January 19, 2012Canadian Radio-Television andTelecommunications CommissionOttawa, ONK1A 0N2
BY ACCESS KEY
Attention: Mr. John Traversy, Secretary GeneralDear 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 isin receipt of a Part 1 Application from Bell Aliant Regional Communications, Limited Partnership (BellAliant), Bell Canada and Télébec, Société en commandite (collectively, the Companies) entitled "
PayTelephone 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 2007-27,
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 andproper consideration of this matter. In the application procedure, intervenors are limited to one writtenintervention 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 theCommission since 2004.
The market has not developed as anticipated in some Commission decisionsand 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 payphoneuse by the public, in particular those persons living on low income. However, commissioning andcompiling this information will take more time than is allotted for intervention. In addition, theCommission and other parties may benefit from an interrogatory round where incumbent wirelineoperators are asked more detailed questions about their payphone services and future plans. Again, thepresent 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
PUBLIC INTEREST ADVOCACY CENTRE LE CENTRE POUR LA DEFENSE DE L’INTERET PUBLIC
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