastlink.ca

Subject: People’s Tel Limited Partnership Tariff Notice No. 93 and Amtelecom Limited Partnership Tariff Notice No. 84 - Introduction of Next Generation 9-1-1 (NG9-1-1) Service

Dear Marielle Wilson,

By way of Telecom Decision 2021-199^Footnote1, the Commission directed all NG9-1-1 network providers to file proposed Wholesale and Retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, or functionalities.

People’s Tel Limited Partnership (Tariff Notice No. 93) and Amtelecom Limited Partnership (Tariff Notice No. 84), carrying on business as Eastlink (Eastlink), submitted that, due to the uncertainty of the role that small incumbent local exchange carriers (SILECs) will play in the delivery of NG9-1-1 calls to end-users emphasized by the Independent Telecommunications Providers Association’s ongoing Part 1 application, the companies propose to use their currently approved 9-1-1 rate of $0.24 in the respective current General Tariffs of People’s Tel Limited Partnership and Amtelecom Limited Partnership for their NG9-1-1 service.

Eastlink stated that, given the unknowns associated with the service, coupled with it not having the resources nor the expertise to complete a Phase II cost study, the company intends to reference the wholesale and retail NG9-1-1 rates that will be in the approved final tariff of its NG9-1-1 network provider. Eastlink further submitted that the Commission confirmed this approach as an acceptable practice in Telecom Decision CRTC 2001-756^Footnote2 – Regulatory framework for the small incumbent telephone companies, where, in cases such as 9-1-1, the SILEC does not provide the service themselves.

Eastlink is reminded that the Commission’s direction provided in Telecom Decision 2021-199, paragraph 29 (c) was for “all NG9-1-1 network providers to file proposed NG9-1-1 wholesale

and retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, or functionalities.” (emphasis added).

Commission staff therefore invites Eastlink to revise the submission of its SILECs to include cost studies in support of the proposed tariffs filed, including detailed information containing a breakdown of how costs causal to the service and causal to demand are derived, including the economic parameters and assumptions made. Commission staff requests that Eastlink respond to this letter no later than 31 January 2022. Where a document is to be filed or served by a specific date, the submission must actually be received, not merely sent, by that date.

If Eastlink chooses not to revise its submissions to include cost studies in support of the proposed tariffs filed, Commission staff request that Eastlink confirm such, along with a detailed explanation as to why a proposed proxy rate constitutes a valid proposal for the NG9-1-1 service for People’s Tel Limited Partnership and Amtelecom Limited Partnership.

The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Broadcasting and Telecom Cover page” or the “Broadcasting Cover Page” located on the Commission’s website. There, you will also find information on the submission of applications to the Commission “Filing Broadcasting and Canadian Program Certification documents with the CRTC: Privacy and Security.”

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

As set out in section 39 of the Telecommunications Act^Footnote3 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961^Footnote4, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.:  Stais Armstrong, CRTC, 819-997-9253, stacey.armstrong@crtc.gc.ca;
Daniel Cardozo, CRTC, 819-962-5720, daniel.cardozo@crtc.gc.ca

Date modified:

2022-01-14