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Telecom - Staff Letter addressed to Stephen Schmidt (TELUS Communications Inc.)

Ottawa, 15 February 2024

Our reference: 8000-C12-202400282

By EMAIL

Stephen Schmidt
Vice-President – Telecom Policy and Chief Regulatory Legal Counsel
Telecom Policy and Regulatory Affairs
TELUS Communications Inc.
Floor 5 – 215 Slater Street
Ottawa, ON K1P 0A6
regulatory.affairs@telus.com

Subject: Proposed disconnection of home telephone service in the Kamloops, BC area

Dear Stephen Schmidt,

Commission staff continues to be concerned about TELUS Communications Inc.’s (TELUS) plan to disconnect home telephone service in three communities in British Columbia, as of 8 March 2024. Disconnecting service in these communities would make it much more difficult for residents to access public safety services, find employment, keep in touch with family and friends, and access health care and schooling.

Like all incumbent local exchange carriers (ILECs), TELUS has an obligation to serve customers in its operating territory. Based on the information provided by TELUS to date, Commission staff is concerned that TELUS may not be in compliance with Commission policies and regulations governing the disconnection of local exchange service. TELUS cannot unilaterally exempt itself from its obligation to serve. TELUS must notify the Commission of its intention to disconnect a community. Moreover, should TELUS wish to be relieved of its obligation to serve a community, it must seek Commission approval.

Accordingly, TELUS should make the necessary arrangements to ensure it can continue providing service in these communities beyond 8 March 2024. TELUS must file a detailed confirmation to this effect with the Commission by 23 February 2024.

Additionally, to help Commission staff continue to assess the situation, TELUS is requested to provide by 23 February 2024, comprehensive answers, including rationale and any supporting information, to the following questions related to the company’s 2 February 2024 responses:

  1. TELUS indicated that the SR 500 microwave transport and local switching equipment it uses to provision service in the affected areas has been discontinued since 2009. Consequently, TELUS would not be in a position to acquire or maintain the equipment necessary to provide service, for example in the event of an equipment failure, because there are limited to no replacement parts. Knowing this since that time, has TELUS made any efforts to find alternate equipment to ensure continuity of service? If so, provide details. If not, why not?
  2. TELUS has known since at least 2019 that the 3500 MHz spectrum that it relies on to provide service in the affected areas would be repurposed for use in 5G networks.
    1. Could the SR 500 microwave transport and local switching equipment used to provision service to these areas operate on another type of spectrum? Did TELUS attempt to identify alternative spectrum to ensure continuity of service for Canadians using the current or alternative equipment? If yes, what options are available. If not, why not?
    2. To the extent not identified in response to question 1, has TELUS considered other solutions using similar available equipment types and available spectrum (for example, non-auctioned spectrum)? If so, identify the equipment/solutions and provide complete details associated with their implementation. If not, why not?
    3. If other solutions were identified or are technically possible, explain why they were not considered/implemented.
  3. TELUS indicated that it has a voice over Internet protocol (VoIP) solution that is only available for business customers. Why is such a solution not available to residential customers? Could it technically be made available and if yes provide all the implementation details.
  4. Provide the company’s view on whether an ILEC should be required to seek Commission approval in order for it to be relieved of its obligation to serve in a given area where it has been providing local telephone services.
  5. Provide the company’s view of whether an ILEC’s obligation to serve continues to apply where facilities (such as spectrum) are no longer available, but alternative facilities may be available (such as alternative spectrum or technology).
  6. Provide the company’s view of whether, to the extent that TELUS may already have disconnected service for one of the communities as of December 2023, TELUS may currently be in contravention of Telecom Regulatory Policy 2020-40 or provisions of the Telecommunications Act.

To the extent that information is submitted in confidence pursuant to section 39 of the Act, an abridged version of all submissions must be provided for the public record. In light of the public’s interest in understanding the situation, TELUS is requested to disclose information on the public record to the maximum extent possible. A copy of this letter and all related correspondence will be added to the public record.

Sincerely,

Original signed by

Leila Wright
Executive Director
Telecommunications Sector

c.c.:  Michel Murray, CRTC, michel.murray@crtc.gc.ca
Christine Brock, CRTC, christine.brock@crtc.gc.ca

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