From: The King's[SMTP:thekings@accesswave.ca]

Sent: August 31, 2001 9:23 PM

To: procedure@crtc.gc.ca

Subject: Proposed NS rate increase

I write regarding Alliant's proposed rate increase for local telephone service in Nova Scotia.  The idea of a rate increase is not what is troubling, what is troubling is that the rate increase is not uniform across all users.  There are several issues which, in my mind, do not add credibility to their proposal.

 

The premise for Alliant's proposal is that it costs more to provide service in remote areas.   What type of service are they referring to; installation, maintenance or operations?  I have had a phone for at least 20 years and have had maintenance issues which are usually resolved remotely rather than a visit by a sercie person to my home.  In this digital age, phones can be tested by a technician/operator remotely, noise levels on the line can be determined and other problems can be determined and I'm sure in some cases rectified without the need for a visit to the site of the problem.  I have experienced this several times over the last few years and have not had a service person visit my residence to resolve any of these problems. 

 

Also, how many communities in the Maritimes can be considered remote.  First, a definition of remote is needed.  Yellowknife or Alert would be remote because of limited access.  There are few places in the Maritimes that truely qualify for the category of remote with perhaps the exception of Labrador and Newfoundland and I wonder how many of those communities have telephone service.  If a suitable definition of remote could be determined, and communities assessed to categorized as remote, I would expect to see the total number of phones in these areas to be rather small compared to the overall number of phones in the Maritimes that Alliant provides service to.  Additionally, for the people who live in these so called remote areas, one would expect to find that the average household income is not as great as the average income in larger urban areas.  The point that I am driving at here is that the increase of their rates because of their location will not pay Alliant for the service that they provide and that the people in these locations cannot be expected to pay more for a universally required communication service. 

 

To draw some parallels to universallity for unique provision of service, federal income tax is the same regardless of location for people making the same wages, public education and health care are federally funded despite geographical location, Search and Rescue, RCMP, and the list goes on.

 

If companies like Alliant, which have a legislated monopoly, are permitted to discriminate based on the concept of a comunity being remote, what would prevent other monopolies like Nova Scotia Power from applying for the same consideration to the other regulatory bodies and use the same arguement.  If one lets the imagination explore the possibilities, what other expense related schemes could be contrived to solicit increases that would be passed on to the detriment of a distinct group of users (remotely situated people in this case) just to increase the profit of the company and benifit the shareholders and provide good bonuses to the upper management.  Consider your federal income tax being determined based on where you live.  For example, if you live in Toronto you would pay much less federal tax than someone living in Sydney NS.

 

The brochure provided by Alliant in a recent account statement indicates that Canadians enjoy some of the lowest rates in the world for long distance, wirless and internet access, and we have lower or comparable prices for local service when compared to other major industrialized nations.  It is interesting that the lowest prices are for the services in which no monopoly exists and the local service is comparable, which I suspect is mostly due to regulation.

 

Alliant's proposed Service Improvement Plan would see some communities that presently do not have telephone or telecommunications service receive service while other communities would not receive service because the expenditure is too great in their opinion.  This hardly sounds like a company that is seeking the benifit of the communities, but a company that is seeking profit for a few.

 

Alliant also indicates that some scheme  of quality of service indicators would be monitored and potential rebates to customers.  Who would determine what the quality of service indicator are, Alliant? Who will monitor the quality, Alliant?   That would be a conflict of interest.

 

I believe that if an independent assessment of Alliants expenses were to be conducted, a proper determination could be made as to the real need of the increase due to servicing of these communities and the rate spread across the entire group of users would be neglible rather than a 20 percent increase to certain as of yet unspecified users.

 

Services that are provided in a monopolistic manner cannot be used as a profit tool.  When Alliant uses the arguement that it wants to adopt pricing policies consistent with other industries, then let Alliant relinquish its monopoly position on local sercive and be consistent with other industries in every aspect.  I would wager that they are not willing to give up their preferred position as the sole provider of local telephone service.  Services, like electrical power, telephones, health care, policing etc are not expected to be provided for based on how many users there are in a given area, rather, they are provided for by the entire population sharing the expense to make these services universally available.  If the costs of servicing is a factor in their providing the service to those in remote areas or to communities that do not yet have service, it should be shared by all and not on the backs of those who obvoiously cannot afford to pay to have it installed.  This is the spirit of the principle that this monopoly is sanctioned by legislation.

 

I firmly believe that they should be given an increase if the need can be justified.  Service must be maintained and expanded to unserviced areas.  The increase in costs must be shared by all and not just those in "remote" areas.

 

Sincerely,

 

Wayne King