Gentlemen:

I am responding to a note from Telus inviting comment on their submision for price changes and on the invitation of C.R.T.C. for comment on their review of current regulations.

In "cost accounting" one looks at an operation and ascertains the weighting of factors to the various components of an operation.  It is my contention that this was not done,but rather in the haste to deregulate an utility, and perhaps, to deal with the situation in a simplified manner, the operations were simply broken down to "local" and "long distance". This designation in no way describes what appears to happen in the communications field. For example, if I placed a long distance call to  the C.R.T.C  I would dial the number  on my local  system which would take the call through the local system to the long distance switching equipment. The long distance system would then route the signal to Hull, Quebec and there the call would be transfered to the local system so it could procede to the Switchboard at the C.R.T.C.  The foregoing, if correct, would indicate that local systems   are an integral part of a long distance system.  One would then have to question statements we hear such as "long distance makes money and subsidizes local systems".

Another fallacy that should be reviewed is that Business should receive lower rates due to their high volume.  Does not a high volume in this business require more equipment which relates to a higher cost to the system and one wouls think that busines should therefore pay a premium rate rather than a decreased rate.

In view of the foregoimg, I recomend that all increases in rates in Canada be frozen until the proper allocation of responsibility for the various components of the long distance system be ascertained and the proper distribution of money raised by long distance fees  between the long distance system and the local systems. 

Please let me know if additional informatin is required.

Syl Villett