PUBLIC INTEREST ADVOCACY CENTRE LE CENTRE POUR LA DEFENSE DE LINTERET PUBLIC

ONE Nicholas Street, Suite 1204, Ottawa, Ontario, Canada K1N 7B7 Tel: (613) 562-4002. Fax: (613) 562-0007. e-mail: piac@piac.ca http://www.piac.ca

January 19, 2012

Canadian Radio-Television and Telecommunications Commission Ottawa, ON K1A 0N2 BY ACCESS KEY Attention: Mr. John Traversy, Secretary General Dear Mr. Traversy: Re: The Companies' Part 1 Application - Pay Telephone Rate Increase The Public Interest Advocacy Centre (PIAC) and Canada Without Poverty (CWP) by its counsel PIAC is in receipt of a Part 1 Application from Bell Aliant Regional Communications, Limited Partnership (Bell Aliant), Bell Canada and Tlbec, Socit en commandite (collectively, the Companies) entitled " Pay Telephone Rate Increase" dated 17 January 2012. The Application cover letter states that it is: "requesting that the Commission grant them the flexibility to increase their pay telephone (payphone) rates from the rates currently applicable to pay telephones that were set in Telecom Decision CRTC 200727, Price cap framework for large incumbent local exchange carriers." PIAC on its own behalf and as counsel for Canada Without Poverty expects to oppose the Application. However, we note that the choice of procedure chosen by the Companies is not conducive to a full and proper consideration of this matter. In the application procedure, intervenors are limited to one written intervention and no reply. The intervention must be filed within 30 days. The Companies may reply. The application raises an issue (payphone service) that has not been extensively reviewed by the Commission since 2004.1 The market has not developed as anticipated in some Commission decisions and as well, the use of payphones by the public has also changed to more resemble a social service. PIAC expects to raise issues of social utility of payphones and ideally to introduce evidence of payphone use by the public, in particular those persons living on low income. However, commissioning and compiling this information will take more time than is allotted for intervention. In addition, the Commission and other parties may benefit from an interrogatory round where incumbent wireline operators are asked more detailed questions about their payphone services and future plans. Again, the present procedure does not allow for this additional information to become part of the record.

See Telecom Decision CRTC 2004-47, Access to pay telephone service (15 July 2004). Online: http://www.crtc.gc.ca/eng/archive/2004/dt2004-47.htm

Therefore, for all of the above reasons, PIAC/CWP request that the Commission turn the above-noted application into a Telecom Notice of Consultation with new timelines that allow for a longer timeframe, full and adequate reply rights and an interrogatory round in order to ensure informed and adequate public participation.

Yours truly,
Original signed

John Lawford Counsel for PIAC/CWP cc The Companies Parties and Interested Parties to Telecom Public Notice CRTC 2006-5 Lynne Fancy, CRTC *** End of Document ***