By Ahmad Hathout
Rogers wants to know why Bell and Telus have such drastic differences in proposed surcharges for a new service that will allow Android phones to more accurately communicate their locations with emergency responders under the next-generation 911 system.
The Emergency Location Service (ELS) is a Google location service that allows Android-based devices – relying heavily on Wi-Fi sensors, but also using GPS and cell towers – to provide enhanced location data directly from the device to the public safety answering point (PSAP) where 911 calls are received. The result, it is said, is accuracy, speed and reliability of location information for emergency calls.
Telus and Bell, who were directed by the commission to be the aggregators for the ELS system, have filed proposed surcharges for the new technology. Telus has proposed a recurring wholesale surcharge of $0.0073 per wireless network access and Bell has proposed a rate of $0.0007, 10 times lower than Telus’s rate.
But Rogers said in an intervention on the proposals this month that because the services provide the same functionality to wireless service providers, it should be the “near identical.”
“The Commission should review in detail the commercial arrangement that was executed between TELUS and their 3rd-party vendor(s),” Rogers said in its submission. “This cost clearly seems to be exaggerated.”
“The service provided by the Aggregators is somewhat rudimentary,” Rogers said in its submission. “Their AML network architecture should be comparable, and one would expect that the proposed AML tariffs would be proportionally similar.
The cable giant noted that it has no insight into why the cost studies are so significantly different because the telcos have claimed confidentiality over components of it. On this point, Rogers is asking for more transparency because it is in the public interest.
“In their respective cost studies, Bell and TELUS provide limited details on their AML network architecture and cost components,” Rogers said. “The Commission should therefore examine closely each network element, specifically where equipment, facilities, 3rd party platform, etc. may be shared with other services (e.g. NG9-1-1).
“Given that AML service is a public good, and that there will never be any competition in that specific market, the ILEC’s confidentiality claims are inappropriate,” Rogers said in its submission.
“The disclosure of the financial information is in the public interest, will not impact their competitive position nor cause them specific and direct harm,” it continued. “The disclosure of this information would provide an extensive amount of detail on the public record about the AML architecture and would allow all interested parties the possibility to assess carefully their costing models.
“Rogers is of the view that the absence of disclosure materially limits the ability to comment on these two tariff filings and undermines the public interest in ensuring that the rates for this critical AML service are just and reasonable.”
Rogers also argued that cost recovery for this new technology should not be five years as proposed, but at the very least on a 10-year timeline, citing legacy 911 cost studies that haven’t been updated in over 20 years.
“NG9-1-1 service, including AML, will be in place, at a minimum, for the next 15 to 20 years,” Rogers said. “It is therefore absolutely imperative that all stakeholders, including the Commission, ensure that these rates are properly set. Canadians should not incur unnecessary charges on their monthly invoices and be required to over-compensate the ILECs for these monopoly services.”
