Letter to CRTC re. Telus Service
To: Cheryl Grossi,
Manager,
Western & Northern Region
CRTC
970–360 Main Street/970- 360 rue Main
Winnipeg, MB, R3C 3Z3
204–983–6599
e-mail: cheryl.grossi@crtc.gc.ca
cc: Patrick Brabazon,
Board Chair,
Powell River Regional District
e-mail: brabazon@shaw.ca
cc: Marie Crawford
Union of B.C. Municipalities
e-mail: mcrawford@ubcm.ca
cc: Gord Johns,
MP — Courtenay-Alberni
e-mail: gord.Johns@parl.gc.ca
cc: The Honourable Mélanie Joly,
Minister of Canadian Heritage
e-mail: melanie.Joly@parl.gc.ca
Via e-mail.
Dear Cheryl Grossi,
Re: CRTC Case ID: 719891
Abstract
1. Subsequent to the purchase of B.C. Tel by Telus, new practices of deferred and insufficient maintenance of the physical plant on Lasqueti Island has resulted in worsening and unacceptably high frequencies of service outages, coupled with unacceptably long time to repair. Telus’ neglect of their Lasqueti customers is causing harm and endangering lives, and the CRTC is coming dangerously close to neglecting their mandate as a regulator by blaming the victims of Telus’ cost-cutting.
Introduction
2. On November 17th, Ezra Auerbach shared correspondence received from the CRTC in response to his formal complaint regarding the reliability of Telus’ phone service.
This correspondence, along with correspondence sent by the Powell River Regional District to the CRTC regarding the unacceptable state of phone service on Lasqueti, can be read at http://www.lasqueti.ca/node/5580
3. It is our view that the response received from the CRTC is unacceptable, and comes dangerously close to what is commonly described as “regulatory capture”, wherein a regulator begins to side with the corporations they are mandated to regulate, rather than with the people who are damaged by the violations committed by these corporation.
It is critical to note that Telus is a for-profit corporation with has a mandate to generate maximal profits for their shareholders. All comments from Telus must be read through this lens of cost avoidance/profit maximization.
Demonstration of Standing and Harm
4. I am a Telus subscriber, and I require reliable telephone service in order to do my job, as I spend an average of four hours each weekday on teleconferences and other phone calls. When there are outages and periods of degraded service (such as significant hum, crackle on the line, and frequent call drops), I must leave my home office and work out of the company office in Vancouver.
5. I have personally experienced multiple service outages over the years, with the longest outage, in early 2015, taking three months to repair. These outages have caused me significant economic harm, measured in thousands of dollars.
6. When we purchased our property on Lasqueti five years ago, being in a Telus service area was a major factor in making our purchase. Without reliable phone service, I am unable to work from home. If I am unable to work from home, living on Lasqueti becomes economically and logistically impractical.
7. Telus is regulated by the CRTC to provide reliable and dependable service for ALL service areas. We rely on the ability and willingness of Canada’s telecommunication regulator to ensure that where phone service is provided, phone service will be reliable and maintained. Lasqueti is only 85 km WNW of downtown Vancouver, and I routinely travel to and from Vancouver using only public transit (bus and ferry). It is not nearly as remote or inhospitable as many other locations where reliable telecommunication services are being provided.
8. Furthermore, calling by telephone is the only way to reach emergency services in the event of a medical or fire emergency. Many areas of Lasqueti Island have no cell phone reception (including our home), so in the event of a medical or fire emergency, landline service outages can result in increased economic damage, or even avoidable death(s).
I am a member of the Emergency Dispatch Advisory Committee, and we have identified that deficiencies in Telus’ service availability and reliability is the single most significant issue preventing the community of Lasqueti from having a reliable and available emergency dispatch service.
As a regulator, the CRTC is the agency ultimately responsible to ensure that lifeline services are reliable and available.
Evidence of Sub-standard Service
9. Reliability issues on Lasqueti are a direct result of deferred maintenance and lack of investment. While Telus is attempting to patch over some of the problems that exist, they have accumulated a significant maintenance deficit, and allowed many components of their outside plant to deteriorate to the point where complete replacements are required.
Examples of sub-standard and deferred maintenance include:
- “Temporary” cable splices that are no longer waterproof, resulting in outages and degraded service due to water ingress during the wet part of the year.
- “Temporary” cable segments that are installed running above ground, instead of being buried like the cable they replace. These above ground cables are often damaged by wild animals, which catch on the cable and pull them, breaking pairs, splices and terminations. Sometimes these “temporary” cables are pulled across the road, where they are further damaged by traffic (until someone stops and moves the cable back to the side of the road).
- Pedestals that are no longer waterproof or insect-proof.
If Telus had continued to maintain and invest in the plant at the same level that B.C. Tel did, we would not be having this discussion.
10. Telus has been aware of significant reliability issues on Lasqueti for years, and has the technical capability to monitor for service outages. However, they have chosen not to proactively schedule repairs. Service to a majority of the island is provided through a FlexAccess 9000 system, so information on communication disruptions and degradation between the COT shelf and the subscriber terminals is available via the system management interface.
Telus has the technical ability to collect detailed reliability statistics for their telephone service. If they do not have this information, it is because they have not chosen to do so.
Our Objections to the CRTC Response
11. In your response, you state, “one of my staff had the opportunity to visit Lasqueti Island a few years ago as part of an investigation into the quality of phone service on the island and has provided me with valuable insight on the island and the manner in which phone service is provided,”
We formally request that you make this report available so that the community can verify its accuracy.
12. You mention “Commission staff is aware of the community’s desire to avoid the use of poles on the island which then forces TELUS to lay its cable at grade deployment.” We feel this is not an accurate representation.
Poles are not an viable option on Lasqueti due to lower reliability and higher costs resulting from significant tree clearing that would be required, and high frequency of falling trees during the stormy winter months. The community does not want poles because they understand that this would be a waste of money, as an aerial cable plant would be very expensive to install and less reliable than what we have today. Furthermore, it is clear that the cost of installing poles would be higher than a direct or conduit bury plant.
13. Telus asserts, and you state you have accepted their assertion that, “the majority of this island’s terrain prohibits direct or conduit bury”. This is incorrect. A majority of the plant is direct bury. In fact, the entire plant, from the CO to our demarc, is (was) completely buried, a distance of almost 8 km.
Where undisturbed, this buried plant remains one of the more reliable part of the system. Over time, as the plant has aged, buried cable has often been replaced with lower-cost at-grade cable to reduce repair costs. However, this has further reduced service reliability.
Telus has approached this from the perspective of trying to avoid investing in the cable plant. Direct or conduit bury is viable, has been done in the past for significant parts of the island, and does not have to be impractically expensive. Other possible options, such as heavily armoured above-ground cable along with industrial ground anchors, does not appear to have been considered. Finally, unexamined cost comparisons can easily be distorted by adjusting assumptions to support a given conclusion.
14. Telus’ assertion that the lack of “standard commercial power restricts its ability to offer seamless telecommunications service on the island” is incorrect and is a poor excuse. As a regulator, the CRTC should be pushing back on assertions like this. By blindly accepting incorrect information from Telus, you create a perception in the community that you are not aware of the situation on the ground and are willing to accept information from Telus without closer examination.
Telus has six power sources for their CO and main microwave link:
- Telus’ backup batteries
- Telus’ backup generator
- Primary generator power purchased from the False Bay School power micro-grid
- Secondary generator power purchased from the False Bay School power micro-grid
- Backup battery power purchased from the False Bay School power micro-grid
- Solar power purchased from the False Bay School power micro-grid
The power supply for the Lasqueti equipment is arguably one of the most reliable power systems in the area.
Lack of grid power in other areas serviced by the CO is not a legitimate concern. Land-line telephone service must, by regulation, continue to operate even during a grid power outage via -48 VDC supplied over the subscriber loop.
We request you request an explanation from Telus to justify their assertion that a lack of “standard commercial power restricts its ability to offer seamless telecommunications service on the island”.
In Conclusion
15. By stating:
“In Commission staffs’ view, the obstacles identified directly above are beyond TELUS’ control and require action by the community first if the provision of phone service to the island is to be improved.”
You are allowing a regulated corporation to avoid investing money to resolve the issues they have created by avoiding investing money.
These “obstacles” are issues of money, namely, Telus’ desire to not spend money to meet their regulatory requirements. And by stating the above, you are failing your role as a regulator.
Fundamentally, you are blaming the community for Telus’ failings. This is known as “victim blaming”. You are here to regulate powerful companies whose primary goal is profit, not to turn around and blame the very customers they are failing to serve.
16. As we stated in our Intervention 2015–134 (file number 8663-C12–201503186):
“as a consequence of the principle of Universal Service [3] enshrined in the establishment of Canada’s first telecommunication service, and the principle of non-discriminatory pricing, no citizen should be punished or denied service as a consequence of their rural or remote location.”
The community wants to work with Telus to have reliable telecommunication services. Telus has not been willing to work with the community. This is why we need a regulator. That is why we are writing to you.
In Conclusion
17. Based on the above, we feel that the following actions are warranted by the CRTC:
- Please provide documentation associated with the visit to Lasqueti mentioned in your correspondence.
- Please request that Telus justify how and why lack of “standard commercial power restricts its ability to offer seamless telecommunications service on the island”
- Please elaborate on what “action by the community” you believe are required, and why these are the “responsibility” of the community, rather than the responsibility of Telus.
Sincerely,
David and Laura Slik
Lambert Lake
Lasqueti Island
B.C., V0R 2J0
** End of Document **
