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Ottawa, 5 April 2011

Our Reference: 8638-C12-201016882

BY E-MAIL

To Distribution List

Re: Follow up to Telecom Regulatory Policy CRTC 2010-632, Wholesale high-speed access services proceeding – Request for disclosure of costing information filed in confidence

This letter addresses requests for disclosure of information for which a claim of confidentiality has been made by Bell Aliant Inc. in Ontario and Quebec, and Bell Canada (collectively the Bell companies), Bell Aliant Inc. in the Atlantic provinces, MTS Allstream Inc., Saskatchewan Telecommunications and TELUS Communications Company, collectively the incumbent local exchange carriers (ILECs).

On 18 March 2011, the Canadian Network Operators Consortium Inc. (CNOC) and Primus Telecommunications Canada Inc. (Primus) each filed requests for disclosure of information for which confidentiality had been claimed.

On 25 March 2011, the ILECs filed with the Commission their responses to the above requests for disclosure of information.

In a letter dated 28 March 2011, the Bell companies filed revisions to their proposed GAS-FTTN services in order to introduce an aggregated volume pricing (AVP) proposal to replace their previous usage-based billing (UBB) model. In attachment to their letter, the Bell companies provided new costing information in support of the proposed new pricing structure. The Bell companies further indicated that the proposed revised access rates were based on costs which exclude all usage cost components.

The Bell companies are asked to confirm whether the 28 March 2011 proposed cost information (including all methodologies and assumptions) associated with the non-usage cost components is the same as that provided on 11 March 2011. If not, the Bell companies are to provide detailed documentation of the changes in costs, methodologies and assumptions, with supporting rationale.

The Bell companies are also asked to confirm whether the 28 March 2011 proposed cost information (including all methodologies and assumptions) for the usage cost components is the same as that provided on 11 March 2011. If not, the Bell companies are to provide detailed documentation of the changes in costs, methodologies and assumptions, with supporting rationale.

Disclosure

Requests for disclosure of information for which confidentiality has been claimed are addressed in light of sections 38 and 39 of the Telecommunications Act and section 33[1] of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure). In evaluating a request, an assessment is made as to whether there is any specific direct harm likely to result from the disclosure of the information in question. Further, in order to justify a claim of confidence, any such harm must be sufficient as to outweigh the public interest in disclosure. In making this evaluation, a number of factors are taken into consideration, including the following:

The degree of competition that exists in a particular market or that is expected to occur is an important consideration in assessing requests for disclosure. All things being equal, the greater the degree of actual or expected competition, the greater the specific harm that could be expected to result from disclosure;

Another factor in assessing the extent of harm is the expected usefulness of the information at issue to parties in furthering their competitive position. In this regard, an important consideration is the degree to which the information at issue is disaggregated. Generally speaking, the more aggregated the information, the less likelihood that harm will flow from its disclosure;

The expectation that specific direct harm might result from disclosure is not, by itself, sufficient to justify maintaining a claim of confidentiality. In certain circumstances, substantial harm from disclosure may still be outweighed by the public interest in disclosure; and

It should be noted that the treatment of confidentiality requests should not be taken as an indication of the manner in which such matters would be dealt with in the future in different circumstances.

Having regard to all of the considerations set out above, the information filed under a claim of confidentiality in response to the interrogatories and cost studies listed in Attachments 1 is, to the extent set out in the Attachment, to be placed on the public record of this proceeding. In each case where full or partial disclosure is to occur, it is considered that the specific direct harm, if any, likely to be caused by disclosure would not outweigh the public interest in disclosure.

Other Matters

It should be noted that in several interrogatory responses, certain requested information was either not provided or was incomplete. Accordingly, the ILECs are to revise their responses to 4 February 2011 and 11 February 2011 interrogatories, and provide responses to reflect the directions specified in Attachment 2.

In addition, certain information is being requested which is considered to be important to the record of this proceeding. The ILECs are each requested to respond to the interrogatories included in Attachment 3.

In their responses to Attachments 3, the ILECs are to provide information on the public record consistent with the disclosure requirements above.

Filing Requirement

As noted above, additional questions are required to assess the additional information provided in response to the 4 February 2011 interrogatories. Accordingly the process is modified to allow additional time to provide responses to the additional questions identified in attachment 3. The ILECs are accordingly required to provide the information sought in Attachments 1, 2 and 3 by 20 April 2011.

The information to be disclosed by the ILECs, as set out in Attachment 1, or to be provided, as set out in Attachments 2 and 3, is to be filed with the Commission and served on all interested parties, by 20 April 2011. The information to be provided by the Bell companies regarding any cost changes proposed in their 28 March 2011 submission is also to be filed with the Commission and served on all interested parties by 20 April 2011. The above material must be received, not merely sent, by this date. Copies of the documents should also be sent to richard.page@crtc.gc.ca.

Yours sincerely,

Yvan Davidson / for
Lynne Fancy
Director General
Competition, Costing and Tariffs
Telecommunications

cc: Yvan Davidson, yvan.davidson@crtc.gc.ca
Richard Pagé, richard.page@crtc.gc.ca

DISTRIBUTION LIST:

regulatoryaffairs@nwtel.ca; bell.regulatory@bell.ca; reglementa@telebec.com; iworkstation@mtsallstream.com; regulatory@bell.aliant.ca; Regulatory.Matters@corp.eastlink.ca; Regulatory@sjrb.ca; marcel.mercia@cybersurf.com; reglementation@xittel.net ; regulatory@distributel.ca; lisagoetz@globalive.com; regulatory@primustel.ca; telecom.regulatory@cogeco.com; regaffairs@quebecor.com; ken.engelhart@rci.rogers.com; regulatory.affairs@telus.com; crtc@mhgoldberg.com; eric@rothschildco.com; gfletcher@incentre.net; berzins@nucleus.com; babramson@mccarthy.ca; regulatory@execulink.com; ctacit@tacitlaw.com; abriggs@cogeco.ca; slavalevin@ethnicchannels.com; crtc@les.net; LBC_Consulting@live.ca; andre.labrie@mcccf.gouv.qc.ca; bob.Allen@abccomm.com; ghariton@sympatico.ca; lefebvre@rogers.com; kirsten.embree@fmc-law.com; bruce@brucebuchanan.net; jonathan.holmes@ota.on.ca; cataylor@cyberus.ca; chris.allen@abccomm.com; regulatory@vianet.ca; piac@piac.ca; tom.copeland@caip.ca ; hemond@consommateur.qc.ca; blackwell@giganomics.ca; jhpratt@msn.com; crtc@paul.ca; regulatory@lya.com; regulatory@teksavvy.com; dmckeown@viewcom.ca; David.Wilkie@tbaytel.com; regulatory@fibernetics.ca; jfmezei@vaxination.ca; stephen.scofich@tbaytel.com; regulatory@bcba.ca; crtcmail@gmail.com; telecom@gov.bc.ca; regulatory@telnetcommunications.com; apilon@acninc.com; regulatory@cnoc.ca; jp@electronicbox.net; pris@pris.ca; michelle.duguay@telus.com; document.control@sasktel.sk.ca;

Attachment 1

Disclosure of Confidential Information

The ILECs are to provide on the public record the information that they filed with the Commission in confidence, as set out below:

Bell Aliant

Bell Aliant(CRTC)15Sep10-104

All information

Bell Aliant(CNOC)11Feb11-3

For tables 5a, 5b and 5d of Bell Aliant’s revised study report filed on 11 March 2011, provide the percentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

Bell Aliant(CNOC)11Feb11-4

For tables 5a, 5b and 5d of Bell Aliant’s revised study report filed on 11 March 2011, provide the percentage of service provisioning calculated as

(Service Provisioning PWAC) / (Total PWAC)

The Companies(Primus)11Feb11-3

The Bell companies

The Companies(CRTC)15Sep10-104 b) i) and ii)

The Companies(CNOC)11Feb11-4

The Companies(CRTC)04Feb11-110c)

All information

 

The Companies(Primus)11Feb11-3

MTS Allstream

MTS Allstream(CNOC)11Feb11-4

For tables 6.4.5-1 to 6.4.5-9 of MTS Alstream’s revised study report filed on 11 March 2011, provide the percentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

SaskTel

Sasktel(CNOC)11Feb11-4

For tables 20 to 28 of SaskTel’s revised study report filed on 11 March 2011, provide the percentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

TELUS

Telus(CNOC)4Feb11-1 A) 2) and TQ(CNOC)4Feb11-1 A) 2)

List of equipment for each of the resource types provided in answer to the interrogatory.

Telus(CRTC)15Oct10-103

Average working fill factors

Telus(Primus)4Feb11-2

Attachment 2

Further responses to Interrogatories

The ILECs are to provide further responses to the interrogatories identified below, to the extent set out below:

The Bell companies

The Companies(CRTC)4Feb11-105 Attachment

Provide on the public record all maximum capacities

The Companies(CRTC)4Feb11-106

Provide on the public record all maximum capacities

MTS Allstream

MTS Allstream(CRTC)4Feb11-106

Provide on the public record all maximum capacities

SaskTel

Sasktel(CRTC)4Feb11-103A Attachment

Provide on the public record all maximum capacities and working fill factors

Sasktel(CRTC)4Feb11-111A Attachment

Provide on the public record all maximum capacities and working fill factors

Attachment 3

Interrogatories

Aggregated ADSL tariffs: matching speeds - Interrogatories to Bell Aliant (defined to include Bell Aliant in the operating territory of the four Atlantic Provinces)

1. In response to Bell Aliant(CRTC)04Feb11-102, Bell Aliant indicated that the FTTN development costs should be recovered from all customers regardless if they are retail or wholesale customers. Bell Aliant further provided an estimate of the wholesale share of total DSL end-user demand at year-end 2015 that it used to allocate its FTTN development costs to wholesale ADSL Access Service-FTTN.

a. Identify all services that make or plan to make use of the FTTN network (e.g. retail Internet, IPTV, GAS-FTTN).

b. For each of the services identified in a) above, for each of the years 2010 to 2015, provide an estimate of the number of retail end-users.

c. Provide an estimate of the proportionate share of each service’s use of the FTTN network. Further provide Bell Aliant’s views on the appropriateness of assigning the above noted FTTN development costs to the FTTN related services based on these proportionate shares.

2. In response to Bell Aliant(CRTC)04Feb11-113, Bell Aliant provided a revised study with a 10 year study period.

a. Provide a revised table 3 of the attachment to Bell Aliant(CRTC)04Feb11-113 which shows the demand for all 10 years of the study period.

b. Using the format of tables 1, 2, 3 and 5 of the cost study and proposed tables of Bell Aliant(CRTC)15Sep10-103, provide revised 10 year cost study information for each of the following changes in assumptions: 

i. For each year of the study period, apply a CIF of -2% for access driven cost components (e.g. DSLAM) and -10% for traffic driven cost components (e.g. IP router).

ii. For each year of the study period, apply a CIF of -5% for access driven cost components (e.g. DSLAM) and -15% for traffic driven cost components (e.g. IP router).

c. Comment on the extent to which equipment capacity for traffic driven cost components are increased over time to satisfy higher traffic demand without significantly increasing the overall provisioning costs per end-user and thereby causing significant decreases in unit cost per peak hour Kbps for this category of costs.

3. Refer to response to Bell Aliant(CRTC)04Feb11-201.  For each of the “Service Order”, “Cross-connect at DSLAM” and “Customer Premises Work” sub-activities, identify the associated method, measurement and/or tracking system used to determine the proposed time estimate.

4. For each of retail and wholesale, in situations where a POTS splitter is already installed and a line optimization and testing has already been performed, explain if and why a truck roll would be required when a customer requests ADSL Access Service-FTTN; further provide an estimate of the percentage of time where a POTS splitter is already installed and a line optimization and testing has already been performed as (i) at the start of the study period and (ii) at the end of the study period, with supporting rationale.

5. In response to Bell Aliant(CRTC)04Feb11-204, the  company indicated that a truck roll is not required in the case of subsequent speed upgrades on an existing access line which do not require use of a VDSL modem or reconfiguration of an existing VDSL modem or where the ADSL Access Service-FTTN customer has provided and installed its own modem. 

Provide the percentage of time that subsequent speed upgrades were assumed to require a truck roll, with supporting rationale.

6. In response to Bell Aliant(CRTC)04Jan11-1, Attachment, the company provided the time estimate for the sub-activity “Technician performing on-site testing and line optimization at customer premises”. Provide a further breakdown of activities performed for this sub-activity, identifying the associated minutes, with supporting rationale.

7. Refer to SaskTel(CRTC)4Feb11-201

a. Comment with supporting rationale on SaskTel’s proposal to remove service establishment activity costs that are common to both the VDSL Access service and the Dry Loop or Unbundled Loop service such as costs for Service Call Taking, Service Call Problem Resolution and Assignment from its VDSL Service connection costs when provisioned with either a Dry Loop or Unbundled Loop in order to avoid double recovery of these costs. Further, identify Bell Aliant’s activities that are common to both the provision of the company’s ADSL Access-FTTN service and Dry Loop or Unbundled Loops.

b. Explain, with supporting rationale, if and why Bell Aliant’s activities identified in response to  a) above  cannot be performed at the same time if both ADSL Access-FTTN Service and Dry Loop or Unbundled Loop services are required at the time of the ISP request; further comment on the expected cost efficiencies and reductions if the service establishment activities for both ADSL Access-FTTN service and Dry Loops or Unbundled Loops are provisioned at the same time, identifying the activities which would be subject to cost efficiencies.

Aggregated ADSL tariffs: matching speeds - Interrogatories to Bell Canada (defined to include Bell Canada and Bell Aliant in the operating territory of Ontario and Quebec)

1. In response to The Companies(CRTC)15Sep10-105 b) i) Revised Update, the Bell companies provided estimates of percentage trouble tickets per end user per year for help desk activities. In response to The Companies(CRTC)28May10-8 TNs 269 & 7205, the Bell companies indicated that 7.08% of all copper-related trouble tickets were directly attributable to DSL service.

a. Explain why the Bell companies are proposing a methodology to estimate help desk costs which is different from that employed in the TN 269\7205 proceeding.

b. Provide a revised estimate of the help desk costs based on the methodology used in TN 269\7205 and adjusted as per Telecom Decision 2011-24 determinations.

2. In response to The Companies(CRTC)04Feb11-101, the Bell companies indicated that the network conditioning activities are performed for the FTTN service as a whole and that since both retail customers and wholesale end-users ultimately benefit from these network conditioning activities, the network conditioning costs should be recovered from both retail and wholesale customers.

In response to The Companies(CRTC)04Feb11-103, the Bell companies indicated that the initial business plan to develop FTTN-based services was premised on the expectation that there would be recovery of the up-front investment from the entire base of future end-users and not just a portion thereof.

In response to The Companies(CRTC)15Sep10-102, the Bell companies provided an estimate of the wholesale share of total residential DSL end-user demand at year-end 2015 that it used to allocate its network conditioning and FTTN development costs to wholesale GAS-FTTN.

a. Identify all services that make or plan to make use of the FTTN network (e.g. retail Internet, IPTV, GAS-FTTN).

b. For each of the services identified in a) above, for each of the years 2010 and 2015, provide an estimate of the number of retail end-users.

c. Provide an estimate of the proportionate share of each service’s use of the FTTN network. Further provide the Bell companies’ views on the appropriateness of assigning the above noted FTTN development and network conditioning costs to the FTTN related services based on these proportionate shares.

3. Refer to The Companies(CRTC)04Feb11-201, Attachment 2, where the Bell companies have identified external vendor fees and the use of Bell Technical Solutions (BTS) technicians.

a. Confirm that BTS was formerly called Entourage Technology Solutions, and that BTS is currently a wholly owned subsidiary of Bell Canada Enterprises.

b. Identify the duration of the current contract with BTS to perform installation activities, including the expected renewal date of the contract.

c. Indicate whether the external vendor fees provided in the response included the Ontario Provincial Sales Tax. If so, provide a revised proposed table in The Companies(CRTC)04Feb11-201, Attachment 2 and further revised proposed tables 5m and 5n of the Bell companies’ revised Economic Evaluation Report filed 11 March 2011, to reflect the exclusion of this tax.

d. Confirm that the costs for VDSL modems are not recovered through the GAS-FTTN rates.  If so, explain with supporting rationale, why a portion of the truck roll required for testing and optimization of the lines for all new FTTN orders should not be attributed to the installation of VDSL modems; further provide a proportion of the truck roll costs that should be attributed to VDSL modems.

4. Refer to the response to The Companies (CRTC)04Feb11-201, Attachments 1 and 2.

a. In response to The Companies(CRTC)04Feb11-116, the Bell companies indicated that for all new FTTN customers, a truck roll to the customer premises occurs in order for technicians to perform testing and line optimization at the customer premises.  The Bell companies also stated that at that time, the technician may also install a POTS splitter at the customer premises.

i. Identify the proportion of the cost of this truck roll that is attributed to each of the monthly and service charge rate elements, with supporting rationale.

ii. Explain how the proportion of the truck roll cost attributed to the service charge is reflected in Attachment 2 of The Companies (CRTC)04Feb11-201(showing the derivation of the associated vendor fee and occurrence rate, including all supporting assumptions). The response should provide the external vendor fee for this truck roll and should confirm that this fee provided in Attachment 2 reflects the external vendor fee charged to the Bell companies, as adjusted to remove the portion of the truck roll activity assigned to POTS splitters.

iii. Explain whether the Bell companies incur a similar truck roll, with similar occurrence rates and external vendor fee, for their retail FTTN Internet services, with supporting rationale for any differences.

b. In response to The Companies(CRTC)04Feb11-116, the Bell companies further indicated that the same truck that has been sent to the customer premises to perform testing and line optimization may also go on to visit the remote DSLAM site serving that customer in order to perform field work at that remote

i. Confirm that this additional visit to the remote DSLAM site represents an additional truck roll activity which implies additional costs over and above those associated with the truck roll identified in part a) above.

ii. Explain how the truck roll cost associated with the additional visit to the remote DSLAM site is reflected in Attachment 2 of The Companies (CRTC)04Feb11-201(showing the derivation of the associated vendor fee and occurrence rate, including all supporting assumptions). The response should provide the External Vendor Fee charge to the Bell companies for this type of truck roll.

iii. Explain whether the Bell companies incur a similar truck roll, with similar occurrence rates and external vendor fee, for their retail FTTN Internet services, with supporting rationale for any differences.

c. In light of the responses to parts a) and b) above, confirm that the Bell companies have assumed that a GAS-FTTN order would cause them to require one truck roll, but would cause them to incur, on average, more than one vendor fee associated with this truck roll. If so, given the high frequency of occurrence for these two vendor fees, explain, with supporting rationale, whether the Bell companies intend to re-negotiate this part of the vendor contract to reduce its truck roll costs; further explain whether this frequency of occurrence is expected to decline over time, and further provide the expected frequency of occurrence in the first and last years of the study, with supporting rationale.

d. Provide the Bell companies’ best estimate of the traveling time for each of the two truck roll activities identified in parts a) and b) above.

5. For each of retail and wholesale, in situations where a POTS splitter is already installed and a line optimization and testing has already been performed, explain if and why a truck roll would be required when a customer requests FTTN service; further provide an estimate of the percentage of time that a POTS splitter is already installed and a line optimization and testing has already been performed as (i) at the start of the study period and (ii) at the end of the study period, with supporting rationale.

6. Refer to the response to The Companies (CRTC)04Feb11-201, Attachment 2. Provide the assumptions, with supporting rationale, used to develop the “Sales Management” cost estimate for “Business office activities”, reflected in the “Actual Expenditures (or Spend) for Sub-activity” column.

7. In response to The Companies (CRTC)04Feb11-206, the Bell companies indicated that a truck roll is not required in the case of subsequent speed upgrades which do not require use of a VDSL modem or reconfiguration of an existing VDSL modem, such as when a speed other than 25 Mbps has been selected without the optional 7 Mbps upload speed, or where the FTTN customer is providing and installing its own modem.

Provide the percentage of time that subsequent speed upgrades were assumed to require a truck roll, with supporting rationale.

8. In response to The Companies(CRTC)04Feb11-117, the Bell companies provided a revised study with a 10 year study period.

a. Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of the response to The Companies(CRTC)15Sep10-103, provide revised 10 year cost study information and proposed revised rates per end-user for each of the following changes in assumptions:

i. For each year of the study period, apply a CIF of -2% for access driven cost components and -10% for traffic driven cost components.

ii. For each year of the study period, apply a CIF of -5% for access driven cost components and -15% for traffic driven cost components.

b. For access driven cost components, derive and provide the average annual change in DSLAM Alcatel 7300 equipment unit cost per end-user from 2006 to 2010, as derived from the information provided in the response to The Companies(CRTC)04Feb11-109. Further explain how the average annual change in DSLAM Alcatel 7300 equipment unit cost per end-user was derived from the information provided in the response, with supporting rationale.

c. For traffic driven cost components, derive and provide the average annual change in IP router unit cost per Kbps for peak hour from 2006 to 2009, as derived from the information provided in the response to The Companies(CRTC)04Feb11-109. Further explain how the average annual change in IP router unit cost per Kbps for peak hour was derived from the information provided in the response, with supporting rationale.

d. Comment on the extent to which equipment capacity for traffic driven cost components are increased over time to satisfy higher traffic demand without significantly increasing the overall provisioning costs per end-user and thereby causing significant decreases in unit cost per peak hour Kbps for this category of costs.

9. Refer to SaskTel(CRTC)4Feb11-201.

a. Comment with supporting rationale on SaskTel’s proposal to remove service establishment activity costs that are common to both the GAS-FTTN Access service and the Dry Loop or Unbundled Loop service such as costs for Service Call Taking, Service Call Problem Resolution and Assignment from its VDSL Service connection costs when provisioned with either a Dry Loop or Unbundled Loop in order to avoid double recovery of these costs. Further, identify the Companies’ activities that are common to both the provision of the Companies’ GAS-FTTN Access service and Dry Loop or Unbundled Loops.

b. Explain, with supporting rationale, if and why the Companies’ activities identified in response to  a) above  cannot be performed at the same time if both GAS-FTTN Access service and Dry Loop or Unbundled Loop services are required at the time of the ISP request; further comment on the expected cost efficiencies and reductions if the service establishment activities for both GAS-FTTN Access service and Dry Loops or Unbundled Loops are provisioned at the same time, identifying the activities which would be subject to cost efficiencies.

Aggregated ADSL tariffs: matching speeds - Interrogatories to MTS Allstream

1. Refer to the company’s response to MTS Allstream(CRTC)15Sep10-103, where the company provided IFC per Access as well as the PWAC for the “Fibre Umbilical – Buried Fibre Cable” associated with the V-AHSSPI services. Further refer to the company’s response to MTS Allstream(CRTC)15Sep10-103 Revised, where the company provided revised costs for the buried fibre cable.

a. Provide the methodology and assumptions used to estimate the revised IFC per Access for the Buried Fibre Cable component associated with the 100 Mbps V-AHSSPI service.

b. Explain the differences in costing methodology and/or assumptions between the buried fibre cable costs provided in response to MTS Allstream(CRTC)15Sep10-103 Revised and those provided in MTS Allstream(CRTC)15Sep10-103, with supporting rationale.

2. At paragraph 17 of its cost study report updated 11 March 2011, MTS Allstream indicated that the Phase II capital costs have been adjusted to reflect capital and expense increase factors and productivity improvements in each year of the study starting in 2011 and ending in 2015. MTS Allstream also provided, in table 6.5.2, the capital increase factors used for each account code.

a. Identify which account code applies to the DSLAM All Equipment component of VDSL access service.  Further identify the changes in capacity and cost per access for DSLAM All Equipment over the last five years; further comment on the appropriateness of using the corporate average CIF proposed for DSLAM All Equipment over the study period.

b. Identify which account code applies to the cabinet component of VDSL access service.  Further identify the changes in capacity and cost per access for cabinet equipment over the last five years; further comment on the appropriateness of using the corporate average CIFs proposed for cabinet equipment over the study period.

c. Identify which account code applies to the Internet computers hardware component for the V-AHSSPI services.  Further identify the changes in capacity and cost per access for Internet computers hardware over the last five years; further comment on the appropriateness of using the corporate average CIF proposed for Internet computers hardware over the study period.

3. In its revised economic study filed 11 March 2011, MTS Allstream used a 5 year study period for the costs causal to demand and a 10 year study period for its costs causal to service.

a. For each of VDSL access service and the three V-AHSSPI services, provide a revised proposed cost study which reflects a study period of 10 years.  The response should include revised proposed tables 6.4.5-1 to 6.4.5-9 as provided in Appendix 1 of Attachment 1 of the cost study report, and revised proposed tables of MTS Allstream(CRTC)15Sep10-103 and 105.  The response should also identify, with supporting rationale, any change in methodology or assumptions. Further comment on the appropriateness of the use of a 10 year study period.

b. Using the format of tables 6.4.5-1 to 6.4.5-9 of the cost study, and tables of the responses to MTS Allstream(CRTC)15Sep10-103 and 105, for the VDSL access service, provide revised 10 year cost study information and proposed revised rates per end-user for each of the following changes in assumptions:

i. For each year of the study period, apply a CIF of -2% for all equipments and facilities.

ii. For each year of the study period, apply a CIF of -5% for all equipments and facilities.

c. Using the format of tables 6.4.5-1 to 6.4.5-9 of the cost study, and tables of the responses to MTS Allstream(CRTC)15Sep10-103 and 105, for the three V-AHSSPI services, provide revised 10 year cost study information and proposed revised rates per end-user for each of the following changes in assumptions:

i. For each year of the study period, apply a CIF of -10% for all equipments and facilities.

ii. For each year of the study period, apply a CIF of -15% for all equipments and facilities.

The response should include revised proposed tables 6.4.5-1 to 6.4.5-9 as provided in Appendix 1 of Attachment 1 of the cost study report of the cost study, and revised proposed tables of MTS Allstream(CRTC)15Sep10-103 and 105.

d. Comment on the extent to which equipment capacity for traffic driven cost components are increased over time to satisfy higher traffic demand without significantly increasing the overall provisioning costs per end-user and thereby causing significant decreases in unit cost per peak hour Kbps for this category of costs.

4. Refer to the company’s responses to MTS Allstream(CRTC)4Feb11-106 Revised, where the company has provided IFC per 100 Mbps V-AHSSPI service associated with various components of the dedicated 1 GB port on 7450 to Competitors equipment.

a. Provide a diagram showing how the following four components are connected: (i) 7450 ESS 12 SLOT DC 400G BUNDLE, (ii) 7450 ESS SFM 2 400G, (iii) IOM – 7450 ESS-6/7/12 IOM-20G, and (iv) 7450 ESS 10-port GigE MDA-B – no opt.  Further provide a brief description of the purpose and function of each of the above components.

b. Confirm that a 1 GB dedicated interface is required to provide a 100 Mbps V-AHSSPI service and that this would result in under utilization of the 1 GB dedicated interface. If so, explain why.

c. Provide the company’s view, with rationale, on providing two distinct tariff components for the V-AHHSPI interface consisting of (i) resources related to dedicated port and (ii) resources related to the shared ports.

5. Refer to the company’s responses to MTS Allstream(CRTC)15Sep10-106 and MTS Allstream(CRTC)4Feb11-111.

a. With regard to the description of the activities provided by the company in part b) of MTS Allstream(CRTC)4Feb11-111, explain why an “Outward: IPMP - Order fulfillment” activity requires activities such as creating the VLAN, configuring the VLAN and testing the operation.

b. With regard to the “Outward: Facilities Management – Issue Order” activity provided by the company, explain with supporting rationale why this activity is a one-time activity specific to each outward movement of VDSL Access service.  If this activity is not specific to each VDSL Access outward movement, provide supporting rationale as to why the cost associated with this activity is viewed to be incremental to the outward movement of the service.

6. Refer to the company’s responses to MTS Allstream(CRTC)15Sep10-106 where the company provided the frequencies and Unit Costs for various ‘Recurring’ activities associated with trouble reports.  Also refer to part d) of MTS Allstream(CRTC)4Feb11-111 VDAS where the company provided the percentage of trouble tickets based on the company’s retail VDSL Data Access service.

a. Confirm that the “Expenses causal to demand – Service Provisioning” expenses shown in Table 6.4.5-1 of the company’s revised Economic Evaluation study report was derived based on the “Outward” and “Recurring” cost elements identified in MTS Allstream(CRTC)15Sep10-106.

b. Provide the calculations showing how the company derived the PWAC for  VDSL Access - “Expenses causal to demand – Service Provisioning” as shown in Table 6.4.5-1 of the company’s revised Economic Evaluation study report, using the wholesale in-service demand data for the VDSL Data Access service as well as the percentage of trouble tickets based on the company’s retail VDSL Data Access service as provided in part d) of MTS Allstream(CRTC)4Feb11-111.  

7. Refer to the company’s responses to MTS Allstream(CRTC)15Sep10-106, where the company has provided the time estimates and unit costs for various V-AHSSPI Inward, Outward and Recurring activities.

a. For each of the company’s 100 Mb, 400 Mb and 1 Gb V-AHSSPI interfaces, provide the Inward and Outward demand for the years 2011 to 2020

b. Explain why the time estimates provided for the various Inward and Outward activities (e.g., IP Traffic – Configuration / De-configuration, Facilities Management – Issue Order, and IPMP – Order Fulfillment) associated with the V-AHSSPI service are the same, given that, unlike Inward movement, the interface and connections for Outward movement already exist.

c. Explain, with supporting rationale, how the time estimates for the Inward and Outward sub-activities were derived.

8. Refer to the company’s response to MTS Allstream(CRTC)15Sep10-105, where the company provided “Vendor  Support PWAC” associated with the maintenance expense causal to demand for the VDSL access as well as the interface services.

Provide the calculations used to estimate the annual maintenance Vendor Support cashflows used to derive the PWAC for the 1000 Mbps V-AHSSPI interface service provided in this interrogatory response.  The response should show the values and sources of the unit cost and demand information used as well as all assumptions, with supporting rationale.

9. Refer to the response to MTS Allstream(CRTC)4Feb11-205, Attachment 1, where MTS Allstream provided, by major activity, LUCs and time estimates for V-AHSSPI and AHSPPI as well as VDSL and ADSL access service charges. Explain, with supporting rationale, the changes in time estimates between (i) V-AHSSPI and AHSPPI and (ii) VDSL and ADSL access service charges. Further explain whether there are changes other than those related to changes in LUCs and time estimates that have contributed to the changes in service charge costs; if so, identify each of these changes, with supporting rationale.

10.Refer to the response to MTS Allstream(CRTC)4Feb11-202.

a. For V-AHSSPI service charge, provide a description for each of the following major activities: broadband coordinator-order coordination; IP traffic-design network order; Facilities management-design and issue orders; IPMP(TECNET)-configure the network; and CO Tech

b. For VDSL service charge, provide a description for each of the following major activities:  IPMP(TECNET)-configures subscriber to network; Facilities management-design and issue orders; Assignment-records management; Workforce controller- dispatch FSTs; Co expediter-dispatch for CO techs; CO Tech; FST-Wire cabinet, Cut endtap, test; FST replace drop; and FST-Install NID.

11. Refer to the response to MTS Allstream(CRTC)04Feb-204. Provide the Occurrence rates for each sub-activity for each of National Account representative-Customer's point of contact activity and the CSG Systems Engineering- Tech Sales support activity, with supporting rationale.

12. Refer to SaskTel(CRTC)4Feb11-201

a. Comment with supporting rationale on SaskTel’s proposal to remove service establishment activity costs that are common to both the VDSL  Access service and the Dry Loop or Unbundled Loop service such as costs for Service Call Taking, Service Call Problem Resolution and Assignment from its VDSL Service connection costs when provisioned with either a Dry Loop or Unbundled Loop in order to avoid double recovery of these costs. Further, identify MTS Allstream’s activities that are common to both the provision of VDSL Access service and Dry Loops or Unbundled Loops.

b. Explain, with supporting rationale, if and why MTS Allstream’s activities identified in response to  a) above  cannot be performed at the same time if both VDSL Access service and Dry Loop or Unbundled Loop services are required at the time of the ISP request; further comment on the expected cost efficiencies and reductions if the service establishment activities for both VDSL Access service and Dry Loops or Unbundled Loops are provisioned at the same time, identifying the activities which would be subject to cost efficiencies.

Aggregated ADSL tariffs: matching speeds - Interrogatories to SaskTel

1. In its response to SaskTel(CRTC)4Feb11-107, SaskTel stated that it assumed that a firmware upgrade is required on an annual basis and requires a 1 hour customer premises visit.

a. Explain, with supporting rationale, whether Sasktel plans to also do annual visits to its retail customer premises to perform a firmware upgrade on an annual basis.

b. Explain, with supporting rationale, whether the firmware upgrades could eventually be done on a remote basis or required on a less frequent basis as the product matures.

c. Explain, with supporting rationale, what would happen if the firmware upgrades were done on an as required basis and provide an estimate of the revised cost per access for this activity under this approach.

2. With reference to SaskTel(CRTC)15Sep10-103, confirm that there is no double counting of capital expenditures for the following IP Core items:

a. Page 2 of 5: IP Core costs (Transport) described as “This equipment includes traffic driven costs connecting redundant trunks between SaskTel IP Core Edge Router and SaskTel IP Core Router”.

b. Page 3 of 5: IP Core costs described as “This equipment is used to connect and aggregate DSLAM traffic and includes costs for connecting redundant trunks to SaskTel IP Core Edge Routers”.

If not, explain why not.

3. With reference to SaskTel(CRTC)15Sep10-103 and Attachment to SaskTel(CRTC)4Feb11-103 interrogatory response, explain the discrepancy in the DSLAM port costs per access between the two responses.

4. With reference to SaskTel(CRTC)15Sep10-103, for each of the Installed First Costs (IFCs) associated with IP Core equipment, provide a detailed breakdown of the IFC per access into the following components:

a. Material cost (specify equipment)
b. Engineering
c. Installation
d. Other (specify)

The answer should identify the WFF and the capacity of each equipment.

5. Refer to the response to SaskTel(CRTC)4Feb11-204 h). Provide the requested estimate of the percentage of existing loops with bridge taps or load coils, identifying the source and vintage of the data.

6. Refer to the response to SaskTel(CRTC)4Feb11-204 i) where SaskTel indicated that certain inside wiring work occurs 100% of the time and other inside wiring work occurs 50% of the time. Provide the list of inside wiring work activities that occur 100% of the time and the time estimate for each of these activities.

Aggregated ADSL tariffs: matching speeds - Interrogatories to Telus

1. In response to Telus(CRTC)4Feb11-105, Telus provided the IFCs for ATM PVC and Gigabit Ethernet per Mbps that were used to calculate its transport costs. For each of the first and last year of the study, provide the assumed proportions of ATM PVC and Gigabit Ethernet used to calculate the final costs for transport, with supporting rationale.

2. In response to Telus(CRTC)4Feb11-116, Telus indicated that it does not include usage-based billing in its tariff. Confirm that there are costs which are driven by traffic demand (e.g. ATM PVC) regardless of whether the company offers usage-based billing. Provide the cost per GB of usage per month for those costs that are driven by traffic demand only. 

3. In response to Telus(CRTC)4Feb11-115, Telus provided revised proposed cost studies for a 5 and 10 year study period for the Alberta and British Columbia territories. For Telus’ operating territory of Quebec, provide revised proposed cost studies (tables 1, 2, 3 and 5) for all of Telus’ proposed matching speed services reflecting a study period of 5 years. If Telus is unable to provide the requested information in the requested timeframe, comment on the use of the 5 year cost study sensitivity information of Alberta and British Columbia as a proxy.

4. With reference to service provisioning expenses, in response to Telus(CRTC)4Feb11-108, Telus stated that the source data for the service provisioning  unit cost is the ABC by product study which is created by assigning costs from the SAP system to products and processes. Explain whether the cost driver used to develop the estimate of service provisioning expenses was inward demand. If not, provide revised cost estimates for provisioning expenses based on inward demand, including all supporting cost assumptions.

5. With reference to Telus(CRTC)15Oct10-103, for each of BRAS/Aggregation and ATM PVC (Gigabit Ethernet) unit costs, provide a detailed breakdown into the following components:

a. Material cost (specify equipment)
b. Engineering
c. Installation
d. Other (specify)

The answer should identify the WFF and the capacity of each equipment.

6. On 15/16 March 2011,Telus provided a revised cost study (with a 3 year study period). Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of Attachments 1 to TELUS(CRTC)15Oct10-103 and TELUS(CRTC)4Feb11-101A,  provide revised 3 year cost study information and proposed revised rates per end-user for each of the following changes in assumptions:

For each of the years 2006 to 2011, apply a retrospective CIF of -10% to the ATM PVC/Gigabit Ethernet equipment. For each of the years 2009 to 2011, apply a retrospective CIF of -10% to the BRAS aggregation equipment and a retrospective CIF of -2% to the DSLAM equipment.

7. In response to TELUS(CRTC)04Feb11-115, Telus provided a revised study with a 10 year study period. Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of Attachments 1 to TELUS(CRTC)15Oct10-103 and TELUS(CRTC)4Feb11-101A,  provide revised 10 year cost study information and proposed revised rates per end-user for each of the following changes in assumptions:

a. For each year of the study period, a CIF of -2% for access driven cost components (e.g. DSLAM) and -10% for traffic driven cost components (e.g. ATM PVC/Gigabit Ethernet, BRAS aggregation).

b. For each year of the study period, a CIF of -4% for access driven cost components (e.g. DSLAM) and -15% for traffic driven cost components (e.g. ATM PVC/Gigabit Ethernet, BRAS aggregation).

c. Comment on the extent to which equipment capacity for traffic driven cost components are increased over time to satisfy higher traffic demand without significantly increasing the overall provisioning costs per end-user and thereby causing significant decreases in unit cost per peak hour Kbps for this category of costs.

8. Refer to Telus(CRTC)4Feb11-201 c) where Telus indicated that for the Product Management expense category, activities are incurred when additional service orders are initiated to ensure the orders are being processed properly, error-free and without delay.  Explain why Product Management costs are viewed to be volume sensitive in light of Telus’ classification of these costs as Non-Volume sensitive on page 5 of Attachment 1 to Telus(CNOC)4Feb11-06. Further comment on the appropriateness of including these costs in the monthly recurring cost studies.

9. Refer to Telus’ response to Telus(CRTC)4Feb11-201 where Telus indicated that costs associated with “assign”, “install”, “activate” and “ensure delivery” are included in the WIAS monthly rate costs.

a. Confirm that the costs for “assign”, “install”, “activate” and “ensure delivery” activities, as well as other order processing activities, are also recovered by either the Dry Loop or Unbundled Loop service order charge. If so, comment on the appropriate adjustments to the Dry Loop or Unbundled Loop service order charge that would be required to avoid double recovery of the costs for these activities.

b. Explain, with supporting rationale, if and why the above-noted activities cannot be performed at the same time if both WIAS and Dry Loop or Unbundled Loop services are required at the time of the ISP request.

c. Comment with supporting rationale on SaskTel’s proposal in its response to SaskTel(CRTC)4Feb11-201 to remove service establishment activity costs that are common to both the VDSL Service and the Dry Loop or Unbundled Loop service such as costs for Service Call Taking, Service Call Problem Resolution and Assignment from its VDSL Service connection costs when provisioned with either a Dry Loop or Unbundled Loop in order to avoid double recovery of these costs. Further, identify TELUS’ activities that are common to both the provision of WIAS and Dry Loop or Unbundled Loops.

10. Refer to Telus(CRTC)4Feb11-204 b) where Telus indicated that the timing estimates are based on its experience with the activities and that the timing estimates are the same for wholesale and retail service.

d. For each of the “Order Entry”, “Update” and “Correction” activities, explain, with supporting rationale, why the timing estimates are the same for wholesale and retail service in light of the fact that retail services require additional task to be performed (e.g. need to create / update / correct a “Yellow Pages” listing for retail business customers, add / update / correct other services being ordered at the same time by the retail customers, time spent by service representatives in selling other services to the retail customers while taking the order).

e. For each of “Order Entry”, “Update” and “Correction” activities, further provide revised time estimates in light of the response to part a) above, with supporting rationale.

11. Refer to Telus(CRTC)4Feb11-204 e). Explain with supporting rationale why the Loop Qualification activity would be required for the 1.5 Mbps to 6 Mbps WIAS service. If the Loop Qualification activity would not be required, comment on the use of a different service charge rate for this service, based on the different service charge costs.

12. Refer to Telus(CRTC)4Feb11-206 where Telus indicated that the proposed tariff for Wholesale Internet ADSL service does not include a monthly payment option for the 15 Mbps and 25 Mbps services.  Further refer to Telus’ proposed Tariff page 226-7A, note 2 b) indicates that service providers can elect to pay an amount of $3.00 per month; further, in its proposed Tariff page 226-7, note 2 (i.e. monthly payment option) indicates that this amount is applicable to the 15 Mbps and 25 Mbps services. Explain the discrepancy.

[1] The new Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure) came into force on 1 April 2011; section 33 of the new Rules of Procedure replaces section 19 of the old CRTC Telecommunications Rules of Procedure.

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