The Public Interest Advocacy Centre has filed a Part VII application with the CRTC claiming ILECs are not revealing the basic toll service rates. An edited version of the submission appears below. Over the years, ILECs have offered an ever-changing array of discount toll plans to residential customers. In addition to their "discount toll plans", ILECs are required to offer toll service under regulated BTS rate schedules. Customers who are not subscribed to a discount toll plan are charged BTS rates, with applicable time-of-day discounts, for toll calls. Depending on the time of day and distance of the call, calls made under BTS rates can be less expensive than if made under a so-called "discount" plan.  Some discount toll plans involve a set monthly fee or minimum monthly charge; others do not. In late 2001, toll service providers began to levy a mandatory monthly $1.25 charge on their discount toll plans as a way of recovering high cost area subsidy funds from subscribers. With the exception of SaskTel, all of the major ILECs and competitors now levy a mandatory $1.25 monthly charge on their residential discount toll plans.  The imposition of monthly fees and minimum charges for discount toll plans immediately increases the threshold of calling below which BTS rates make more economic sense for subscribers. In the absence of such charges, there may have been relatively few customers for whom BTS made more sense than a discount toll plan. Once mandatory monthly fees are added to discount plans, however, BTS rates become the best option for many more customers. According to data provided by Bell Canada during the recent price cap review proceeding, 7.4 per cent of Bell’s customer accounts used no long distance at all during the period January to June 2001, 25 per cent used less than 7.5 minutes of toll calling per month, and the median customer (50th percentile) used 42.5 minutes per month. Telus provided similar data for the same period. Based on this data, it would appear that a significant proportion of Bell and Telus customers are better off under BTS rates than under discount toll plans. Yet, according to Bell in October 2001, "less than five per cent of its residential customers make toll calls in a typical month yet are not signed up for a toll plan with either the Company or a competitor". In June 2002, PIAC began researching long distance rates for its 10-year review of competition and deregulation in the telephone industry. One of the many items researched was ILEC basic toll rates. This information is not provided in telephone directories. In summary, no company provided BTS rate schedules to us upon request to customer service (requests were made by both tele-phone and email). In no case other than Bell Canada were we able to find the BTS schedules on the company website.  During a meeting of the CRTC "BMT Committee" on June 17th, 2002, regulatory staff from each major ILEC were informed by PIAC counsel of this problem, and were notified that action would be taken if it was not resolved. By late August 2002, most of the ILECs in question still did not make their BTS rate schedules available upon request, and most still did not have this information posted on their websites.  Of the three companies that now make this information available on their websites, only Telus’s posting discloses the BTS rates as a toll option. SaskTel’s BTS rate schedules are located on an obscure page of its website and are not mentioned on the page listing long distance options. Bell Canada’s web posting of "base rate schedules" is presented in a manner and location that is unlikely to be noticed by consumers seeking to understand their toll options with Bell Canada.  In addition, when low volume toll users inquire by telephone about the most appropriate toll option given their calling profile, research conducted by PIAC suggests that ILECs almost always direct them to discount toll plans, even when the customer may be better off under BTS rates.