To:  The Secretary General, CRTC

Dear Sir/Madam,

                                                    re:  TELUS - Proposed Service Improvement Plan

When reviewing the form of regulation for telephone companies in Canada, the Canadian Radio-television and Communications Commission (CRTC) should not lose sight of its obligation to protect the interests of the ordinary citizen, and in particular, householders for whom telephone services are essential.  The CRTC should not overlook the fact that the telephone companies are private commercial undertakings whose primary aim is to make profits for the purpose of paying dividends to their shareholders, and high salaries and perquisites to their executives.  It should also be borne in mind that operating and expansion costs will nearly always be a factor when deciding dividend and bonus payouts, with the former usually a secondary consideration because investors in privitized utility companies are not in the game for altruistic reasons.  They are in it for financial gain.   While this may be acceptable in a free market society in the context of general commercial activity, it is an entirely different matter when it comes to the supply of essential services to society as a whole.  An affordable telephone service is one such undertaking.

The proposed TELUS Service Improvement Plan is skillfully presented as a social benefit reaching out to unserviced communities and areas where upgrading is required.  Unfortunately the munificent provider of the benefit is unwilling to pay for it and has come up with a 'subsidy' scheme which, if approved by the CRTC, will impose an additional financial burden on seniors, non-profit organizations, as well as ordinary working people.

There have been rumours that the telephone companies are anxious to raise charges against local calls.  This aspect seems to have been factored into the TELUS Service Improvement Plan, in that it requests flexibility "...to raise rates for local services (including extended area services) by up to $3 per month, per year, to a maximum monthly rate of $35 per month for residential customers."   The proposal for business customers is even more draconian!   The plea by TELUS for flexibility to raise local and extended area service rates should be disregrded, because it is nothing more than a request to be liberated from CRTC supervision when it embarks on increasing the prices of services provided to the consumer by the former.  Furthermore, the funding proposals for the Improvement Plan envisaged by TELUS is tantamount to a tax/levy on its existing customers, in that only part of the cost would be borne by those who would ultimately benefit from new or extended services.  All other customers would have to subsidize the beneficiaries "...for any amount beyond the customer's $1000 per household, up to a maximum of $25,000 per household."   Even more horrific is the proposal that costs of Service Improvement Plan upgrades for under-serviced communities are to be paid entirely from a levy on ALL other customers.  This proposal is absolutely unacceptable because TELUS is a private commercial corporation which should fund expansion of its trading operation from its own revenues.  It is unreasonable for TELUS to expect to enjoy the same financial privileges as federal or provincial government agencies.  Of prime importance, TELUS and similarly structured corporations should NEVER be empowered to raise levies or like charges on consumers without surveillance by and approval of the CRTC.

Yours truly,

A. James Muller

Copy to TELUS:  Willie Grieve, Vice President - Regulatory Affairs