ARCHIVED - Transcript
This page has been archived on the Web
Information identified as archived is provided for reference, research or recordkeeping purposes. It is not subject to the Government of Canada Web Standards and has not been altered or updated since it was archived. Please contact us to request a format other than those available.
Providing Content in Canada's Official Languages
Please note that the Official Languages Act requires that government publications be available in both official languages.
In order to meet some of the requirements under this Act, the Commission's transcripts will therefore be bilingual as to their covers, the listing of CRTC members and staff attending the hearings, and the table of contents.
However, the aforementioned publication is the recorded verbatim transcript and, as such, is transcribed in either of the official languages, depending on the language spoken by the participant at the hearing.
TRANSCRIPT OF PROCEEDINGS BEFORE
THE CANADIAN RADIO‑TELEVISION AND
TELECOMMUNICATIONS COMMISSION
TRANSCRIPTION DES AUDIENCES DEVANT
LE CONSEIL DE LA RADIODIFFUSION
ET DES TÉLÉCOMMUNICATIONS CANADIENNES
SUBJECT:
Review of regulatory framework for Northwestel Inc. /
Examen du cadre de réglementation
applicable à Norouestel Inc.
HELD AT: TENUE À:
Convention Centre Centre des congrès
High Country Inn High Country Inn
4051 4th Avenue 4051, 4e rue
Whitehorse, Yukon Whitehorse (Yukon)
July 11, 2006 Le 11 juillet 2006
Transcripts
In order to meet the requirements of the Official Languages
Act, transcripts of proceedings before the Commission will be
bilingual as to their covers, the listing of the CRTC members
and staff attending the public hearings, and the Table of
Contents.
However, the aforementioned publication is the recorded
verbatim transcript and, as such, is taped and transcribed in
either of the official languages, depending on the language
spoken by the participant at the public hearing.
Transcription
Afin de rencontrer les exigences de la Loi sur les langues
officielles, les procès‑verbaux pour le Conseil seront
bilingues en ce qui a trait à la page couverture, la liste des
membres et du personnel du CRTC participant à l'audience
publique ainsi que la table des matières.
Toutefois, la publication susmentionnée est un compte rendu
textuel des délibérations et, en tant que tel, est enregistrée
et transcrite dans l'une ou l'autre des deux langues
officielles, compte tenu de la langue utilisée par le
participant à l'audience publique.
Canadian Radio‑television and
Telecommunications Commission
Conseil de la radiodiffusion et des
télécommunications canadiennes
Transcript / Transcription
Review of regulatory framework for Northwestel Inc. /
Examen du cadre de réglementation
applicable à Norouestel Inc.
BEFORE / DEVANT:
Richard French Chairperson / Président
Helen del Val Commissioner / Conseillère
Barbara Cram Commissioner / Conseillère
Andrée Noël Commissioner / Conseillère
Ronald Williams Commissioner / Conseiller
ALSO PRESENT / AUSSI PRÉSENTS:
Madeleine Bisson Secretary / Secrétaire
Peter McCallum/ Legal Counsel /
Leanne Bennett Conseillers juridiques
HELD AT: TENUE À:
Convention Centre Centre des congrès
High Country Inn High Country Inn
4051 4th Avenue 4051, 4e rue
Whitehorse, Yukon Whitehorse (Yukon)
July 11, 2006 Le 11 juillet 2006
TABLE DES MATIÈRES / TABLE OF CONTENTS
PAGE / PARA
PREVIOUSLY AFFIRMED: SCOTT ROBERTS 284 / 2007
AFFIRMED: RAY HAMELIN
PREVIOUSLY AFFIRMED: MURIEL CHALIFOUX
AFFIRMED: JODY WOODLAND
Examination by Northwestel 284 / 2009
Examination by Consumers Groups 285 / 2021
Examination by UCG 345 / 2472
Examination by Government of Yukon 413 / 2962
Examination by the Commission 480 / 3443
EXHIBITS / PIÈCES JUSTICATIVES
PAGE / PARA
TELUS-2 Globe and Mail article - 277 / 1956
identified as No. 8
TELUS-3 Yukon Statistical Review 2004 278 / 1957
Annual Report - identified as
No. 20
TELUS-4 2006 NWT Socio-Economic Scan - 278 / 1958
identified as No. 21
CRTC-1 Document entitled "Questions 280 / 1976
from CRTC Staff re Costing"
CRTC-2 Document entitled "Questions 280 / 1976
from CRTC Staff re Depreciation"
PIAC-3 Northwestel Actual/Forecast 287 / 2041
Operating Revenues and NCF Funding
for 2002-2007
PIAC-4 Estimate of Northwestel fixed and 298 / 2126
common costs recovered through 25%
mark-up
PIAC-5 Fixed structures - Based on 301 / 2154
NWTel(CRTC) 10APR06-1601 -
Attachment 2
TELUS-5 Document entitled "Proposed Switch 476 / 3419
Connect Rate"
NWTEL-3 Operating Expenses 2001-2005 479 / 3440
(Requested by UCG)
ERRATA
Monday, July 10, 2006 / le 10 juillet 2006
Volume 1
Throughout transcript:
"Krauss" s/b "Kraus"
"NorthwesTel" s/b "Northwestel"
Page Line/ligne
22 16 "Raychuck" s/b "rate shock"
24 23 "Northwestel" s/b "Northwest"
30 24 "Articom" s/b "Ardicom"
113 4 "Going‑in, period" s/b "going‑in period"
114 24 "MS CHALIFOUX:" s/b deleted
128 22 "MR. WALKER:" s/b "MR. ROBERTS: "
143 16 "MR. RONDEAU:" s/b "THE CHAIRPERSON: "
164 16 "MS CHALIFOUX:" s/b "MS KRAUS: "
165 1 "MS CHALIFOUX:" s/b "MS KRAUS: "
182 16 "$0.37" s/b "$0.0037"
183 25 "brand NSI" s/b "BRAND and NSI"
184 3 "brand" s/b "BRAND"
188 19 "MR. CHALIFOUX:" s/b "MR. WALKER: "
189 5 "MS KRAUSS:" s/b "MS CHALIFOUX: "
189 19 "MS KRAUSS:" s/b "MS CHALIFOUX: "
191 3 "MS KRAUSS:" s/b "MS CHALIFOUX: "
192 10 "programs" s/b "forbearance"
210 23 "Dakuakada" s/b "Dakwakada"
211 5 "Self‑service" s/b "Cell service"
215 22 "Sabie" s/b "Sabia"
223 7 "MR. WALKER:" s/b "MR. RYAN: "
223 16 "MR. RYAN: " s/b "MR. WALKER: "
223 17 "MR. WALKER:" s/b "MR. RYAN: "
224 24 "MR. WALKER:" s/b "MR. RYAN: "
225 21 "MR. WALKER:" s/b "MR. RYAN: "
225 24 "MR. RYAN: " s/b "MR. WALKER: "
226 6 "MR. WALKER:" s/b "MR. RYAN: "
241 14 "the average" s/b "de‑averaged"
245 10 "appointed" s/b "a point of"
263 2 "that is charged" s/b deleted
266 10 "MR. WALKER:" s/b "MR. ROBERTS: "
269 3 "self‑service" s/b "cell service"
269 4 "self‑service" s/b "cell service"
269 6 "self‑service" s/b "cell service"
ADDENDA
Page Line/ligne
132 4 "wireline NAS rates" s/b
"wireline NAS penetration rates"
132 10 "that is just one service" s/b
"that this just one service"
229 4 "draw net fund" s/b
"draw on the National Contribution Fund"
Whitehorse, Yukon / Whitehorse (Yukon)
‑‑‑ Upon resuming on Tuesday, July 11, 2006
at 0900 / L'audience reprend le mardi
11 juillet septembre 2006 à 0900
LISTNUM 1 \l 1 \s 19501950 THE CHAIRPERSON: Order, please. A l'ordre, s'il vous plaît.
LISTNUM 1 \l 11951 Ladies and gentlemen, this morning I'm informed that vital questions of a preliminary nature have to be discussed by a wide diversity of parties, including Telus, Northwestel and the CRTC.
LISTNUM 1 \l 11952 Madame la secrétaire...?
LISTNUM 1 \l 11953 THE SECRETARY: Yes. It is regarding the exhibits.
LISTNUM 1 \l 11954 For the record, the opening statements for each participant were numbered as Exhibit No. 1 for that party.
LISTNUM 1 \l 11955 Also, Telus exhibits as at the cross‑examination period were numbered as follows:
LISTNUM 1 \l 11956 Document No. 8, identified No. 8 by Telus, is an ad in the Globe and Mail article. It is numbered Exhibit No. 2.
EXHIBIT TELUS-2: Globe & Mail article, identified as No. 8
LISTNUM 1 \l 11957 THE SECRETARY: Exhibit No. 3 will be the document referred as Document No. 20, Yukon Statistical Review 2004 Annual Report.
EXHIBIT TELUS-3: Yukon Statistical Review 2004 Annual Report - Identified as No. 20
LISTNUM 1 \l 11958 THE SECRETARY: Exhibit No. 4, document referred as Document No. 21, 2006 NWT Socioeconomic Scan.
EXHIBIT TELUS-4: 2006 NWT Socio-Economic Scan - identified as No. 21
LISTNUM 1 \l 11959 THE SECRETARY: That's it.
LISTNUM 1 \l 11960 THE CHAIRPERSON: That's it. Very exciting.
LISTNUM 1 \l 11961 Northwestel, I understand you have something preliminary?
LISTNUM 1 \l 11962 MR. ROGERS: Just a very minor point, Mr. Chairman.
LISTNUM 1 \l 11963 I have indicated to the Commission counsel that we have gone through the transcript from yesterday and relatively minor and uncontentious errors appear, as is quite common in the transcript. What we propose to do is consolidate all of that and provide the Commission, the court reporters and all parties in the room a hard copy or a soft copy of those changes and they can review them. We will do that later today.
LISTNUM 1 \l 11964 THE CHAIRPERSON: Thank you, Mr. Rogers.
LISTNUM 1 \l 11965 Telus...?
LISTNUM 1 \l 11966 UNIDENTIFIED SPEAKER: No thank you, Mr. Chairman.
LISTNUM 1 \l 11967 THE CHAIRPERSON: No preliminaries from Telus?
LISTNUM 1 \l 11968 Thank you.
LISTNUM 1 \l 11969 Mr. McCallum...?
LISTNUM 1 \l 11970 MR. McCALLUM: Yes, thank you, Mr. Chair.
LISTNUM 1 \l 11971 Yesterday we passed informally to Northwestel two proposed CRTC exhibits. The Secretary now has a number of copies of these proposed exhibits which she will make available and distribute.
LISTNUM 1 \l 11972 We have attempted to determine if Northwestel can respond to the proposed staff interrogatories.
LISTNUM 1 \l 11973 There are two sets. One is entitled "Questions From CRTC Staff Re Costing" and the second is called "Questions From CRTC Staff Re Depreciation".
LISTNUM 1 \l 11974 I am informed that Northwestel is able to respond to all of the questions in the two documents, one the costing document and the second one the depreciation document, by the 21st of July 2006, with one exception. That is Question No. 7 on the costing document, but which time they have undertaken to get back by the 28th of July, which is the following Friday.
LISTNUM 1 \l 11975 So if acceptable to all, I would propose that these be introduced as exhibits in the record. I might propose that the costing document be Exhibit No. 1 and the depreciation document be Exhibit No. 2.
LISTNUM 1 \l 11976 Thank you, Mr. Chairman.
EXHIBIT CRTC-1: Document entitled "Questions from CRTC Staff re Costing"
EXHIBIT CRTC‑2: Document entitled "Questions from CRTC Staff re Depreciation"
LISTNUM 1 \l 11977 MR. RYAN: Mr. Chairman, I would like to speak to that issue, if I may.
LISTNUM 1 \l 11978 THE CHAIRPERSON: Yes, Mr. Ryan.
LISTNUM 1 \l 11979 MR. RYAN: If my recollection is correct ‑‑ and I'm sorry, I don't have the document in front of me to verify it ‑‑ I think final argument is due on the 21st of July.
LISTNUM 1 \l 11980 I am anticipating that the questions to be raised by the Commission are of some importance or they wouldn't raising them at all. It would be, I think, appropriate if we had a chance to look at those responses before we were asked to file final argument.
LISTNUM 1 \l 11981 THE CHAIRPERSON: Mr. McCallum?
LISTNUM 1 \l 11982 MR. McCALLUM: Would you have any idea how long you might need ‑‑ it being recognized, of course, that some of the answers might be provided in confidence. So what you may see is an abridged version of some of them.
LISTNUM 1 \l 11983 I would also note that some of them refer to documents where confidentiality has been claimed already by various parties.
LISTNUM 1 \l 11984 Could you give an estimate of what you might require and perhaps after that Mr. Rogers could give his comments.
LISTNUM 1 \l 11985 MR. RYAN: I wouldn't be looking for anything other than an opportunity to have some idea of what the questions and answers are. I appreciate at this stage many of the questions posed might lead to answers that are confidential.
LISTNUM 1 \l 11986 Of course, that in itself raises the issue of whether confidentiality is appropriately claimed.
LISTNUM 1 \l 11987 I would have thought that something in the order of 72 hours would be perfectly adequate for us to review and either raise any issues we have about confidentiality with the Commission, in which case some ad hoc solution might be found, or we could incorporate, as we see fit, the information that has been provided into our final argument, or to at least take it into account before filing our final argument.
LISTNUM 1 \l 11988 It is possible Mr. Rogers might be able to accelerate the delivery of these answers by 72 hours in order to permit us to stick with the original schedule for final argument.
LISTNUM 1 \l 11989 MR. ROGERS: Mr. Chairman, one thing that might affect this is that Mr. Ryan hasn't actually seen the interrogatories yet.
LISTNUM 1 \l 11990 THE CHAIRPERSON: Indeed. And I'm not sure. Has he seen them now? No.
LISTNUM 1 \l 11991 MR. ROGERS: So he is hardly in a position to know how much it might affect his argument.
LISTNUM 1 \l 11992 THE CHAIRPERSON: Exactly.
LISTNUM 1 \l 11993 MR. ROGERS: And further to Mr. McCallum's comment, certainly from what I have seen, many of the interrogatories posed relate to matters which have already been examined on previously in prior rounds by the Commissions, and responses to certain of those interrogatories were filed in confidence and that confidentiality was not challenged.
LISTNUM 1 \l 11994 So perhaps Mr. Ryan may be given an opportunity to review the interrogatories and we might revisit the issue of timing at lunch time.
LISTNUM 1 \l 11995 THE CHAIRPERSON: I agree.
LISTNUM 1 \l 11996 Is that satisfactory, Mr. Ryan?
LISTNUM 1 \l 11997 MR. RYAN: Perfectly satisfactory, Mr. Chairman.
LISTNUM 1 \l 11998 THE CHAIRPERSON: I don't think there are any other preliminary matters.
LISTNUM 1 \l 11999 Madame la Secrétaire. En anglais bien sûr.
LISTNUM 1 \l 12000 THE SECRETARY: Thank you, Mr. Chairman.
LISTNUM 1 \l 12001 We would like to invite now the Finance Panel from Northwestel.
‑‑‑ Pause
LISTNUM 1 \l 12002 MR. ROGERS: Mr. Chairman, I will briefly introduce the panel before they are sworn. Then they can be sworn and we will do the direct.
LISTNUM 1 \l 12003 This is the Finance Panel of Northwestel. The Chair of this panel is Mr. Ray Hamelin, CFO of the Company.
LISTNUM 1 \l 12004 With him is Muriel Chalifoux, who was on the prior panel, AVP Carrier and Regulatory; Mr. Scott Roberts, Director of Regulatory Framework; and Jody Woodland, Senior Business Analyst.
LISTNUM 1 \l 12005 Providing back‑up to the panel in the row behind them is Sheldon Schmidt, Senior Financial Analyst; Norm Eady, Manager of Fixed Assets; and Kate Warner, Business Analyst.
LISTNUM 1 \l 12006 The panel is ready to be affirmed.
LISTNUM 1 \l 12007 THE SECRETARY: Thank you.
PREVIOUSLY AFFIRMED: SCOTT ROBERTS
AFFIRMED: RAY HAMELIN
PREVIOUSLY AFFIRMED: MURIEL CHALIFOUX
AFFIRMED: JODY WOODLAND
LISTNUM 1 \l 12008 THE SECRETARY: Thank you very much.
EXAMINATION / INTERROGATOIRE
LISTNUM 1 \l 12009 MR. ROGERS: Mr. Hamelin, was the finance evidence and associated interrogatories therewith prepared by you or under your direction?
LISTNUM 1 \l 12010 MR. HAMELIN: It was, yes.
LISTNUM 1 \l 12011 MR. ROGERS: Do you have any corrections or additions to make to that evidence at this time?
LISTNUM 1 \l 12012 MR. HAMELIN: No, I do not.
LISTNUM 1 \l 12013 MR. ROGERS: To your information and belief, is that evidence accurate and true?
LISTNUM 1 \l 12014 MR. HAMELIN: Yes, it is.
LISTNUM 1 \l 12015 MR. ROGERS: Thank you.
LISTNUM 1 \l 12016 The panel is available.
LISTNUM 1 \l 12017 THE CHAIRPERSON: Thank you, Mr. Rogers.
LISTNUM 1 \l 12018 Madam Secretary.
LISTNUM 1 \l 12019 THE SECRETARY: Thank you, Mr. Chairman.
LISTNUM 1 \l 12020 The first party for cross‑examination is the Consumer Groups.
EXAMINATION / INTERROGATOIRE
LISTNUM 1 \l 12021 MS LOTT: Good morning, Mr. Chairman, members of the panel, and good morning to you.
LISTNUM 1 \l 12022 My name is Sue Lott. I am legal counsel for the Consumer Groups, and that represents today the Consumers' Association of Canada and the National Anti‑Poverty Organization.
LISTNUM 1 \l 12023 To my right is Andrew Briggs, who is a consultant and is working with us, as well, and who will help me through this again today.
LISTNUM 1 \l 12024 I wonder if you could tell me what rate of return Northwestel is proposing to use to establish your going‑in rates.
LISTNUM 1 \l 12025 MR. HAMELIN: It will be 10.5 percent.
LISTNUM 1 \l 12026 MS LOTT: What is the basis for the use of 10.5 percent in setting the going‑in rates?
LISTNUM 1 \l 12027 MR. HAMELIN: We thought it would be appropriate to view this proposal as a package and to continue on with the unique regulatory framework that we have currently to assess, for going‑in rates, what the ROR should be, and 10.5 percent was deemed appropriate by management.
LISTNUM 1 \l 12028 MS LOTT: Could you undertake to provide the current yield on Government of Canada long‑term bonds?
LISTNUM 1 \l 12029 MR. HAMELIN: Yes, we could. Could you give me a moment, please?
‑‑‑ Pause
LISTNUM 1 \l 12030 MR. HAMELIN: I believe it is 5.25 percent.
LISTNUM 1 \l 12031 MS LOTT: My understanding is that that was the forecast long‑term bond rate provided by your expert. What I am looking for in my question is the current yield on Government of Canada bonds.
LISTNUM 1 \l 12032 MR. HAMELIN: Do you have an idea of the maturity you are looking for ‑‑ 10 years, 20 years?
LISTNUM 1 \l 12033 MS LOTT: Thirty years.
‑‑‑ Pause
LISTNUM 1 \l 12034 MS LOTT: If you would like to take that on as an undertaking, that would be fine.
LISTNUM 1 \l 12035 MR. HAMELIN: It changes every day. We would have to go and check.
LISTNUM 1 \l 12036 MS LOTT: So you will undertake to find that for me, the current yield on Government of Canada long‑term bonds for 30 years?
LISTNUM 1 \l 12037 MR. HAMELIN: Absolutely, we will find that for you.
LISTNUM 1 \l 12038 MS LOTT: Thank you.
LISTNUM 1 \l 12039 I would like to move now to some questions related to the National Contribution Fund. For that, we have prepared an exhibit, and that exhibit is entitled, "Table 2: Northwestel Actual/Forecast Operating Revenues and NCF Funding for 2002‑2007."
LISTNUM 1 \l 12040 I think that has been provided.
LISTNUM 1 \l 12041 THE SECRETARY: That is Exhibit No. 3.
EXHIBIT PIAC‑3: Northwestel Actual/Forecast Operating Revenues and NCF Funding for 2002‑2007
LISTNUM 1 \l 12042 MS LOTT: Exhibit No. 3. Thank you.
LISTNUM 1 \l 12043 Do you have that in front of you?
LISTNUM 1 \l 12044 MR. HAMELIN: No, I don't.
LISTNUM 1 \l 12045 MS LOTT: It was provided to your counsel.
LISTNUM 1 \l 12046 MR. HAMELIN: Is it entitled Northwestel Actual Forecast Operating Revenues?
LISTNUM 1 \l 12047 MS LOTT: And NCF funding for...
LISTNUM 1 \l 12048 MR. HAMELIN: Right. I have it now, thanks.
LISTNUM 1 \l 12049 MS LOTT: You have that now. Thank you. Okay.
LISTNUM 1 \l 12050 This is an exhibit that is similar to the table 1 that we used yesterday in front of the marketing panel where we were looking at the revenue forecast, but we have now summarized some of these lines and added on funding from the national contribution fund, as you can see from the table, those are lines 20 down.
LISTNUM 1 \l 12051 MR. HAMELIN: Yes, I see that.
LISTNUM 1 \l 12052 MS LOTT: You see that. Okay.
LISTNUM 1 \l 12053 So if we look at lines 22 to 23, these are showing proposed funding, if we go over to column J, proposed funding in 2007 from the national contribution fund, and line 21, as you can see, provides the level of funding, that's entitled supplemental funding from the prior years before 2007.
LISTNUM 1 \l 12054 Do you follow the table?
LISTNUM 1 \l 12055 MR. HAMELIN: Yes, I do.
LISTNUM 1 \l 12056 MS LOTT: Okay. So, in total, if we look across over the yearly periods there we can see that the level of the national contribution funding is proposed to rise from approximately 10 million per annum to about over 43 million and that's ‑‑ I'm looking at line 24, column J, starting in 2007.
LISTNUM 1 \l 12057 You see where I'm looking?
LISTNUM 1 \l 12058 MR. HAMELIN: Yes, I see that.
LISTNUM 1 \l 12059 MS LOTT: Okay. And at line 26 we have the NCF funding to increase from approximately 6 percent of Northwestel's total revenue requirement to 27 percent in 2007.
LISTNUM 1 \l 12060 And you see that, again line 26 ‑‑
LISTNUM 1 \l 12061 MR. HAMELIN: Yes, I see that.
LISTNUM 1 \l 12062 MS LOTT: ‑‑ columns H and J?
LISTNUM 1 \l 12063 So my question would be: How is this level of funding expected to change over time and by what magnitude?
LISTNUM 1 \l 12064 MR. HAMELIN: In the future you mean?
LISTNUM 1 \l 12065 MS LOTT: Yes.
LISTNUM 1 \l 12066 MR. ROBERTS: Is this with regard to the period of the price cap ‑‑ the price cap period, the four‑year price cap period?
LISTNUM 1 \l 12067 MS LOTT: Sure, that would be fine.
LISTNUM 1 \l 12068 MR. HAMELIN: I don't think it's going to change much because what we are talking about in 2007 is a cost‑based subsidy.
LISTNUM 1 \l 12069 In fact, of the three different elements of the subsidy that we are talking about, the SIP program subsidy we believe is ‑‑ I believe it's been suggested that it remains constant, as does the toll connect subsidy ‑‑ and we can talk more about that.
LISTNUM 1 \l 12070 The only one that would vary in the cost‑based subsidy would be the Res PES element of the total subsidy. I believe the suggestion is that it be based on the NAS count as per down south every year.
LISTNUM 1 \l 12071 The other element that you see, recovery of DRD, that's simply due to a change in methodology to be consistent with the telcos down south. That would be filed on an annual basis and I believe that it's ‑‑ it hovers above the 3 million mark in both 2007, 2008 and then it drops significantly in 2009 and 10.
LISTNUM 1 \l 12072 MS LOTT: Well, you have made reference to the cost‑based subsidy as indicated in the table here of 39.4 million for 2007.
LISTNUM 1 \l 12073 Can you just confirm for me again what you were just saying, what this consists of?
LISTNUM 1 \l 12074 MR. HAMELIN: There are three main elements to this subsidy. One is the SIP portion of the subsidy, which is $11.4 million. I should add that $5.4 million of SIP is also included in the Res PES subsidy. So in effect, if you just take that piece, add it together, almost $17 million is due to the SIP program that we commenced in 2001.
LISTNUM 1 \l 12075 You know, just for the record, just to make things clear on this, this is the carrying costs of the SIP program, $85 million was spent. Now, for us, that is worth at least two years' worth of the total capital expenditure of this company or third of its net asset base. We mentioned yesterday that would be about $3 billion I think for Telus. I think any which way you count it it is a big number for us.
LISTNUM 1 \l 12076 Seventeen million dollars out of the $39 million cost‑based subsidy is 40 percent of new carrying costs that this company is incurring since 2001. I just wanted to make that point clear. This has all things to do with connecting, providing basic service of objectives to a very difficult market.
LISTNUM 1 \l 12077 The second element toll connect is $10.8 million. That has to do with connecting the local switches to the toll switches and Mr. Woodland can talk at length about that in detail, if need be. The Res PES study of $17.2 million, which includes the $5.4 million of SIP due to access that I mentioned, that is exactly the same methodology as down south.
LISTNUM 1 \l 12078 So what we are talking about are two exceptions to down south, is the toll connect piece and the SIP piece, SIP being $17 million of it since 2001.
LISTNUM 1 \l 12079 MS LOTT: Okay, thank you for that. My question flowing from that though is isn't the National Contribution Fund intended to be used to subsidize local service in high‑cost serving areas?
LISTNUM 1 \l 12080 MR. HAMELIN: That is certainly ‑‑ in principle, yes.
LISTNUM 1 \l 12081 MR. ROBERTS: I might add that that is one element of it. Currently, Northwestel has supplemental funding from the National Contribution Fund and that would represent not only the portion that you identified, but I guess a broader non‑specific subsidy. Other companies have also had I guess a broader application of funds from the National Contribution Fund. And I would note in passing here that the Commission's powers with regard to I guess having a Contribution Fund are set out in 46.5 of the Act and it doesn't refer specifically to local service and high‑cost serving areas, but rather to meeting the basic service objective, which I would suggest ‑‑
LISTNUM 1 \l 12082 MS LOTT: Well, that was going to be my question, yes, wasn't the ‑‑
LISTNUM 1 \l 12083 MR. HAMELIN: ‑‑ which I would suggest is broader.
LISTNUM 1 \l 12084 MS LOTT: ‑‑ wasn't the supplemental funding implemented to assist you in meeting your basic service objectives?
LISTNUM 1 \l 12085 MR. ROBERTS: Basic service, yes, which I would add, under 99.16, includes access to toll services amongst other things.
LISTNUM 1 \l 12086 MS LOTT: Just one minute please.
LISTNUM 1 \l 12087 MR. ROBERTS: In fact, if it is of assistance, at paragraph 24 of Telecom Decision 99.16, the elements of basic service objective are set out. Would you like me to share or..?
LISTNUM 1 \l 12088 MS LOTT: That is fine, thank you. I will just be a minute, thank you.
LISTNUM 1 \l 12089 I would like to know whether the CRTC permitted the small ILECs to recover any shortfall in toll interconnection revenues in Decision 2005‑3.
LISTNUM 1 \l 12090 MR. ROBERTS: I am sorry, could you please repeat it?
LISTNUM 1 \l 12091 MS LOTT: Did the CRTC permit the small ILECs to recover any shortfall in the toll interconnection revenues in Decision 2005‑3?
LISTNUM 1 \l 12092 MR. ROBERTS: I am not aware of them doing so, no.
LISTNUM 1 \l 12093 MS CHALIFOUX: I think though, just to be clear, the nature of Northwestel's toll connect facilities are quite unique and the Commission has even recognized that we may not be able to recover those facilities via traditional means and in fact assign those costs to our monopoly access category from a Phase 3 perspective.
LISTNUM 1 \l 12094 But again, just to be clear, we have got ‑‑ toll connect in the case of Northwestel consists of thousands of kilometres of microwave, 42 satellite‑based communities. Again, this is to serve a population base of 110,000 people. So there really is no comparison when you are talking toll connect facilities to SILECs.
LISTNUM 1 \l 12095 You cannot compare Northwestel to ILECs. We have quite a unique high‑cost network and the Commission has recognized the challenges that Northwestel faces in trying to recover that network through traditional means.
LISTNUM 1 \l 12096 MR. ROBERTS: In fact, again in 99‑16, Telecom Decision CRTC 99‑16, at paragraph 62 they specifically recognize that Northwestel may not have the means to achieve the basic service objective under similar terms and conditions to other southern telcos and they further at paragraph 68 provided for the treatment of toll connecting facilities, i.e. facilities between our class 4s and class 5s as monopoly access under Phase 3.
LISTNUM 1 \l 12097 To put this into context, treatment as monopoly access under the traditional regime, the historic regime, meant that it was eligible for subsidy.
LISTNUM 1 \l 12098 MS LOTT: Well, just for the record, I will read you the extract from that decision, paragraph 92. It states:
"The Commission notes that the NCF was established to subsidize local service in high‑cost serving areas and considers that it should not be used to subsidize any shortfall in the toll interconnection revenues of the small ILECs." (As read)
LISTNUM 1 \l 12099 MR. ROBERTS: Again, I would reiterate that in 99‑16 the Commission provided for unique treatment of Northwestel's circumstances addressing our specific challenge with regard to toll connecting trunks. So I would suggest that that would apply to the other telcos in Canada but consistent with paragraph 62 of Telecom Decision CRTC 99‑16 it would not apply to Northwestel.
LISTNUM 1 \l 12100 MS LOTT: Okay.
LISTNUM 1 \l 12101 MR. HAMELIN: Just the distance we are talking about for these interconnections, I think the figure we have is over 7,000 kilometres. It is twice the distance between Ottawa and Victoria, both back and forth. So I don't think there is any ILEC that would come even close to this kind of concept and geography and density and so on.
LISTNUM 1 \l 12102 MS LOTT: Okay, thank you for that.
LISTNUM 1 \l 12103 I wanted to move on to look at the issue of mark‑up, the level of mark‑up included in the proposed subsidy calculation.
LISTNUM 1 \l 12104 My understanding here is that the ‑‑ I have prepared an exhibit here which is called the "Estimate of Northwestel fixed and common costs" ‑‑ that should be the second exhibit in the package that was given to you. As I said, it is entitled "Estimate of Northwestel fixed and common costs recovered through 25 percent mark‑up."
LISTNUM 1 \l 12105 MR. HAMELIN: I have it.
LISTNUM 1 \l 12106 MS LOTT: Do you have that in front of you?
LISTNUM 1 \l 12107 MR. HAMELIN: I do.
LISTNUM 1 \l 12108 MS LOTT: Okay. So my understanding is that the subsidy calculations, as you have said here, include a mark‑up of 25 percent on costs. The CRTC typically permits 15 percent for other ILECs.
LISTNUM 1 \l 12109 So what we have done here on this table is that we estimated the total fixed and common costs for Northwestel based on a 25 percent mark‑up using its total revenues as follows. So you can see there that we have started with the 2006 total forecast operating revenues of $154 million and we have added to that. In the second line, we have divided by 1 plus the 25 percent mark‑up, which is 1.25.
LISTNUM 1 \l 12110 And then in the third line we have achieved the 2006 total, excluding the mark‑up, which is $123 million.
LISTNUM 1 \l 12111 Are you following my ...?
LISTNUM 1 \l 12112 MR. HAMELIN: Well, I see what you have done, yes.
LISTNUM 1 \l 12113 MS LOTT: Okay.
‑‑‑ Pause
LISTNUM 1 \l 12114 MS LOTT: So the fourth line being the estimate of the fixed and common costs, that would be line "D", being $30,808,000, which is implied in your total revenues.
‑‑‑ Pause
LISTNUM 1 \l 12115 MS LOTT: Are you in agreement with my math?
LISTNUM 1 \l 12116 MR. WOODLAND: Your math is correct.
LISTNUM 1 \l 12117 MS LOTT: Okay. Thank you.
‑‑‑ Pause
LISTNUM 1 \l 12118 MS LOTT: So is this ‑‑
LISTNUM 1 \l 12119 MR. HAMELIN: If you could just give us a moment, please?
LISTNUM 1 \l 12120 MS LOTT: Sure.
LISTNUM 1 \l 12121 COMMISSIONER CRAM: Excuse me, I just needed to clarify something, Ms Lott.
LISTNUM 1 \l 12122 MS LOTT: Yes.
LISTNUM 1 \l 12123 COMMISSIONER CRAM: Is this a separate exhibit?
LISTNUM 1 \l 12124 MS LOTT: This is ‑‑
LISTNUM 1 \l 12125 COMMISSIONER CRAM: I know I have the document in front of me, but I just need to know for the record whether it is Consumers Groups Exhibit 4 or part of page 2 of Consumers Groups Exhibit 3.
LISTNUM 1 \l 12126 MS LOTT: My apologies, it should be a separate exhibit, Exhibit 4.
EXHIBIT PIAC-4: Estimate of Nothwestel fixed and common costs recovered through 25% mark‑up
LISTNUM 1 \l 12127 THE SECRETARY: It is noted as Exhibit No. 4.
LISTNUM 1 \l 12128 COMMISSIONER CRAM: Thank you.
LISTNUM 1 \l 12129 Just for the record so we have the same thing.
LISTNUM 1 \l 12130 MS LOTT: Yes, to clarify. Absolutely, yes.
LISTNUM 1 \l 12131 We stapled them together just for ease of distribution.
LISTNUM 1 \l 12132 I will give you a minute there before I ask my question.
‑‑‑ Pause
LISTNUM 1 \l 12133 MS LOTT: Mr. Chairman, I just wanted to apologize for the delay here. We did hand out copies of these exhibits yesterday to counsel for Northwestel, but something might have happened in translation.
LISTNUM 1 \l 12134 THE CHAIRPERSON: Well, that suggests to me that you don't need to apologize, Ms Lott.
‑‑‑ Pause
LISTNUM 1 \l 12135 MR. HAMELIN: So you have a question?
LISTNUM 1 \l 12136 MS LOTT: Yes, I do. I just wanted to make sure you were ready for me to go. Okay.
LISTNUM 1 \l 12137 My question is: Is this the total level of fixed and common costs?
LISTNUM 1 \l 12138 MS CHALIFOUX: I'm sorry, which number are you referring to? The top there? The total...?
LISTNUM 1 \l 12139 MS LOTT: The $30.8 million.
LISTNUM 1 \l 12140 MS CHALIFOUX: Well, if you use sort of the hypothesis that generally all rates times a 25 percent mark‑up equals your revenue, then that is the ballpark of what is required.
LISTNUM 1 \l 12141 MS LOTT: Just to confirm what you have said there, that is the total level. You are confirming that that is the total level of fixed and common costs?
LISTNUM 1 \l 12142 MS CHALIFOUX: If you are looking for a proxy, that could be deemed to be a proxy.
‑‑‑ Pause
LISTNUM 1 \l 12143 MS LOTT: I would like to move to the bottom part of the exhibit that you have in front of you. That bottom half is entitled "Northwestel Identifiable Fixed and Common Costs".
LISTNUM 1 \l 12144 So it is the same table, just the bottom half of it.
LISTNUM 1 \l 12145 You are seeing where I am fixing there? Okay.
LISTNUM 1 \l 12146 So a second area of fixed and common costs...
LISTNUM 1 \l 12147 Just to explain what we have here, in Northwestel the interrogatory response to CRTC‑310, Attachment 10, identifies common operating and administration expenses of $9.5 million. That is what we have listed here in the Common Operating Expenses line and the Common Administrative Expenses line and the Total Common Costs line of $9.4 million.
LISTNUM 1 \l 12148 Do you follow my reference there?
LISTNUM 1 \l 12149 MS CHALIFOUX: Yes, I am following along.
LISTNUM 1 \l 12150 MS LOTT: So the second area of fixed and common costs is the fixed structures which were identified in CRTC‑1601, Attachment 2, and reproduced here in another exhibit, which I will ask you to pull out, which is the third exhibit that we have prepared here.
LISTNUM 1 \l 12151 That is entitled "Fixed Structures Based on Northwestel CRTC‑1601, Attachment 2".
LISTNUM 1 \l 12152 Do you see that in the next ‑‑ it should be the next one behind the ‑‑
LISTNUM 1 \l 12153 THE CHAIRPERSON: We will call it Exhibit 5.
LISTNUM 1 \l 12154 MS LOTT: Thank you.
EXHIBIT PIAC‑5: Fixed structures - Based on NWTel(CRTC)10Apr06-1601- Attachment 2
LISTNUM 1 \l 12155 MS CHALIFOUX: Yes, we have that one here.
LISTNUM 1 \l 12156 MS LOTT: If we could focus on that one right now, I wonder if you could tell me what services make use of these assets that are listed.
LISTNUM 1 \l 12157 MS CHALIFOUX: The nature of these investments, if you look here as an example, generating plants ‑‑ perhaps I could step back to give you an illustration.
LISTNUM 1 \l 12158 Northwestel has 137 microwave radio stations. So for each of these 137 microwave stations there would be a tower foundation. Many of these sites need to be self‑generated power so you would have a generating plant on site.
LISTNUM 1 \l 12159 Fifty‑two sites have no road access and need to be maintained and fuelled by helicopters, so you would see a helicopter pad.
LISTNUM 1 \l 12160 Actually, for an illustration, if you look at our opening argument we provided a picture of one of our microwave sites, Fraser, B.C., and you can see quite clearly there a lot of what we are talking about here.
LISTNUM 1 \l 12161 You can see a tower. You can see a helicopter pad. So these are microwave stations.
LISTNUM 1 \l 12162 Many services use these. Many services ride on a microwave itself, but there is a large fixed component.
LISTNUM 1 \l 12163 So when you are looking at service‑specific costing, causal costing ‑‑ and Mr. Woodland can elaborate here ‑‑ you look at costs that going forward vary with demand; so demand for data, demand for toll.
LISTNUM 1 \l 12164 But because these fixed costs do not vary ‑‑ they are by nature fixed ‑‑ it is the mark‑up component that you apply on top of your Phase 2 costing which provides a suitable recovery towards these costs.
LISTNUM 1 \l 12165 MR. WOODLAND: I can expand on Ms Chalifoux's answer by noting that, for instance, duct systems are used by any services that ride on outside plant. So that would include the connection end of data circuits. It would include local service.
LISTNUM 1 \l 12166 Batteries are used, effectively, by every service that the company offers. Batteries are part of the power system in any one of our facilities, whether it is a microwave site or a central office.
LISTNUM 1 \l 12167 Generating plants would primarily be used by services that make use of the transport network, because most of our generating plant investment is there, although a substantial amount is also embodied in standby generation, and that can be at central offices as well.
LISTNUM 1 \l 12168 Inverters and converters are similar to batteries.
LISTNUM 1 \l 12169 Permanent buildings would tend to be central offices. Semi‑permanent buildings would tend to be buildings used for the transport network. So any service, whether it is IP, internet, data circuits, toll, that make use of the transport network would make use of those assets.
LISTNUM 1 \l 12170 Access roads and site clearance, again, are primarily involved with the transport network.
LISTNUM 1 \l 12171 Towers are primarily involved with the transport network, and services making use of that.
LISTNUM 1 \l 12172 Air conditioning and heating systems would apply to all buildings and, therefore, to all services.
LISTNUM 1 \l 12173 That should be sufficient.
LISTNUM 1 \l 12174 MS LOTT: Thank you.
LISTNUM 1 \l 12175 What is the total 2006 depreciation expense for these assets?
LISTNUM 1 \l 12176 I have a figure, but I wanted to confirm that I am correct with $4.464 million.
LISTNUM 1 \l 12177 MS CHALIFOUX: Yes, subject to check, but if you have that from our interrogatories, that would be the total depreciation accrual related to those assets.
LISTNUM 1 \l 12178 MR. WOODLAND: I would like to point out that these are very specific lines in the investment record that are considered part of fixed structures and considered part of fixed and common costs, but it is not a good way to look at the total of fixed and common costs related to investment that Northwestel has made. There is a big difference between recording an investment as part of the investment record aligned against a certain asset, and then the way it is treated in doing Phase 2 calculations to determine a Phase 2 cost going forward.
LISTNUM 1 \l 12179 So there are significant portions of the investment in all of the different asset classes that would be considered fixed.
LISTNUM 1 \l 12180 An example would be the central processing portion of the DMS‑100. In a few years we will have to upgrade that, at a cost of more than $2 million, and we will be upgrading that because the manufacturer no longer supports the version we have.
LISTNUM 1 \l 12181 The version of the central processing unit that we have already exceeds our needs. It has capacity far in excess of what we will ever put through it.
LISTNUM 1 \l 12182 The new server, at greater than $2 million, will exceed that by even more.
LISTNUM 1 \l 12183 I want to be very clear that the list you have provided here in your exhibit is far and away from being a complete list of fixed and common assets.
LISTNUM 1 \l 12184 MS LOTT: Let me remind you that I am taking your interrogatory response. This is your list.
LISTNUM 1 \l 12185 I wanted to confirm, as you have indicated, and we have produced it, that the fixed structures as a percentage of total represent 14 percent of total depreciation accruals versus 22 percent of total plan and service.
LISTNUM 1 \l 12186 Am I correct that that is what you produced in your response?
LISTNUM 1 \l 12187 MS CHALIFOUX: Yes, that appears to be correct.
LISTNUM 1 \l 12188 Many of these ‑‑ just the nature of these fixed structures is such that they do have lengthy lives.
LISTNUM 1 \l 12189 However, to go back to the point that Mr. Woodland made, yes, this is our list, but this list, to be clear, was to be illustrative of fixed structural costs.
LISTNUM 1 \l 12190 We also noted in our response to the interrogatory that there is also this fixed common investment, which Mr. Woodland was referring to, the nature of the CPU upgrade that he was referring to.
LISTNUM 1 \l 12191 Again, those aren't as easily identifiable at an asset code level. It was difficult to illustrate them; whereas the fixed structure cost ‑‑ clearly one can look at that and say, "Aha, that is, in essence, 100 percent fixed."
LISTNUM 1 \l 12192 Again, it was meant to illustrate a portion, and, more importantly, to illustrate the relative significance of that portion.
LISTNUM 1 \l 12193 MS LOTT: Thank you for that.
LISTNUM 1 \l 12194 I want to take us back, then, to the exhibit, the estimates of the Northwestel fixed and common costs, at the bottom half of that exhibit.
LISTNUM 1 \l 12195 If we combine that figure that you have confirmed there of the fixed structures depreciation expense of 4.5 million with the common expenses added up ‑‑ total common costs of 9.5 million, we have reached a total there of the total fixed structures and common costs of approximately 14 million.
LISTNUM 1 \l 12196 Do you follow what I have put in the bottom half of the table there?
LISTNUM 1 \l 12197 MS CHALIFOUX: Right. And that would be, again, a representation of only a component of the costs.
LISTNUM 1 \l 12198 Take the fixed structure, the nature of the investment is such that, you know, you also have to recover your normal financing costs, your normal carrying costs.
LISTNUM 1 \l 12199 There's interest expense, you know, a return in the taxes paid on that return, all the innocents, the carrying costs of that investment need to be recovered.
LISTNUM 1 \l 12200 So the mark‑up is intended to contribute towards all of those components not just the depreciation. And then on top of that, again, you have got these common elements that Mr. Woodland provided some good examples of.
LISTNUM 1 \l 12201 So, I mean, this is only a partial analysis and this is one of the challenges that Northwestel has. I mean, it's very difficult to go and provide a detailed qualitative analysis that sums magically to 25 percent.
LISTNUM 1 \l 12202 But, again, our main point there is that costs are significant and particularly relative to the ILECs and the small independent companies we are very unique.
LISTNUM 1 \l 12203 Just the example we were talking about previously, the extent of our microwave stations. no other company has that degree of inter‑toll facilities ‑‑ or inter‑network facilities, I should say, intra‑network facilities. Satellite, no other company has the degree of satellite that we have. There's just a number of examples that clearly indicate relative to others the need for a higher mark‑up.
LISTNUM 1 \l 12204 MR. WOODLAND: So this is just to be clear, the bottom half of your exhibit falls short of the representation of the total fixed and common costs of the company by the operating amounts that Ms Chalifoux identified with relation to the fixed structures, so it's missing interest costs, return and taxation on those and then, as well, is missing depreciation on the other asset classes that I mentioned and all of the operating, administrative expenses and interest and income tax and return that's associated with those assets as well.
LISTNUM 1 \l 12205 MS LOTT: I'm just wondering, based on what you said, if you could build that back up and add in those elements that you have just identified so that we can see what those are.
LISTNUM 1 \l 12206 MR. HAMELIN: Just as a comment, I don't believe that down south a 15 percent mark‑up was proven company‑by‑company in the sense of reconciling phase 2 studies with phase 3 embedded costs, originally started a long ‑‑ several ‑‑ I don't know exactly how long ago, but certainly a long time ago.
LISTNUM 1 \l 12207 It used to be 25 percent was the accepted norm, then further decisions came along whereby 15 percent became the norm.
LISTNUM 1 \l 12208 All we are suggesting is in the case of Northwestel, because we differ so significantly from not just the ILECs ‑‑ certainly all the ILECs down south, that 25 percent still would be required relative to those down south.
LISTNUM 1 \l 12209 THE CHAIRPERSON: Thank you, Mr. Hamelin, but you were asked another question.
LISTNUM 1 \l 12210 Do you think you could respond to the other question?
LISTNUM 1 \l 12211 MR. HAMELIN: I'm sorry, can you repeat the question?
LISTNUM 1 \l 12212 MS LOTT: Well, because one of your panellists has indicated what would make up the difference, added in to make up that estimate of 31 million in fixed and common costs and you have started to indicate what some of those would be, I'm just wondering if you could fill that in for us item by item and undertake to let us see what that would be.
LISTNUM 1 \l 12213 MR. WOODLAND: Not within the time frame of this hearing certainly. The entire costing department of Northwestel is sitting here in this chair and I have already committed the next few weeks to some interrogs.
LISTNUM 1 \l 12214 MS CHALIFOUX: I think again too, just to go back to some of the fundamentals of the costing, I mean, we don't have detailed service‑specific costing for all our services.
LISTNUM 1 \l 12215 So, you know, to do a detailed analysis one would need to go and say okay let us do phase 2 studies for all of our services and then let us see the residual, the fixed component that needs to be recovered.
LISTNUM 1 \l 12216 So this is to what Ray was alluding to, you know, many of the ILECs could possibly put some quantitative analysis for one service on the record, but certainly not for all of their services and nor could Northwestel undertake to do the same thing.
LISTNUM 1 \l 12217 MS LOTT: Well I guess my question would be that because you are asking for a 25 percent mark‑up on costs shouldn't the onus be on you to be able to specifically justify to us why that mark‑up should be there?
LISTNUM 1 \l 12218 MS CHALIFOUX: What we are trying to do is trying to clearly illustrate, if nothing else, the uniqueness and the relative merits of a higher mark‑up for Northwestel.
LISTNUM 1 \l 12219 MR. HAMELIN: I don't think that there is one SILEC that comes even close compared to Northwestel, particularly after Northwestel having spent a SIP program of the magnitude we are talking about, which just added to the cost base significantly. And there is virtually no chance of, particularly on that aspect of the investment, of getting any scale gains whatsoever.
LISTNUM 1 \l 12220 MR. WOODLAND: Just as an example of one fixed cost item. Northwestel has 570 diesel fuel tanks compared to 700 in the Bell consolidated trust, which is basically Bell's operations in Central and Eastern Canada outside Montreal, Toronto and Ottawa. For our 75 NAS then, we have one fuel tank for every 133 of them. The consolidated trust has one fuel tank for every 4,857 NAS, so that is a ratio of 36 times as many.
LISTNUM 1 \l 12221 THE CHAIRPERSON: I do think this point has been made. I would add, that what we are trying to get at here, as I understand Ms Lott, is the justification for raising the proportion of your revenue received from the National Contribution Fund from 6 percent to 27 percent in a one‑year step function. That too doesn't exist in the south.
LISTNUM 1 \l 12222 So now we are in a unique situation and we are asking really can you help us to understand why the figures that have been put forward by the consumer group are inadequate. And you have explained them in very general terms. I think what we are not looking for is a series of cost studies, we are looking for a more detailed and black and white explanation of what the inadequacies of this particular calculation in Exhibit 4 really are in your minds.
LISTNUM 1 \l 12223 Is it possible that you could provide us that in writing in a fairly short time period?
LISTNUM 1 \l 12224 MS CHALIFOUX: Well we could certainly ‑‑ just to actually clarify Exhibit 4 is the one with the calculations there of $13 million, is that..?
LISTNUM 1 \l 12225 MS LOTT: That is correct.
LISTNUM 1 \l 12226 MS CHALIFOUX: Okay.
LISTNUM 1 \l 12227 THE CHAIRPERSON: What items would have to be added in writing ‑‑ and you don't even have to put figures on them, if necessary.
LISTNUM 1 \l 12228 MS CHALIFOUX: Yes, we can certainly put figures to some and then others we would just note that these are the elements ‑‑
LISTNUM 1 \l 12229 THE CHAIRPERSON: I think that is fair, Ms Chalifoux. We are asking for a good faith attempt to try to explain in black and white why these ‑‑
LISTNUM 1 \l 12230 MS CHALIFOUX: ‑‑ to reconcile.
LISTNUM 1 \l 12231 THE CHAIRPERSON: ‑‑ why this data is inadequate.
LISTNUM 1 \l 12232 MS CHALIFOUX: Sure.
LISTNUM 1 \l 12233 MS LOTT: Absolutely, thank you.
LISTNUM 1 \l 12234 Okay, you are asking to recover a 25 percent mark‑up on residential costs through the National Contribution Fund. I am interested in knowing whether all other Northwestel services are making this level of recovery to its fixed common cost.
LISTNUM 1 \l 12235 MR. HAMELIN: I don't have in front of me all the costing studies by services, but certainly some services contribute more than others and..
LISTNUM 1 \l 12236 MS LOTT: Okay, I wonder if we could then maybe go through some of the services and I wanted to go back to a table that I provided actually yesterday to the marketing group, but I have also provided it for your convenience and it was identified as Exhibit 1 yesterday again in this group of exhibits that you would have been given. Do you have that in front of you? It says, Table 1, Northwestel Actual Forecast Operating Revenues for 2002 to 2007.
LISTNUM 1 \l 12237 MR. HAMELIN: Yes, I do.
LISTNUM 1 \l 12238 MS LOTT: Okay, so if I could go through that. I am interested in knowing here what services offered by Northwestel have rates that provide a mark‑up of at least 25 percent. For example, line 2 and 3, the business primary exchange ‑‑ sorry, line 2?
LISTNUM 1 \l 12239 MR. WOODLAND: Well clearly, residential does not in that we are seeking subsidy for the gap between its revenue and costs.
LISTNUM 1 \l 12240 MS LOTT: But the business primary exchange?
LISTNUM 1 \l 12241 MR. WOODLAND: We answered that in an interrog, less than 25 percent but it does require a mark‑up.
LISTNUM 1 \l 12242 MS LOTT: Okay.
LISTNUM 1 \l 12243 MR. ROBERTS: And I would add that the associated toll that those customers also take contributes a significant mark‑up, so if you look at the broader picture.
LISTNUM 1 \l 12244 MS LOTT: Okay.
LISTNUM 1 \l 12245 MR. WOODLAND: I think the point is really that on aggregate the services that provide revenue aside from the subsidies in our proposal, on aggregate they will be recovering 25 percent over costs.
LISTNUM 1 \l 12246 MS LOTT: Have you done cost studies for those?
LISTNUM 1 \l 12247 MR. WOODLAND: No, we have indicated that already.
LISTNUM 1 \l 12248 MR. ROBERTS: If I could maybe illustrate some other services as well. I think particularly relevant to this proceeding is that the CAT rate we are proposing now is cost‑based, switch connect rates to replace the CAT that is currently in force.
LISTNUM 1 \l 12249 The proposed switch connect rate, again, is cost‑based with a 25 percent mark‑up and that yields a rate of .825 cents per minute. The current rate is 7 cents and that rate represents a significant source of mark‑up of implicit contribution and, of course, we are maintaining, as reiterated throughout this proceeding, that this is not sustainable at this extreme level of contribution subsidy of mark‑up.
LISTNUM 1 \l 12250 Similarly, I would point to private wire services. Private wire services also taken by business are currently at a rate that equates to approximately $18,000 per month per T1 per DS1 from Whitehorse to Fort St. John, for instance.
LISTNUM 1 \l 12251 A comparable rate in a forborne market, presumably a cost‑based rate then, would be approximately $1,100 to $1,200, for instance, given specific quotes we have had from different parties from Fort St. John to Edmonton.
LISTNUM 1 \l 12252 So again, you can see the magnitude of mark‑up on these services and this is really at the heart of why we are proposing the rate restructuring that we are, because we are concerned about the sustainability of these very high mark‑ups going forward. They are making a disproportionate contribution to the costs here and again, in our view, they are just not sustainable.
LISTNUM 1 \l 12253 MR. HAMELIN: So what we are saying is in the end the proposal that we are presenting will be bringing down ‑‑ eliminating a lot ‑‑ to a great degree, I should say, the implicit subsidies. But in the end we feel we are not going far enough. There are still some implicit subsidies that will exist even after the rate proposals that we are proposing. The example you just got is quite a substantial one.
LISTNUM 1 \l 12254 MS LOTT: Okay. Just so that I can be quite specific here about services though, line 16, the total terminal, does that have rates that provide a mark‑up of at least 25 percent?
LISTNUM 1 \l 12255 MR. WOODLAND: We don't know that.
LISTNUM 1 \l 12256 MS LOTT: Okay. And how about line 18, which is the total "Other"?
LISTNUM 1 \l 12257 MR. WOODLAND: Again, not having performed Phase II studies on all the services, I can't answer that either.
LISTNUM 1 \l 12258 MS LOTT: Okay.
LISTNUM 1 \l 12259 MR. HAMELIN: I can say that under Phase III things like competitive terminals are still somewhat not compensatory and this comes as no real big surprise when you think of the nature of our territory.
LISTNUM 1 \l 12260 You will not find a Radio Shack or a Circuit City, or a McDonald's for that matter, when you are talking to most of our communities that we are serving. And so in the end we are the end provider of terminals, for example, and I wouldn't expect that you would see a compensatory 25 percent mark‑up.
LISTNUM 1 \l 12261 MS LOTT: Okay, thank you for that.
LISTNUM 1 \l 12262 I wanted to move on to a last area that I want to look at with you this morning and that is some questions around productivity.
‑‑‑ Pause
LISTNUM 1 \l 12263 MS LOTT: So my understanding is that Northwestel is proposing to be able to increase its primary exchange residential rates by inflation for price cap purposes and its costs by inflation for the high‑cost serving area subsidy calculation purposes since it is proposing a productivity offset or an "X" factor of 0 percent.
LISTNUM 1 \l 12264 Am I correct about that? That's what you are proposing?
LISTNUM 1 \l 12265 MR. HAMELIN: That's correct.
LISTNUM 1 \l 12266 MS LOTT: Does this mean that there is no annual productivity improvement?
LISTNUM 1 \l 12267 MR. ROBERTS: On a net basis we are suggesting that we would have a significant challenge in trying to gain a positive productivity on a net basis, given the challenges illustrated historically by costs.
LISTNUM 1 \l 12268 MS LOTT: So the answer is yes?
‑‑‑ Pause
LISTNUM 1 \l 12269 MR. ROBERTS: I believe so, yes.
LISTNUM 1 \l 12270 MS LOTT: All right.
‑‑‑ Pause
LISTNUM 1 \l 12271 MS LOTT: So if I can just confirm here that while you have filed productivity estimates of negative productivity ‑‑ I understand that that was ‑2.9 percent per annum ‑‑ you are now proposing a productivity offset of 0 percent.
LISTNUM 1 \l 12272 That's correct?
LISTNUM 1 \l 12273 MR. HAMELIN: That's correct.
LISTNUM 1 \l 12274 MR. WOODLAND: Well, if I may, just to be clear, we didn't file an estimate of ‑2.9 percent with regards to forward‑looking productivity estimates. That was simply the result of a calculation based on the last eight years worth of data that we have, which represents two points of data, 1998 and 2006.
LISTNUM 1 \l 12275 MR. ROBERTS: Going forward and arriving at our 0 percent "X" factor that's proposed, we relied on three basic factors for determining this as a reasonable proposal, reasonable and balanced.
LISTNUM 1 \l 12276 The first is the significant challenge that we have in making net productivity gains. I would suggest that the year‑over‑year study, what is it, 1998 versus 2006, for Res PES demonstrates the challenge in broad terms with regard to containing costs.
LISTNUM 1 \l 12277 In addition, while we have had some, I guess, success in achieving productivity in specific areas we are also trying to deal with a number of items that go up. So it's a balancing act.
LISTNUM 1 \l 12278 We also have extremely low density on a comparative basis to other carriers which exacerbates our ability to benefit from economies of scale.
LISTNUM 1 \l 12279 In fact, we also have a very small base of operations. This small base results in individual events, perhaps like a damaged dish, a damaged tower, having significant impacts on our overall productivity.
LISTNUM 1 \l 12280 To differentiate again from other carriers, if you look at a circumstance that we had ‑‑
LISTNUM 1 \l 12281 MS LOTT: I will just remind you here, I didn't ask you why. I'm just asking you to confirm some of these numbers for me and just to make sure that I have total understanding here of your evidence.
LISTNUM 1 \l 12282 Am I correct that you have also updated that negative productivity estimate from your initial filings to correct for an error and the result is now a negative 3.2 percent per year?
LISTNUM 1 \l 12283 Am I correct about that?
LISTNUM 1 \l 12284 MR. WOODLAND: Yes.
LISTNUM 1 \l 12285 MS LOTT: Okay. Thank you.
LISTNUM 1 \l 12286 Now, by contrast the current productivity offset for the large ILECs as well as for Québec Tel and Télébec is 3.5 percent, which is significantly greater than your estimate or your proposed productivity offset.
LISTNUM 1 \l 12287 MR. HAMELIN: They didn't have to invest a third of their balance sheet to try and provide basic service objectives. That is one point.
LISTNUM 1 \l 12288 The second point is our systems have no scale essentially to allocate the costs as significantly as down south. So those two elements have caused a real distortion in productivity between 1998 and 2005.
LISTNUM 1 \l 12289 MS LOTT: Thank you.
LISTNUM 1 \l 12290 Just one moment.
‑‑‑ Pause
LISTNUM 1 \l 12291 MS LOTT: Am I correct here as well that that estimate is based on only two data points for residential Phase 2 costs providing service, 1998 versus 2006?
LISTNUM 1 \l 12292 Am I correct?
LISTNUM 1 \l 12293 MR. WOODLAND: That is correct.
LISTNUM 1 \l 12294 MS LOTT: How many data points does Northwestel use in deriving its productivity estimate?
LISTNUM 1 \l 12295 You indicated 1998 and 2006.
LISTNUM 1 \l 12296 MR. WOODLAND: Again, I will just reiterate that that is not an estimate of future productivity likelihoods. It is simply a calculation of the past eight years, the actual productivity over those past eight years.
LISTNUM 1 \l 12297 MR. ROBERTS: And if you would like me to elaborate as to how we came up with our forward looking productivity estimate, I would ‑‑
LISTNUM 1 \l 12298 MS LOTT: That is not in my list of questions.
LISTNUM 1 \l 12299 My question following that is: Doesn't that lack of data points limit the validity of the estimate?
LISTNUM 1 \l 12300 I believe you have indicated that in an interrogatory response to Telus.
LISTNUM 1 \l 12301 MR. WOODLAND: And I point out once again that that is not our estimate of future productivity factor. It is simply a calculation of the historical and is used primarily as an indication and an illustration of the cost challenges that Northwestel has faced, not necessarily those that we will face going forward.
LISTNUM 1 \l 12302 MS LOTT: Yes, we are interested in the historical.
LISTNUM 1 \l 12303 THE CHAIRPERSON: Wait a minute. The question was not that. The question was: Do you or do you not have confidence in the value of that study as an indicator for your future forecast?
LISTNUM 1 \l 12304 Did you or did you not concede that there might be problems with that study?
LISTNUM 1 \l 12305 That was the purpose of the question.
LISTNUM 1 \l 12306 MR. WOODLAND: If that was the purpose of the question, it wasn't clear.
LISTNUM 1 \l 12307 In that sense then, I would agree that the absence of additional data points makes it difficult to determine essentially the slope of the curve of Res PES costs over the period and in particular the slope of the curve close to the present day in terms of it being an indication of what the productivity factor might be in the future.
LISTNUM 1 \l 12308 The absence of intervening data points makes it hard to understand whether the curve went up and it is coming down now or was flat and then rose very quickly near the end and is still continuing to rise. Absolutely that is a problem with only having two data points.
LISTNUM 1 \l 12309 I will point out though that two data points, given that they are fairly far apart, that does smooth some of the possibly intervening spikes in costs in terms of what did actually happen over that eight‑year period.
LISTNUM 1 \l 12310 If those two data points had been two years apart and were that far apart, well, I wouldn't put very much reliance at all on the slope of the line. But given the distance apart that they were and the fact that they both performed to the best of our abilities following Phase 2 principles, as advised by our consultant, Leon Shufeld, we have every confidence in the individual numbers in both of those studies and what they represent in terms of the change in cost over that period of eight years.
LISTNUM 1 \l 12311 MR. ROBERTS: In addition, I would suggest that those numbers are very instructive with regard to illustrating how different we are from other telephone companies. I would suggest that no other telephone company would have a profile between two data points on their curve over such a long period as we have.
LISTNUM 1 \l 12312 So again it's I believe very illustrative of how different we are and how unique our circumstances are.
LISTNUM 1 \l 12313 MS LOTT: Does the 1998 cost estimate include the costs associated with Northwestel's recent service improvement plan program?
LISTNUM 1 \l 12314 MR. WOODLAND: No, it does not.
LISTNUM 1 \l 12315 MS LOTT: It doesn't; okay.
LISTNUM 1 \l 12316 MR. WOODLAND: That program started in 2001 and completed in 2005.
LISTNUM 1 \l 12317 MS LOTT: So it's in the 2006 numbers. Am I correct?
LISTNUM 1 \l 12318 MR. WOODLAND: That is correct.
LISTNUM 1 \l 12319 MS LOTT: Just one moment, please.
‑‑‑ Pause
LISTNUM 1 \l 12320 MS LOTT: My understanding, as well, is that there were a number of other adjustments that were made to the 1998 data for changes in income tax, interest rates, asset life changes, and the variable common cost factor.
LISTNUM 1 \l 12321 Am I correct about that?
LISTNUM 1 \l 12322 MR. WOODLAND: Yes.
LISTNUM 1 \l 12323 MS LOTT: In response to an interrogatory from the Consumer Groups, PIAC‑04(G) ‑‑ and I am looking at the bottom of page 3 of 4, going over to the top of page 4 of 4.
LISTNUM 1 \l 12324 Do you want to pull that out?
LISTNUM 1 \l 12325 MR. WOODLAND: I have it.
LISTNUM 1 \l 12326 MS LOTT: You have indicated there that the marginal cost data provided by Bell in the price cap proceeding, which led to Decision 2002‑34, included normalization‑like adjustments to assure cost data comparability over time.
LISTNUM 1 \l 12327 I note that you have a footnote referencing an interrogatory ‑‑ CRTC of the 16th of March 2001, 105, the price caps.
LISTNUM 1 \l 12328 Do you see that footnote reference you made?
LISTNUM 1 \l 12329 MR. WOODLAND: Yes.
LISTNUM 1 \l 12330 MS LOTT: In that interrogatory response, CRTC‑105, did Bell make any adjustments to its cost estimates over time for the items I have mentioned ‑‑ the income tax rates, the changes in interest rates, the changes in variable common cost factors, and the changes in asset lives?
‑‑‑ Pause
LISTNUM 1 \l 12331 MS LOTT: If you are not able to answer the question right away, not having the response in front of you, you could undertake it.
LISTNUM 1 \l 12332 The supposition I would make to you is that the answer is no, but we could make that subject to check.
LISTNUM 1 \l 12333 MR. WOODLAND: Subject to check, I will accept that.
LISTNUM 1 \l 12334 I think we should be clear that the normalization adjustments were made to try to put the results of the two studies on an equal footing and take out of the calculation the effects of factors that affect productivity that are not necessarily reproducible going forward.
LISTNUM 1 \l 12335 If you remove that and recalculate, we still end up with negative productivity over that period.
LISTNUM 1 \l 12336 It was really just for illustrative purposes. It highlights the extent of the cost changes for us over that period of time.
LISTNUM 1 \l 12337 But even without the normalization, we would still have negative productivity over that period.
LISTNUM 1 \l 12338 MS LOTT: Thank you.
LISTNUM 1 \l 12339 Just a moment, please.
‑‑‑ Pause
LISTNUM 1 \l 12340 MS LOTT: Now I would like to take what we have been talking about and establish what the productivity estimate would be, excluding the adjustments that were made by Northwestel to the 1998 data, excluding the SIP, and using currently approved asset lives.
LISTNUM 1 \l 12341 As you see, we have another exhibit for you here. I hope you have it. It is called, "Productivity Offset for Northwestel".
LISTNUM 1 \l 12342 MR. WOODLAND: I have it.
LISTNUM 1 \l 12343 MS LOTT: I don't know what exhibit number we are at, but I will leave that to the Commission.
LISTNUM 1 \l 12344 THE CHAIRPERSON: Are we at 6, Madam Secretary?
LISTNUM 1 \l 12345 THE SECRETARY: Yes, it is Exhibit No. 6.
LISTNUM 1 \l 12346 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 12347 MS LOTT: If we could look at this exhibit, what we have done here is shown Northwestel's productivity estimate, and the Consumer Groups have done an alternative derivation of a productivity estimate.
LISTNUM 1 \l 12348 We wanted to provide a comparison of Northwestel's estimate of productivity with that using unadjusted 1998 costs and 2006 costs, excluding the SIP and using current asset lives, and an inflation estimate, as you can see here, that we have put at 2.3 percent.
LISTNUM 1 \l 12349 I will now take you through this.
LISTNUM 1 \l 12350 MR. WOODLAND: If it will speed things up, I have reviewed the calculation and the mechanics of it are fine.
LISTNUM 1 \l 12351 MS LOTT: You are following my math on that?
LISTNUM 1 \l 12352 MR. WOODLAND: Yes.
LISTNUM 1 \l 12353 MS LOTT: Okay.
LISTNUM 1 \l 12354 MR. ROBERTS: If I may reiterate, that it's not our estimate of forward looking productivity.
LISTNUM 1 \l 12355 MS LOTT: Okay. So if I could just confirm that you would certainly agree to the alternate calculation that we have made here, the productivity estimate of ‑‑ yours of being ‑3.2 percent and the one we have derived at of 0.7 percent?
LISTNUM 1 \l 12356 MR. WOODLAND: Oh, I agree to the accuracy of the calculations, I don't necessarily agree with the assumptions ‑‑
LISTNUM 1 \l 12357 MS LOTT: Right.
LISTNUM 1 \l 12358 MR. WOODLAND: ‑‑ embedded in the notes.
LISTNUM 1 \l 12359 MS LOTT: Yes, thank you. Okay.
LISTNUM 1 \l 12360 MR. WOODLAND: In fact, I will note that I did my own calculation where if retaining normalization in the calculation I would come up with a productivity offset of ‑0.7.
LISTNUM 1 \l 12361 I have in my own notes an example of doing ‑‑ without normalization, or sorry, leaving SIP in with no normalization I would get a productivity factor of ‑1.8.
LISTNUM 1 \l 12362 So, I mean, there are different ways to package these things and I think the key is that if some other mechanism for calculating or forward estimate is used, that estimate can only legitimately be applied to the costs that were actually included in that calculation.
LISTNUM 1 \l 12363 I mean, I really don't think it makes sense to take SIP access costs out of residential PES ‑‑ there are many reasons for that and we'll probably get into at another point ‑‑ but if they were taken out, then the productivity factor could not be applied to those SIP, those NAS, I mean, it could only be applied to the NAS that were left behind.
LISTNUM 1 \l 12364 MS LOTT: Yes. I will just state that we'll leave that for argument that we will submit in due course of this hearing.
LISTNUM 1 \l 12365 So in estimating the level of productivity, Northwestel has used the incremental cost of residential service instead of a full total factor productivity study for the company as a whole.
LISTNUM 1 \l 12366 Am I correct about that?
LISTNUM 1 \l 12367 MR. HAMELIN: Absolutely.
LISTNUM 1 \l 12368 MS LOTT: Why was a total factor productivity study not conducted?
LISTNUM 1 \l 12369 MR. HAMELIN: Well, we just applied the same methodology that was used down south in calculating the Res PES productivity.
LISTNUM 1 \l 12370 When it comes to total productivity for the company, this differs very significantly. I mean, today what we have been using under the current regime is something that includes inflation, it includes load as a proxy, mostly being the growth in NAS, and the growth in NAS virtually is kind of nil these days, has been for several years ‑‑ in fact, we are projecting a decline next year ‑‑ minus 2 percent.
LISTNUM 1 \l 12371 Now, having said that, if I showed you the ‑‑ you know, the level of operating expenses from I would say five, six years in a row consecutively, you would see that expenses have been contained ‑‑ regardless of how you calculate the productivity, expenses have been contained to a growth of just about 1 percent max per year.
LISTNUM 1 \l 12372 I believe I have figures from 19 ‑‑ just a moment, please.
LISTNUM 1 \l 12373 For example, our operating expenses in 2001 were $72.9 million, the end of 2005 they are $75.9 million. That's merely a $3 million increase over four years.
LISTNUM 1 \l 12374 We are still at $78 million in 2007.
LISTNUM 1 \l 12375 THE CHAIRPERSON: Mr. Hamelin, do we already have that data?
LISTNUM 1 \l 12376 MR. HAMELIN: No ‑‑
LISTNUM 1 \l 12377 THE CHAIRPERSON: The longitudinal expense series?
LISTNUM 1 \l 12378 MR. HAMELIN: No, you ‑‑
LISTNUM 1 \l 12379 THE CHAIRPERSON: Perhaps, would it be reasonable if you could provide the data over the period in question?
LISTNUM 1 \l 12380 MR. HAMELIN: We have it very handy right now.
LISTNUM 1 \l 12381 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 12382 MR. HAMELIN: So my point is, on the total company basis you can see that expenses were constrained and contained very lately.
LISTNUM 1 \l 12383 Anyone else wants to...
LISTNUM 1 \l 12384 MR. WOODLAND: But specific to that total factor productivity methodology, Northwestel doesn't have the data required to do that. There is significant historical data I think over a 10‑year period and particular data, datum, data items are required in order to properly conduct that that aren't available in terms of being specific to Northwestel.
LISTNUM 1 \l 12385 I think there are a number of capital input factors, various national economic factors that aren't available and specific to Northwestel's environment as opposed to Canada as a whole.
LISTNUM 1 \l 12386 MR. HAMELIN: I hope I didn't confuse matters. I was talking about the productivity calculations under the current regime that we are in as opposed to maybe you are talking total factor productivity, that my colleagues talking..
LISTNUM 1 \l 12387 MS LOTT: That is right. Do you consider that the productivity estimate that you arrived at in the response to CRTC‑104 be revised to be representative of what would have been derived using a total factor productivity study for the company as a whole?
LISTNUM 1 \l 12388 MR. WOODLAND: Sorry, could you clarify?
LISTNUM 1 \l 12389 MS. LOTT: The productivity estimates that you produced in your response to the interrog from CRTC‑104 be revised, do you consider that that estimate is representative of what would have been derived had you been using a total factor productivity study for the company as a whole?
LISTNUM 1 \l 12390 MR. WOODLAND: Not having conducted that total factor productivity I really don't know. I mean, keep in mind that our recommended productivity factor is zero, not the result of that calculation. Whether or not a total factor productivity calculation would have come up with zero, I really can't say.
LISTNUM 1 \l 12391 MR. HAMELIN: One thing is for sure though, the costs that have been incurred, particularly since 2001, they are there to stay, they are part of our base right now.
LISTNUM 1 \l 12392 MS LOTT: Okay, thank you for that.
LISTNUM 1 \l 12393 Isn't it the case that offering additional services which share the existing inputs will result in an increase in productivity growth? Would you agree with that?
LISTNUM 1 \l 12394 MR. WOODLAND: Could you be more specific please?
LISTNUM 1 \l 12395 MS LOTT: Well, I guess the context I am looking at is trying to understand what economies of scope are and that those occur when a company is offering multiple services, experiences, but you have declined total average costs because of the number of services offered increases.
LISTNUM 1 \l 12396 MR. WOODLAND: In general that is true, to the extent that the investment can be used for other services. With respect to most of the investment that is in place for residential PES, as an example, that is less the case certainly than say transport investment.
LISTNUM 1 \l 12397 MS CHALIFOUX: And just to clarify as well, I mean the other side of the equation is obviously the corresponding combined output from those services, so again there you have to take that into consideration.
LISTNUM 1 \l 12398 MS LOTT: Maybe I will use a concrete example here. Do you offer high‑speed internet services, DSL services?
LISTNUM 1 \l 12399 MR. WOODLAND: Yes, we do.
LISTNUM 1 \l 12400 MS LOTT: And do both the local voice service and the DSL service make use of the same local loop?
LISTNUM 1 \l 12401 MR. WOODLAND: Yes, that is correct.
LISTNUM 1 \l 12402 MS LOTT: So the local loop would be the shared input in providing both the local voice and the DSL, is that correct?
LISTNUM 1 \l 12403 MR. WOODLAND: In a technical sense, yes. In a costing sense and in a rating sense and in a tariff sense, no. In the tariff sense the residential PES service pays for the loop and now what that does is it says that ADSL only has to be rated or costed without taking into account the loop and that is standard practice everywhere.
LISTNUM 1 \l 12404 MR. ROBERTS: In addition, I would note that quantity is a factor in determining the productivity leveraged and there is a significant impact in the other direction with regard to this and future productivity expectations.
LISTNUM 1 \l 12405 Again, I reiterate the market disruptions associated with the very broad Industry Canada initiatives of BRAND and NSI, they are effectively duplicating our local distribution and transport networks throughout the Northwest Territories, 31 of 33 communities, and 25 of 26 communities in Nunavut. Therefore, we can expect that with a competitive network, with essentially the competitor having a heavily subsidized cost of entry, that there will be significant displacement of services from our network.
LISTNUM 1 \l 12406 And so going forward in four years, if we were to calculate the unit costs of things like Res PES, given the fixed costs that are involved and the high proportion of fixed costs, we could actually see a large per unit cost increase.
LISTNUM 1 \l 12407 So again, you are quite right in pointing out that the leverage of the asset is a factor in determining productivity but I would suggest that given the unique circumstances we face, particularly with regard to these government programs in the vast majority of our communities, it may in fact cut the other way.
LISTNUM 1 \l 12408 MR. WOODLAND: I will just add to that that ‑‑
LISTNUM 1 \l 12409 THE CHAIRPERSON: No, please. The original question was a very simple factual question.
LISTNUM 1 \l 12410 MS LOTT: Yes, I am just asking if you would confirm whether the offering of both the local voice service and the DSL service is an example of an economy of scope.
LISTNUM 1 \l 12411 MR. WOODLAND: Well, I hope that I made clear that I didn't think it was an economy of scope or an economy of scale.
LISTNUM 1 \l 12412 THE CHAIRPERSON: You did, indeed.
LISTNUM 1 \l 12413 Could I just ask the panel? We do appreciate the attempt to paint the total picture for us. It is important that the Commission understand it and we are listening attentively to what you say but you will have other opportunities to make many of the points that you are making.
LISTNUM 1 \l 12414 When a simple, straightforward question is asked, it is appropriate, with reference to that specific question, to try to clarify and assist all of us in understanding the import of it and the implications.
LISTNUM 1 \l 12415 The broader question, I would ask you to exercise some judgment as to whether this is the right moment to introduce the other themes. We have read your evidence. You are going to have final argument. There is a policy panel coming. So please try to help the consumer groups to move through their agenda without unduly loading down the response each time.
LISTNUM 1 \l 12416 And I repeat, it is important that we understand this but we have all made a good faith attempt to listen and to read and we do understand the points you are making but you are going to have other opportunities to makes these points.
LISTNUM 1 \l 12417 MS LOTT: Thank you, Mr. Chairman.
LISTNUM 1 \l 12418 I am now wanting to just confirm what we had gone through previously in my example of using the DSL service and the local voice service.
LISTNUM 1 \l 12419 My understanding is that you had agreed with me that that is an example of a shared input and that you would then agree with me that that is an example of ‑‑ the offering of both those services is an example of economy of scope.
LISTNUM 1 \l 12420 MR. WOODLAND: No, I guess I wasn't clear. I did not agree that that was a shared input. The loop cost is an input only to the cost of residential voice service, is not an input to cost of ADSL.
LISTNUM 1 \l 12421 MS LOTT: If I could just clarify. My question is really just technical. Do both the local voice service and the DSL service make use of the same local loop?
LISTNUM 1 \l 12422 MR. WOODLAND: Yes.
LISTNUM 1 \l 12423 MS LOTT: I am just asking this in a technical sense.
LISTNUM 1 \l 12424 MR. WOODLAND: Yes.
LISTNUM 1 \l 12425 MS LOTT: So it is a shared input in providing both the local voice and the DSL?
LISTNUM 1 \l 12426 MR. WOODLAND: That would depend on what you mean by shared input then, I guess. I take shared input to mean an input to the cost and I would have to disagree.
LISTNUM 1 \l 12427 THE CHAIRPERSON: Look, this is an argument about the economics of telecom, which is the framework within which you are getting a response, and perfectly legitimately so, and the broader economics of a shared asset.
LISTNUM 1 \l 12428 In the context of the broader economics of a shared asset, I daresay that it is a shared input but for purposes of the conventions of telecom costing and pricing ‑‑
LISTNUM 1 \l 12429 MR. WOODLAND: Yes.
LISTNUM 1 \l 12430 THE CHAIRPERSON: ‑‑ and I think this is Mr. Woodland's point ‑‑ it is not a shared asset. The cost of the local loop is recovered or not recovered, as the case may be, within the framework of local telephone service. I think that is the point. Am I correct?
LISTNUM 1 \l 12431 MR. WOODLAND: Absolutely.
LISTNUM 1 \l 12432 THE CHAIRPERSON: So it is not that the panel doesn't want to give an honest answer, it is simply that it is answering in the framework of this curious world of the conventions of telecommunications.
LISTNUM 1 \l 12433 MS LOTT: Okay, thank you.
LISTNUM 1 \l 12434 I am just wondering, how have these types of scope economies in offering multiple services using the same input ‑‑ how have they been reflected in Northwestel's productivity estimate from your response to CRTC 104(b) revised?
LISTNUM 1 \l 12435 MR. WOODLAND: Well, I guess I would say that they haven't ‑‑
LISTNUM 1 \l 12436 MS LOTT: They haven't.
LISTNUM 1 \l 12437 MR. WOODLAND: ‑‑ in that calculation.
LISTNUM 1 \l 12438 MS LOTT: Could you just confirm that?
LISTNUM 1 \l 12439 MR. WOODLAND: Yes.
LISTNUM 1 \l 12440 MS LOTT: Okay, that is all I wanted.
LISTNUM 1 \l 12441 Doesn't the lack of inclusion of these types of scope economy productivity improvements in Northwestel's estimation of productivity represent a shortcoming of Northwestel's methodology?
LISTNUM 1 \l 12442 MR. WOODLAND: It is not our methodology.
LISTNUM 1 \l 12443 MS LOTT: Isn't it the case that under Northwestel's ‑‑ the methodology that all the productivity gains associated with these types of economies of scope accrue to the company since they are not reflected in the target productivity offset?
LISTNUM 1 \l 12444 MR. WOODLAND: Shall I answer this from the telecom perspective or the broadly economic perspective?
LISTNUM 1 \l 12445 THE CHAIRPERSON: Mr. Woodland, anything you can say to help us in respect of either would be good and you should label them as such when you respond.
LISTNUM 1 \l 12446 MR. WOODLAND: In the telecom view, no, because things are very specifically allocated to specific products which are then required or expected to recover those costs.
LISTNUM 1 \l 12447 MS LOTT: All right. Thank you.
LISTNUM 1 \l 12448 I'm going to move on one last area here, just a couple of questions. I wanted to talk about the inclusion of a stretch factor or a consumer productivity dividend.
LISTNUM 1 \l 12449 My question is: Have you proposed to include a stretch factor in deriving your proposed productivity offset?
LISTNUM 1 \l 12450 MR. HAMELIN: Just going to zero merely already we are assuming that it is already included in there.
LISTNUM 1 \l 12451 MS LOTT: So that would be no?
LISTNUM 1 \l 12452 MR. ROBERTS: Again, if you, as you seem to insist, take the service‑specific marginal costing approach, the delta between the result of that study and zero could be taken as a stretch. However, again, the 0 percent that we have proposed going forward is based on a number of factors that you don't seem to want to explore here but that nonetheless would include balance including a form of stretch.
‑‑‑ Pause
LISTNUM 1 \l 12453 MS LOTT: Just one moment.
‑‑‑ Pause
LISTNUM 1 \l 12454 MS LOTT: I'm sorry, it's late in the morning for me and I'm really not clear of whether you are saying that ‑‑ I guess my question again is: Have you proposed to include a stretch factor in deriving your proposes productivity offset?
LISTNUM 1 \l 12455 MR. ROBERTS: Again I would suggest that the 0 percent does include a stretch factor in a balanced approach.
LISTNUM 1 \l 12456 If you again insist on using your methodology, the service‑specific marginal cost, you could imply a specific stretch factor, but we would suggest that it's something that is not specifically quantified in our proposal but is embedded in the 0 percent and the challenge that we have, the magnitude of the stretch, is broadly illustrated by the service‑specific marginal cost studies.
LISTNUM 1 \l 12457 MS LOTT: Isn't it true that Northwestel will experience gains from regulatory streamlining and incentives to be more productive under your proposed framework?
‑‑‑ Pause
LISTNUM 1 \l 12458 MR. ROBERTS: The incentives will exist, as will the challenges that we can underscore in great detail if you would like us to elaborate.
LISTNUM 1 \l 12459 MS LOTT: No, that's fine. Thank you.
LISTNUM 1 \l 12460 Those are my questions, Mr. Chairman. Thank you.
LISTNUM 1 \l 12461 THE CHAIRPERSON: Thank you, Mr. Wylie and Ms Lott. We appreciate it.
LISTNUM 1 \l 12462 Thank you, panel.
LISTNUM 1 \l 12463 We will take a break. All the members of the panel are pleading with me to ensure that there will be a break.
LISTNUM 1 \l 12464 MS LOTT: That's Mr. Briggs, Andrew Briggs.
LISTNUM 1 \l 12465 THE CHAIRPERSON: Briggs, I'm sorry. I know I'm going to get it right one day.
LISTNUM 1 \l 12466 We will rise and we will reconvene at 10 minutes to 11:00.
LISTNUM 1 \l 12467 Thank you.
‑‑‑ Upon recessing at 1033 / Suspension à 1033
‑‑‑ Upon resuming at 1052 / Reprise à 1052
LISTNUM 1 \l 12468 THE CHAIRPERSON: Order, please. A l'ordre, s'il vous plaît.
LISTNUM 1 \l 12469 Madame la Secrétaire.
LISTNUM 1 \l 12470 THE SECRETARY: Merci, Mr. Chairman.
LISTNUM 1 \l 12471 We will call now on Mr. Rondeau from UCG.
‑‑‑ Pause
EXAMINATION / INTERROGATOIRE
LISTNUM 1 \l 12472 MR. RONDEAU: Good morning, ladies and gentlemen. My name is Roger Rondeau. I am President of the Utilities Consumers Group and the representative on their behalf.
LISTNUM 1 \l 12473 Before I move on to other areas of finance, panel, I would like to pursue a little bit more in depth the issue of affordability that I spoke of yesterday that we left off with.
LISTNUM 1 \l 12474 It would seem that the direction of one of the intervenors and one of the Commission Members implied that rates should even go higher. I think it is very important that we get this into a bit better perspective for the Commission.
LISTNUM 1 \l 12475 Yesterday we left off with a debate about tax filer in low categories and it was mentioned by one of the panel that these can be offset by students. I think it was a relevant point.
LISTNUM 1 \l 12476 What I would like you to do now is look at UCG evidence, Exhibit C.
LISTNUM 1 \l 12477 THE CHAIRPERSON: Sorry, Madame la Secrétaire. What is it, Exhibit 1, UCG?
LISTNUM 1 \l 12478 THE SECRETARY: Yes, UCG Exhibit No. 1.
LISTNUM 1 \l 12479 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 12480 MR. RONDEAU: Mr. Chair, it is not the ‑‑
LISTNUM 1 \l 12481 THE CHAIRPERSON: You are talking about your previous exhibit.
LISTNUM 1 \l 12482 MR. RONDEAU: Exactly, yes.
LISTNUM 1 \l 12483 THE CHAIRPERSON: I'm sorry.
LISTNUM 1 \l 12484 MR. RONDEAU: It is an article in one of the newspapers in Whitehorse.
LISTNUM 1 \l 12485 MR. HAMELIN: We have it.
LISTNUM 1 \l 12486 MR. RONDEAU: I have gleaned some of the important issues that I consider the Commission should be aware of from this article, and then I will ask you a few questions.
LISTNUM 1 \l 12487 This article was put in by the Anti‑Poverty Association in the Yukon. They have taken into account that most of the people that are using the food banks have changed substantially in the last number of years. It used to be mostly men, people with disabilities or alcohol problems. Now these banks are being frequented more increasingly by women, the elderly, family, single parents with children basically and the working poor.
LISTNUM 1 \l 12488 When the soup kitchen started at Sacred Heart, approximately ten years ago, it served 30 to 40 people. Now it is serving more than double, anywhere from 85 to 100.
LISTNUM 1 \l 12489 It is the same with the Mary House's emergency food bank.
LISTNUM 1 \l 12490 The Salvation Army emergency food bank, which can be frequented only every five weeks, experienced over 2,000 drops in the last year.
LISTNUM 1 \l 12491 Also, social assistance rates in the Yukon have not increased in 15 years, yet the cost of living has crept up by somewhere in the neighbourhood of 2 percent per year. By the third week of the month, many of the recipients are out of money.
LISTNUM 1 \l 12492 Do you have any comments on this particular article that you would like to bring forward?
LISTNUM 1 \l 12493 MR. ROBERTS: With respect, I would suggest that the Policy Panel may be a better forum for this. The Finance Panel is a little more focused on numbers and such.
LISTNUM 1 \l 12494 Again, with respect, perhaps you could raise that question when the Policy Panel is up.
LISTNUM 1 \l 12495 MR. RONDEAU: That is fine. I will continue, because I think that some of the questions I have are more related to you.
LISTNUM 1 \l 12496 Are Northwestel customers not already paying the higher end of local charges, even with the increase proposed?
LISTNUM 1 \l 12497 MR. HAMELIN: They are at the higher end.
LISTNUM 1 \l 12498 MR. RONDEAU: Would you agree that Northwestel customers should be protected under the statutes of Canada ‑‑ in other words, the Telecommunications Act, specifically section 7?
LISTNUM 1 \l 12499 MR. HAMELIN: Yes.
LISTNUM 1 \l 12500 MR. RONDEAU: Are you aware of the decision by the CRTC in 2002 which capped local resident phone services in southern jurisdictions at the then current rate, which was in the $20 to $30 range?
LISTNUM 1 \l 12501 THE CHAIRPERSON: Mr. Rondeau, apart from my reservations about the accuracy of the premise of your question, I would ask you to try to focus on specific aspects with which the Financial Panel can help us.
LISTNUM 1 \l 12502 I do appreciate your concerns with broad welfare issues, but this is really not the panel to address those questions to.
LISTNUM 1 \l 12503 If you have specific questions that relate to the financial performance of the company, its productivity performance, the relationship between its proposals and its historical experience with respect to issues like pricing and costing and depreciation, then this is the right place. But the broader questions of general welfare ‑‑ it is probably a bit unfair to pose those questions to this panel, who have not prepared themselves to respond to those kinds of questions.
LISTNUM 1 \l 12504 MR. RONDEAU: I only have a few more questions. I will skip this and let the Policy Panel handle these questions.
LISTNUM 1 \l 12505 THE CHAIRPERSON: I think that is appropriate.
LISTNUM 1 \l 12506 You will, of course, be very welcome to pose those questions at that time.
LISTNUM 1 \l 12507 MR. RONDEAU: I will move on to the productivity level.
LISTNUM 1 \l 12508 The response to CRTC‑1301. I gather you would like to see this, so that you have it in context.
LISTNUM 1 \l 12509 MR. HAMELIN: Just a moment, please.
‑‑‑ Pause
LISTNUM 1 \l 12510 MR. HAMELIN: We have the interrog right now.
LISTNUM 1 \l 12511 MR. RONDEAU: Okay. This is in respect to the going in rates for your level of expenses productivity gains using the TIP for the 2007 forecasts, and I read your statements to the Commission says:
"Current framework must be applied as a whole in order to ensure that the balance of interest is not undermined and that the determinations with regard to the reasonableness of rates are valid." (As read)
LISTNUM 1 \l 12512 Could you explain this a bit more for us, please?
LISTNUM 1 \l 12513 MR. HAMELIN: I'm sorry, could you tell me where you are reading from?
LISTNUM 1 \l 12514 THE CHAIRPERSON: Page number, Mr. Rondeau? What page and paragraph number?
LISTNUM 1 \l 12515 MR. RONDEAU: It's a seven‑page response with ‑‑ I'm sorry, maybe I can come back to this a bit later on. I don't have it ‑‑ 13.01.
LISTNUM 1 \l 12516 THE CHAIRPERSON: I think we found in paragraph 3 of page 4.
LISTNUM 1 \l 12517 MR. RONDEAU: Page 4 of 7, yes, that's correct.
LISTNUM 1 \l 12518 THE CHAIRPERSON: Why don't you just re‑read it just to refresh our memory and then we will all be on the same page, Mr. Rondeau, and then you can ask your question.
LISTNUM 1 \l 12519 MR. RONDEAU: Your statement read:
"Current framework must be applied as a whole in order to ensure that the balance of interest is not undermined and that the determinations with regard to the reasonableness of rates are valid." (As read)
LISTNUM 1 \l 12520 THE CHAIRPERSON: And your question is...?
LISTNUM 1 \l 12521 MR. RONDEAU: My question is to explain this, first of all.
LISTNUM 1 \l 12522 THE CHAIRPERSON: Please explain it, rephrase it, rationalize it, help us to understand it.
LISTNUM 1 \l 12523 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12524 MR. ROBERTS: Fair enough. What we are referring to here specifically is the unique nature of Northwestel's transition from our current framework which is one of a kind and separate and apart from any other telecommunications carrier in Canada and to going directly to price caps.
LISTNUM 1 \l 12525 The other companies had, amongst other things, the rate bases split into utility segments and non‑utility I guess, and the focus was on a sub‑set, just a part of their business in examining things like the rate of return, et cetera.
LISTNUM 1 \l 12526 So in Northwestel's case we haven't gone through that process in our transition, we are left with a much more aggressive, much more dramatic transition to price caps.
LISTNUM 1 \l 12527 And we are saying that in order to do this a fair way, you have to take our current framework as a whole and not borrow from the methodology of transitioning the other companies in part and keep other aspects of ours in the mix as well.
LISTNUM 1 \l 12528 So you are mixing two different systems if you don't take all of the elements of our current framework into play, and we are suggesting that that's not appropriate and wouldn't be in the benefit of northerners.
LISTNUM 1 \l 12529 MR. RONDEAU: Okay, I understand, thank you.
LISTNUM 1 \l 12530 Could you give me your definition of reasonableness of rates taken from that statement as well?
LISTNUM 1 \l 12531 MR. ROBERTS: The Telecommunications Act requires that rates be reasonable as deemed by the Commission in weighing all the factors.
LISTNUM 1 \l 12532 MR. RONDEAU: Thank you. Using the TIP methodology, your results are that you have a productivity factor of zero.
LISTNUM 1 \l 12533 My question is how do you expect to become more efficient and cost effective with a TIP of zero ‑‑ this is the major premise or principle of a price cap regime, so how do you expect to become...
LISTNUM 1 \l 12534 MR. ROBERTS: If I may, the TIP methodology is our ‑‑ relates to our current productivity requirement, that's total implied productivity.
LISTNUM 1 \l 12535 I believe what you are referring to is an "x" factor of zero going forward in a price cap regime.
LISTNUM 1 \l 12536 With regard to that, we are acknowledging certainly that there will be isolated opportunities to gain specific gains. However, we are suggesting that that on a net basis, globally across the company, there is a significant challenge and indeed a greater challenge than with other telephone companies in achieving net productivity gains again across the base.
LISTNUM 1 \l 12537 MR. HAMELIN: I would like to add, Mr. Rondeau, that what you are referring to here in this particular interrogatory, the TIP factor of 2 percent has been included in the forecast of 2007. But this is TIP methodology I was trying to distinguish. It is the one that we are using today under our current framework as opposed to the productivity offset that is included in price caps for regulating baskets of services. This is very different concepts in terms of productivity.
LISTNUM 1 \l 12538 MR. ROBERTS: So just to add a little further clarity. When we are testing the reasonableness of the rates, given a revenue forecast and given a return of 10.5 percent, we are using the TIP methodology to test the reasonableness of the rates. Going forward under price caps we would be suggesting that an X factor of zero be employed going forward.
LISTNUM 1 \l 12539 MR. HAMELIN: Just to be clear, the TIP that we are talking about here relates to expenses, it is 2 percent productivity on the expense envelope that is and has been measured on a yearly basis under the current regime by the CRTC and, in fact, made public on the record on a yearly review basis process, that everybody gets to see it and analyze.
LISTNUM 1 \l 12540 So it is very clear that is related to the total expense envelope based on inflation, plus growth, growth being modelled mostly, primarily, by growth and NAS and somewhat with adjustment for ADSL, but essentially it relates to expenses. While the X productivity that we are talking, the price cap, is to govern the pricing of baskets of goods.
LISTNUM 1 \l 12541 MR. RONDEAU: Okay. Could you please look at CRTC 1403. Specifically, what I want you to look at is that you state in here that the companies should have discretion to increase rates of up to a maximum of $1.00 per year.
LISTNUM 1 \l 12542 MR. ROBERTS: That is correct.
LISTNUM 1 \l 12543 MR. RONDEAU: I guess my question is if you have the discretion to raise rates every year, is this really price capping?
LISTNUM 1 \l 12544 MR. ROBERTS: Well, there is a couple of important things here. I would suggest, first, that the dollar would represent a cap. But this also is just the allowable flexibility to change rates. It doesn't necessarily reflect the ability to do so or the desirability, the benefit of doing so. Northwestel's very cognizant of the limits on which it can grow its revenue associated with this service, whether through price increase or through demand increase.
LISTNUM 1 \l 12545 So again, it doesn't mean that that would be the fact. Certainly, after four years it wouldn't make sense to raise rates $4.00. We acknowledge that that would not be something that would be supported by the market. So again, this is with regard to flexibility and it doesn't necessarily mean that that is going to happen.
LISTNUM 1 \l 12546 MR. RONDEAU: Well, I guess my question is why do you need this particular discretion?
LISTNUM 1 \l 12547 MR. ROBERTS: I would suggest that any company would try and maintain the maximum amount of discretion in pricing to the market. Markets dictate prices by and large and we are trying to adopt a framework that is going to have greater reliance on market forces consistent with the trend in the south and the recommendations of the Telecom Policy Review. So we are, again, trying to keep the discretion, the flexibility, but at the same time we are very cognizant of the limits in raising these rates.
LISTNUM 1 \l 12548 MR. RONDEAU: Okay. The intervener before asked questions on the 25 percent mark‑up and I believe the first part of my question here has been answered, which was to give a rationale and you have done your job at that. So I will ask a few questions.
LISTNUM 1 \l 12549 Is the 25 percent mark‑up on all company costs?
LISTNUM 1 \l 12550 MR. HAMELIN: The mark‑up would be there to try and contribute to fixed and common costs. When you are studying something on a Phase II basis, that is a service, right?
LISTNUM 1 \l 12551 MR. WOODLAND: We have specifically applied a 25 percent mark‑up in the calculation of our various subsidy amounts and, as I mentioned previously, in aggregate on the rated products. In other words, the sources of revenue that we have that are not subsidy, in aggregate there would be a 25 percent mark‑up on those, though not necessarily a 25 percent mark‑up on each specific product. So overall, yes. The answer is yes.
LISTNUM 1 \l 12552 MR. RONDEAU: So specifically, the 25 percent mark‑up is added to the NAS costs?
LISTNUM 1 \l 12553 MR. WOODLAND: It is in a calculation of that particular subsidy, yes.
LISTNUM 1 \l 12554 MR. RONDEAU: Now when you do your financial statements, are not your operating costs the true hard costs that you undergo?
LISTNUM 1 \l 12555 MR. HAMELIN: They are the ones that are audited every year by Deloitte.
LISTNUM 1 \l 12556 MR. RONDEAU: Is this mark‑up already added into these costs?
LISTNUM 1 \l 12557 MR. WOODLAND: I am sorry, do you mean is there a mark‑up included in the costs as recorded in the financial statements?
LISTNUM 1 \l 12558 MR. RONDEAU: Correct.
LISTNUM 1 \l 12559 MR. WOODLAND: No.
LISTNUM 1 \l 12560 MS CHALIFOUX: But just to be clear, I mean embedded in your financial ‑‑ your annual financial operating expenses would be elements related to ‑‑ in which the 25 percent mark‑up is intended to recover.
LISTNUM 1 \l 12561 So as we went through this morning with Ms Lott as an example, the depreciation, the annual depreciation, the annual carrying costs associated with fixed structures would be embedded in our financial statements as well as our annual overhead type costs.
LISTNUM 1 \l 12562 MR. RONDEAU: I will move on to cost of service. Could you quickly rationalize for us how you have come up with a figure in your 2006 residential NAS rate being $57.42?
LISTNUM 1 \l 12563 MR. WOODLAND: I am not sure ‑‑ could the Chairman give me some guidance on how expansive to be when answering this?
LISTNUM 1 \l 12564 THE CHAIRPERSON: I think you want to try, Mr. Woodland, to give Mr. Rondeau the kind of general purpose answer in two paragraphs or less that might illuminate him as to what the process is because I know it is a very elaborate and complex one and we don't go into details but I think you are well positioned to provide him with a synthesis thereof.
LISTNUM 1 \l 12565 MR. WOODLAND: Okay. We applied Phase II costing principles to determine the cost of that service and essentially what we look at is what are the pieces of capital investment that are required to provide the service, both in terms of the service in general and those that are specific to demand. Examples of demand‑specific would be line cards in the switch and the actual loops to the house in order to provide that service.
LISTNUM 1 \l 12566 We also look at operating expenses in the same sense, those that are required by the service, things like the billing costs or the customer management costs in the call centres, and then costs that are specific to demand as well.
LISTNUM 1 \l 12567 And then those are all looked at in a perspective incremental basis, and by perspective what we mean is costs as if we had to build the facilities today using today's costs. Incremental says we try to look at it primarily in the sense of what is required to add that one extra customer. There are some exceptions to the incremental approach but I don't think we should go into that at this point.
LISTNUM 1 \l 12568 Then we look at demand over the period that the price cap regime is expected to apply to and add up all those cost pieces over that period, do discounted cash flow analysis on that to determine the present worth of the annual costs and the annual equivalent costs, divide those by the number of NAS that are affected and determine the individual NAS costs.
LISTNUM 1 \l 12569 MR. RONDEAU: Okay. Thank you.
LISTNUM 1 \l 12570 Would you now look at PIAC‑07, specifically page 3?
‑‑‑ Pause
LISTNUM 1 \l 12571 MR. WOODLAND: I have it.
LISTNUM 1 \l 12572 MR. RONDEAU: Specifically paragraph No. 2 where it starts "The Company".
LISTNUM 1 \l 12573 MR. WOODLAND: Oh, okay. Do you have the revised version? On mine that paragraph I think is paragraph 3 but, in any case, go ahead.
LISTNUM 1 \l 12574 MR. RONDEAU: It states:
"The Company also notes that the SIP programmers represents a much larger portion of the total investment than is the case for any southern company. The SIP program represents about 29% of Northwestel's net assets. SIP assets on its own is over 9% of the net assets." (As read)
LISTNUM 1 \l 12575 MR. WOODLAND: Yes.
LISTNUM 1 \l 12576 MR. RONDEAU: My question is: If you would remove the SIP from the NAS, what would the rates be?
LISTNUM 1 \l 12577 MR. WOODLAND: What would the cost be?
LISTNUM 1 \l 12578 MR. RONDEAU: Yes.
LISTNUM 1 \l 12579 MR. WOODLAND: I believe we answered that in the attachment to that particular interrogatory and the costs of residential PES would be $448.42 per month.
‑‑‑ Pause
LISTNUM 1 \l 12580 MR. RONDEAU: Is this using ‑‑
LISTNUM 1 \l 12581 MR. WOODLAND: I'm sorry, I would just like to make one small clarification.
LISTNUM 1 \l 12582 That $48.42 was also calculated using the currently approved service lives, not the proposed ones.
LISTNUM 1 \l 12583 THE CHAIRPERSON I'm still confused, Mr. Woodland.
LISTNUM 1 \l 12584 Could you go through it again, because I didn't get it, just slowly with the details?
LISTNUM 1 \l 12585 MR. WOODLAND: I'm sorry. This particular interrogatory from PIAC asked us to recalculate the RES PES costs without the SIP access lines included,. and also to use the currently approved service lives for access, not the proposed ones, you know, where five of them are being modified, in particular the cable asset being reduced to 20 years from 26.
LISTNUM 1 \l 12586 So the effect of the two things was to take out the cost chunk that is related to SIP access lines and to remove the slight cost increase of impact of the change in service lives that we have proposed. So the net effect was to take the costs from the $57.42 that we have submitted down to this $48.42.
LISTNUM 1 \l 12587 THE CHAIRPERSON Thank you very much.
LISTNUM 1 \l 12588 Excuse me, Mr. Rondeau. We are still a little confused. We want to ask another question on this subject. Excuse us for interrupting you.
LISTNUM 1 \l 12589 MR. RONDEAU: That's fine. That helps me understand as well.
LISTNUM 1 \l 12590 COMMISSIONER CRAM: The difference between the $57 and the $48 is what is the $5.4 million that Mr. Hamelin was talking about in terms of the subsidy.
LISTNUM 1 \l 12591 Is that correct?
LISTNUM 1 \l 12592 MR. WOODLAND: Well, they are associated. You have to go through the calculations of, you know, the difference between rate and cost impacted by the features revenue. You also have to take a long ‑‑ if you are going to take SIP out of the RES PES you have to take along the operating costs and expenses as well. Right? So that gets you the net change in subsidy of $5.4 million. So it's not a direct ‑‑ I just want to be clear that, you know, the amount that this average cost change is not the thing that we would have to look at in determining the shifting around of those subsidy amounts.
LISTNUM 1 \l 12593 COMMISSIONER CRAM: And multiply by the NAS?
LISTNUM 1 \l 12594 MR. WOODLAND: Correct.
LISTNUM 1 \l 12595 COMMISSIONER CRAM: All right. Thank you.
LISTNUM 1 \l 12596 MR. RONDEAU: My next question: When you were cross‑examined by the Consumers Groups in front of me it was noticed that the isolation of the SIP costs would be questioned ‑‑ and that's what I'm doing now ‑‑ to tell us why you would not isolate the capital costs of SIP?
LISTNUM 1 \l 12597 MR. WOODLAND: Well, I guess at the end of the day it's an arbitrary decision. If SIP access costs were to be taken out of RES PES we would propose that they be added to the SIP carrying cost subsidy.
LISTNUM 1 \l 12598 There are two key reasons in my mind for not doing that.
LISTNUM 1 \l 12599 The first is, simply from an administrative perspective, the continuing separate tracking of NAS, whether they are SIP or whether they are non‑SIP NAS, over time would become more and more difficult and more and more of a burden to manage, both for the company and for the Commission and interested parties.
LISTNUM 1 \l 12600 The other reason is that in our view the addition of SIP NAS really truly represents a change in the average cost of our NAS. We don't manage SIP NAS any differently going forward. We dispatch technicians in exactly the same fashion.
LISTNUM 1 \l 12601 Everything that we do about taking care of them and ultimately replacing those investments is exactly the same.
LISTNUM 1 \l 12602 So from our perspective, it makes a lot more sense to roll them in.
LISTNUM 1 \l 12603 Yes, we recognize the bump in costs that that has caused.
LISTNUM 1 \l 12604 I will point out that, from my understanding, Bell does manage all of its NAS as a pool essentially. So all SIP NAS are considered to be just part of the overall NAS pool.
LISTNUM 1 \l 12605 I don't know that they go to the extent that we have in terms of trying to incorporate SIP‑specific costs into that assessment. But at the same time, they don't have anywhere near the materiality of that cost impact.
LISTNUM 1 \l 12606 MR. HAMELIN: Mr. Rondeau, I would like to add just for clarity, that bump in costs that we are talking about, $28 million of the SIP program has been associated to the access and NAS and 2,800 lines have either been upgraded, if you will, from an underserved perspective or really added to our NAS base.
LISTNUM 1 \l 12607 That is $10,000 of investment per NAS due to that piece of the SIP program.
LISTNUM 1 \l 12608 Overall, our total investment per NAS, our gross investment is the $7,500, as you see in our evidence, which is at least almost three times, on average, just about anybody else's NAS investment in the country.
LISTNUM 1 \l 12609 Anyway, I just wanted to make that point clear. We have added to our cost base $10,000 NAS costs.
LISTNUM 1 \l 12610 MR. RONDEAU: I understand that; thank you.
LISTNUM 1 \l 12611 Do you not have to isolate SIP to get your supplementary funding in order?
LISTNUM 1 \l 12612 MR. HAMELIN: Today the regime ‑‑ and this is a concept I was trying to clarify earlier this morning.
LISTNUM 1 \l 12613 Under the current regime the SIP carrying costs are obviously in our actuals that you referred to just a moment ago, and those costs do not disappear.
LISTNUM 1 \l 12614 Under the current regime, some folks may think that the supplementary funding is there to finance the SIP program. Well, this is not the case.
LISTNUM 1 \l 12615 The SIP program, let me tell you $85 million, I had to go ‑‑ we, the company, had to go to the market and raise some bonds, if you will, to meet this excess capital program, if you will, over this last five‑six years. Twice in fact I went to the bond market and raised $20 million for 20 years one year and $15 million for ten years another year.
LISTNUM 1 \l 12616 Let me assure you that when you are raising these funds, I get grilled for several hours from those that are investing with us as to will they ever see these monies 20 years later.
LISTNUM 1 \l 12617 To be frank, I cannot hide the SIP program from them. I tell them it is totally uneconomic, but not to worry, there is this regulatory bargain that comes into play.
LISTNUM 1 \l 12618 Suffice to say that they have confidence and we go ahead and raise those funds. It is an important piece that I just want you to understand.
LISTNUM 1 \l 12619 MR. RONDEAU: Yes. Thank you.
LISTNUM 1 \l 12620 Were any of these SIP capital costs directly for the Whitehorse or Yellowknife area?
LISTNUM 1 \l 12621 MR. HAMELIN: Actually, they served multiple places.
LISTNUM 1 \l 12622 Could you give me a second? We do have some details on this.
LISTNUM 1 \l 12623 MR. RONDEAU: Yes.
‑‑‑ Pause
LISTNUM 1 \l 12624 MR. WOODLAND: The answer is yes. There are a number of NAS in the Whitehorse and Yellowknife areas that were served by SIP.
LISTNUM 1 \l 12625 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12626 MR. WOODLAND: I don't have the specific numbers at hand.
LISTNUM 1 \l 12627 MR. HAMELIN: And Ray Wells will be in a much better position to answer that in the Policy also.
LISTNUM 1 \l 12628 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12629 You mention in your proposal some new SIP programs. My question is, are these all absolutely necessary, or are they now what I would call cream?
LISTNUM 1 \l 12630 MR. HAMELIN: No, they are absolutely necessary.
LISTNUM 1 \l 12631 Again, Mr. Wells would be in a much better position to add to this, but suffice it to say that it would be a lesser level of the current SIP program, which was extremely beneficial to the North, and which allowed us to be able to bring broad service objectives into play.
LISTNUM 1 \l 12632 There are still 22 switches that would need upgrade that I do know about. We just have a little bit further to go, if you will.
LISTNUM 1 \l 12633 Again, the program can be much better explained by Mr. Wells.
LISTNUM 1 \l 12634 Again, it is mostly for basic services. All of it, actually, is for basic service objectives, which, by the way, are somewhat curtailed. When you think of CMS features, for example, they are not available ubiquitously across all of our territory, simply because of the nature of the cost associated with each switch.
LISTNUM 1 \l 12635 When you consider the density of switches per NAS, I think we are probably one of the highest switches per NAS in the country, and in North America.
LISTNUM 1 \l 12636 MR. RONDEAU: In the same area, in cost of service, you mentioned that there is a cost to a new billing and customer care system. My question is, would this not be considered part of your productivity factor?
LISTNUM 1 \l 12637 Why was this added on to your cost of service?
LISTNUM 1 \l 12638 MR. WOODLAND: I am not sure that I understand. Could you help me understand the distinction you are seeking between being part of productivity or being part of the cost of service?
LISTNUM 1 \l 12639 MR. RONDEAU: I am asking if this should not be in the productivity area. That is what I am asking.
LISTNUM 1 \l 12640 In your savings.
LISTNUM 1 \l 12641 MR. WOODLAND: I will try to be a bit more broad in answering the question.
LISTNUM 1 \l 12642 As a company with 70‑some‑odd thousand NAS customers and 100,000 residents to serve, and 96 communities, like any telco, we rely on large systems to manage our business. Those systems are required to maintain customer information, to perform billing functions, to collect data from switches, and rate toll calls, and all kinds of things like that, and they are quite properly, in my view, considered to be a part of the cost of providing those services.
LISTNUM 1 \l 12643 MR. RONDEAU: The last part for cost of service is, yesterday, and a bit more today, we spoke of your NAS lines basically being flat in the last number of years.
LISTNUM 1 \l 12644 Is that correct?
LISTNUM 1 \l 12645 MR. HAMELIN: Yes, that is correct.
LISTNUM 1 \l 12646 There is some common phenomenon down South too. A lot of it could be attributed to cellular services and displacement from ADSL services.
LISTNUM 1 \l 12647 MR. RONDEAU: Do you not have an increase in second and third lines being installed in the more affluent family homes?
LISTNUM 1 \l 12648 MR. HAMELIN: It is exactly the reverse. The more ADSL that becomes available, the more displacement you get, particularly from second lines.
LISTNUM 1 \l 12649 I am thinking of those that only have access to dial‑up internet, as we call it. As soon as ADSL or something of the kind becomes available, they can save on the second line in order to pay partly for the ADSL service.
LISTNUM 1 \l 12650 MR. WOODLAND: Just to be clear, as well, adding a second line to a home doesn't change the unit cost of that second line. Because of the very nature of Phase 2 costing, we have determined what the incremental costs are per line, so the second line would double the cost, effectively.
LISTNUM 1 \l 12651 MR. RONDEAU: Getting into a bit more of the financials, I guess the best thing would be to have you have UCG‑11 in front of you, which are financial statements.
LISTNUM 1 \l 12652 You will also need the exhibit that was handed out this morning, but there are other areas. UCG 1.1 is the financial statement and also PAC 18.
LISTNUM 1 \l 12653 THE SECRETARY: The exhibit that Mr. Rondeau is talking about is ‑‑ I just distributed it this morning, it's UCG Exhibit No. 1.
LISTNUM 1 \l 12654 MR. RONDEAU: It's a page ‑‑
LISTNUM 1 \l 12655 THE SECRETARY: It's called ‑‑ I'm sorry. It's called from Northwestel Yearly Financial Statements in million of dollars.
LISTNUM 1 \l 12656 MR. HAMELIN: I have that.
LISTNUM 1 \l 12657 COMMISSIONER CRAM: And the other document you were referring to is an interrog?
LISTNUM 1 \l 12658 MR. RONDEAU: They are both in the interrogatories, both UCG 1.1 and PAC 18, and they are both financial statements. One is 2004, one's 2005.
LISTNUM 1 \l 12659 MR. HAMELIN: I have them, Mr. Rondeau.
LISTNUM 1 \l 12660 MR. RONDEAU: Thank you. If we just look at the new exhibit given to you this morning, this is long‑range numbers that I've taken out of the financial statements.
LISTNUM 1 \l 12661 Now, it shows in this form that you've had a very healthy increase in your revenues yearly. Is that correct?
LISTNUM 1 \l 12662 MR. HAMELIN: I'm just unclear. We're talking the years 1991 to 2007, this document?
LISTNUM 1 \l 12663 MR. RONDEAU: Yes.
LISTNUM 1 \l 12664 MR. HAMELIN: And you're talking the revenue line?
LISTNUM 1 \l 12665 MR. RONDEAU: Yes.
LISTNUM 1 \l 12666 MR. HAMELIN: It appears to be, just looking at this, and I only got it just this morning, that what we have here are consolidated results.
LISTNUM 1 \l 12667 Now, from 1991 to 1995 you'd see telco results only; 1996 we purchased cable TV in Yellowknife; 1997 we spun off NMI as a subsidiary.
LISTNUM 1 \l 12668 So, 1998, 1999, 2000, 2001, 2002 would be consolidated results that will incorporate mobility and cable.
LISTNUM 1 \l 12669 In 2003 you revert back to only cable and telco because we sold Mobility on January 1, 2003 and, therefore, onwards, 2004, 2005, '06 and '07 you'd have just telco and cable.
LISTNUM 1 \l 12670 Now, to help you put this in perspective, cable TV ‑‑ and we do have ‑‑ we have operations, as was mentioned, in Yellowknife, we have one in Fort Nelson and we also have one in ‑‑ pardon me, Norman Wells we said yesterday, but we also have one in Fort Nelson, a small operation there.
LISTNUM 1 \l 12671 I guess it was discarded in Mr. Walker's comments simply because I guess Telus was suggesting that, you know, competition in northern B.C., them being present wouldn't count.
LISTNUM 1 \l 12672 But, in any event, what I'm saying here is you've got consolidated results for cable and telco, and cable in totality represents something like three per cent of the revenue that's buried here.
LISTNUM 1 \l 12673 So, the lion's share of these results really are telco, one might say. So, I just wanted to make sure we were clear as to what the nature of these...
LISTNUM 1 \l 12674 As you see it in terms of profits too ‑‑ I'm sorry, my colleague is trying to say something to me here.
LISTNUM 1 \l 12675 2006 and 2007 are telco, but the whole document though deserves some clarity.
LISTNUM 1 \l 12676 In 2002 you can see that the profits are showing at 18‑million, which is the highest it's peaking there but that's because, again, that was the last year you had mobility buried in these data. Afterwards you revert back to just cable and telco.
LISTNUM 1 \l 12677 MR. RONDEAU: I understand that all these things happened.
LISTNUM 1 \l 12678 MR. HAMELIN: I'm sorry, one point of clarify, Mr. Rondeau.
LISTNUM 1 \l 12679 My colleagues are correct in saying that 2006 and 2007 are Telco only from the data that is presented here, but previous material is all ‑‑
LISTNUM 1 \l 12680 MR. RONDEAU: Yes, one of the reasons why I presented this is that I realize you would say this. I guess my question is how can the regulator get a hold on all of this when you have had all these transitions in your financials through the number of years? These numbers are all skewed.
LISTNUM 1 \l 12681 MR. HAMELIN: No, these ‑‑
LISTNUM 1 \l 12682 THE CHAIRPERSON: Well just a minute, Mr. Hamelin. Mr. Rondeau, these numbers are the product of accounting conventions and these accounting conventions have to be observed by anyone who operates in the way that Northwestel operates. And it is perfectly legitimate for you to ask questions to understand them, but I don't think that you can ask the panel to justify them in someway, because all they are doing is reporting according to generally accepted accounting principles.
LISTNUM 1 \l 12683 MR. RONDEAU: Fair enough, Mr. Chair.
LISTNUM 1 \l 12684 I guess what I would like you to concentrate on is the net income, what I would like to focus on. This is your profits, is that correct?
LISTNUM 1 \l 12685 MR. HAMELIN: That is correct.
LISTNUM 1 \l 12686 MR. RONDEAU: The return for your investors?
LISTNUM 1 \l 12687 MR. HAMELIN: The net income does belong to the shareholder and it is yielding on a Telco basis as we see there in 2006, 10.9 per cent on a forecasted basis and 10.5 on a forecasted basis also for 2007, although the two regimes would differ significantly, here one being ROR and the other one being price caps.
LISTNUM 1 \l 12688 MR. RONDEAU: Do you consider this to be a fair and reasonable return for your investors?
LISTNUM 1 \l 12689 MR. HAMELIN: Well, I think it is a very reasonable approach that we are proposing for 2007. In the case of 2006, frankly I am not sure how you got 10.9 per cent ROE because our budget is normally at the mid point of the allowed range, which is 10 and a half.
LISTNUM 1 \l 12690 But what is noticeable, very noticeable between 2005, 2006, 2007, as you can see we are not proposing changes in profits here. Really, the essence of this proposal has to do with sustainability, has to do with rate restructuring, displacing implicit subsidies today and making them explicit.
LISTNUM 1 \l 12691 You know, when we think of the rate of return system that we have today, if I go back five, six years ago when it was decided, nobody was picking at specifics, if you will, of the whole regime. It is a whole package, a comprehensive package. It would be very easy as a finance person to say well I don't want to do SIP, but I will keep the rate increase of $5.00 that you have on business and $3.00 on RES.
LISTNUM 1 \l 12692 No, no, we have accepted the whole package plus the commitment, the commitment that we were entrusted of spending over $85 million. In fact, the original budget was maybe within slightly less than that. But suffice it to say, it was a very good forecast of what our capital program might be over five, six years. We lived within it, we delivered, we reported the NAS, you name it, everything was there and we committed to that package.
LISTNUM 1 \l 12693 Today, what we are saying is we are proposing a package and there is a variety of packages that could be presented. You know, you can tweak on depreciation here and you can tweak on CAT here and you can tweak.. At the end of the day what we present is a cost base on cost‑based principles a subsidy, and these costs are not going to go away, they are there today, they are buried in our actuals.
LISTNUM 1 \l 12694 All we are saying is retweak the rates in such a way that, you know, we have a package here that we can go forward with and presumably you have a sustainable, a much more streamlined regulatory framework that everyone would benefit from and without exaggerating, you know, where we are at today. The profits are the same. It is very key for you to understand this. All we are talking about really is a reflection of the mix in revenue.
LISTNUM 1 \l 12695 MR. RONDEAU: I understand.
LISTNUM 1 \l 12696 Let us look a little bit more specifically at the operating expenses. You stated that 2005, 2006, 2007 are simply the telcos; is that correct?
LISTNUM 1 \l 12697 MR. HAMELIN: 2006 ‑‑ subject to check ‑‑ just hold on a second, this shouldn't take long.
LISTNUM 1 \l 12698 MR. RONDEAU: Five, six ‑‑ '05, '06 and '07.
‑‑‑ Pause
LISTNUM 1 \l 12699 MR. HAMELIN: 2005 and '06 are telcos. Yes, that is what I am being told.
LISTNUM 1 \l 12700 MR. RONDEAU: Okay. Can you please look at UCG‑13 where you explain cost moderations in our IR? Now ‑‑
LISTNUM 1 \l 12701 MR. HAMELIN: Just a moment, please.
LISTNUM 1 \l 12702 MR. RONDEAU: You may not necessarily need these in front of you. My question is, these techniques that you have stated in this IR to moderate your costs, should not these techniques reduce your operating costs? I see an increase in those three years in your operating costs. If you are implementing cost moderations, I would assume in most businesses it lowers.
LISTNUM 1 \l 12703 MR. ROBERTS: These are individual productivity gains in isolation. One has to consider the net productivity gain, I guess is the way you describe it, and there were other items where costs went up and they more than offset, I would suggest, the gains that were identified here.
LISTNUM 1 \l 12704 So it is not that Northwestel is saying there are no productivity gains to be had on an isolated specific project‑by‑project basis but rather that our challenge is achieving material net productivity gains.
LISTNUM 1 \l 12705 MS CHALIFOUX: And just sort of to be clear, Mr. Rondeau, operating expenses are, yes, impacted by productivity gains but also just by general price increases in the market, in the industry, goods that we buy as well as by demand drivers. As you are ‑‑ for instance, demand for certain services grows as does the cost needed to maintain and provide those services grow as well. So a number of drivers impact the level of operating expenses.
LISTNUM 1 \l 12706 MR. ROBERTS: If I could give you maybe a specific example of how gains would be undermined. Given our small base and given the high‑cost nature, the unique nature of our territory, we have instances like the replacement of a dish.
LISTNUM 1 \l 12707 We had a 9‑metre dish in one of our remote communities essentially blown over by a very extreme storm. We had to charter a 737 to fly in a new dish. So as you can imagine, the costs associated with doing something like that in a community which is already not contributing positively to the base can dramatically undermine things.
LISTNUM 1 \l 12708 Another company that is faced with that kind of challenge could just take one of their trucks and move the dish in and it wouldn't necessarily be as big a dish either due to the latitude.
LISTNUM 1 \l 12709 So we have these specific high‑cost instances that can undermine our gains and given the vast distances that we have in our territory, our exposure to things like these climactic events is much higher. So this will happen more often for Northwestel than a comparable SILEC for instance.
LISTNUM 1 \l 12710 MR. RONDEAU: Okay. The next concern we have is the area of depreciation, the write‑offs. This chart in front of you shows that depreciation costs have almost tripled since 1991. Can you give us the reasons?
LISTNUM 1 \l 12711 MR. HAMELIN: They are filed every year. Every year we file with the Commission a depreciation study with our expert Dr. Aly Elfar. These are submitted every year and they are sometimes accepted and sometimes not.
LISTNUM 1 \l 12712 MS CHALIFOUX: Just to elaborate, the depreciation accruals are driven by obviously the nature and the degree of our investment base, as well as the asset lives that Mr. Hamelin was alluding to there.
LISTNUM 1 \l 12713 MR. RONDEAU: Could you now look at UCG‑11, specifically page 14? It's the interest payments made on your various loans.
LISTNUM 1 \l 12714 MR. HAMELIN: What page, I'm sorry?
LISTNUM 1 \l 12715 MR. RONDEAU: Page 14.
LISTNUM 1 \l 12716 MR. HAMELIN: I have it. It's our schedule of long‑term bond?
LISTNUM 1 \l 12717 MR. RONDEAU: Yes. Now, when you take loans like this, you only make payments on the interest, is that correct not on the principal?
LISTNUM 1 \l 12718 MR. HAMELIN: That's correct.
LISTNUM 1 \l 12719 These are unsecured debentures. You pay interest on them, generally on a semi‑annual basis, some quarterly, and a balloon payment at the end for the total principal at maturity.
LISTNUM 1 \l 12720 MR. RONDEAU: At maturity you pay the total amount. Okay.
LISTNUM 1 \l 12721 Is there a reason why this is done this way?
LISTNUM 1 \l 12722 MR. HAMELIN: The company has been able to raise these bonds in this fashion on the market. By the way, we are the sole ‑‑ we raise our funds individually, i.e. ‑‑ I wouldn't say individually, but what I'm saying is there is no help from anyone in this. We raise our funds under our own merits.
LISTNUM 1 \l 12723 Some of these funds, they are not guaranteed because the performance of the company to date has been such that we were able to sustain this capability of raising funds, which is very important when you consider the level of the capital program that we have. So the income record that you just provided us on the previous page shows stability and provides confidence to the investment community and this is what we have in front of us. We were able to raise all these funds.
LISTNUM 1 \l 12724 Now, all of these, by the way, are mostly held by insurance companies, just out of interest.
LISTNUM 1 \l 12725 MR. RONDEAU: There is a portion in here also on American loans.
LISTNUM 1 \l 12726 Why are their interest rates so much higher?
LISTNUM 1 \l 12727 MR. HAMELIN: This has to do with the purchase of the company. This company was purchased by BCE on December 1, 1988 and it was purchased from ‑‑ it was a subsidiary of CN. In fact, the company was incorporated I believe in '79. I guess CN was in financial difficulty and decided to sell the corporation and BCE was successful in purchasing it.
LISTNUM 1 \l 12728 As part of the purchase, these U.S. bonds ‑‑ which I gather CN had operations not just in Canada but also in the U.S. ‑‑ were part of the balance sheet of the company that was being sold. So it was not a matter of negotiations or anything, it was just there. It's what is. This is buyer beware, it is what you are buying, it is these U.S. bonds.
LISTNUM 1 \l 12729 Now, I should mention, as part of ‑‑ well, I will stop there. These are the bonds at the time of the purchase.
LISTNUM 1 \l 12730 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12731 Please look at page 17 of this same document where you talk about ‑‑ where it states:
"Lease operating and capital to invest in direct ownership." (As read)
LISTNUM 1 \l 12732 Is it cheaper to lease operating and capital than to invest in direct ownership is my question?
LISTNUM 1 \l 12733 MR. HAMELIN: Are you talking capital leases?
LISTNUM 1 \l 12734 MR. RONDEAU: Yes.
LISTNUM 1 \l 12735 MR. HAMELIN: Capital leases are simply an accounting entry here that suggests that given the nature of the lease that you are getting into, rather than it being an operating lease, it is classified as a capital lease. And it is one of three conditions.
LISTNUM 1 \l 12736 To make it simple, just imagine when you are renting a car for a couple of days. You are leasing a car for a couple of days. It is an expense.
LISTNUM 1 \l 12737 But if you are leasing a car for six, seven years, you are more than perhaps 75 percent of the life of the car; or if there is a bargain option at the end of the lease; or as a third thing is if 90 percent in terms of present value of the current market value of the car, it would be classified as a capital lease.
LISTNUM 1 \l 12738 What it means is instead of you going and buying it outright, you have found another banker, which is the lessor, and you have to enter in an agreement. It is a long‑term payment program as opposed to you borrowing at the bank and being able to buy it cash and registering it in your books as a capital. It is just a different banker.
LISTNUM 1 \l 12739 MR. RONDEAU: So depending on the time, it would be cheaper to invest in direct ownership if it was for a long term.
LISTNUM 1 \l 12740 Is that what you are stating?
LISTNUM 1 \l 12741 MR. HAMELIN: There are various reasons why one enters into leases. It could be obsolescence, for example. You could buy computer equipment that you don't want to be ‑‑ you may enter in a capital lease but you don't want to be tied in terms of ownership.
LISTNUM 1 \l 12742 There are different reasons or rationale as to why you get into capital leases.
LISTNUM 1 \l 12743 MR. ROBERTS: To make it very clear, going back to that rental car example, if you only need a car for one day it doesn't make sense to buy it. It is no more effective.
LISTNUM 1 \l 12744 MR. RONDEAU: Yes, I understand that.
LISTNUM 1 \l 12745 Who are these leases from, the majority of them?
LISTNUM 1 \l 12746 MR. HAMELIN: Are you talking operating or capital? I mean, we do lease ‑‑ just a second. Maybe I can get some clarification.
LISTNUM 1 \l 12747 THE CHAIRPERSON Mr. Rondeau, what are you trying to get at here?
LISTNUM 1 \l 12748 MR. RONDEAU: I'm trying to find out if these leases are from affiliates specifically.
LISTNUM 1 \l 12749 THE CHAIRPERSON: That is a clear question.
LISTNUM 1 \l 12750 MR. HAMELIN: For example, we lease vehicles, our fleet. Most of our vehicles are on a lease basis with Ford Motor Company.
LISTNUM 1 \l 12751 MR. RONDEAU: There are none of these, in other words, with your affiliates, with your mother corporation.
LISTNUM 1 \l 12752 MR. HAMELIN: We are not renting from our mother ‑‑ we are a self‑sustaining company. And if we did, it would be at tariff rates and market rates.
LISTNUM 1 \l 12753 I'm not sure where...
LISTNUM 1 \l 12754 MR. RONDEAU: That's fine.
LISTNUM 1 \l 12755 THE CHAIRPERSON: Mr. Hamelin, it is clear what he wanted. He wants to know whether any of your capital or operating leases, or any significant capital or operating leases are with any affiliates of your parent company.
LISTNUM 1 \l 12756 I think you have answered and you have said no.
LISTNUM 1 \l 12757 MR. HAMELIN: Well, we do have a long‑term contract let's say with Telesat in terms of transponders. They are kind of a sister company.
LISTNUM 1 \l 12758 But I can assure you they are at tariff rates.
LISTNUM 1 \l 12759 MR. RONDEAU: On page 19 of this same document, in an IR to UCG you responded that there were no loans to affiliates at this present time.
LISTNUM 1 \l 12760 My question is: Did you have loans prior to your affiliates?
LISTNUM 1 \l 12761 MR. HAMELIN: We did. I think you are referring here to 17(h). Is that it?
LISTNUM 1 \l 12762 And that would be very easily explainable.
LISTNUM 1 \l 12763 MR. RONDEAU: The one for $21 million?
LISTNUM 1 \l 12764 MR. HAMELIN: Yes. What that was had to do with a transfer price, a transfer of Part 6 taxes related to preferred shares with Bell Canada.
LISTNUM 1 \l 12765 To make a long story short, it is taking advantage of tax arbitrage. If you have a subsidiary that is paying a higher level rate of tax than yourself, given that there are withholding taxes on preferred shares, BCE was able to pass on to us an arrangement in such a way that, on a net basis ‑‑ on a net‑net basis ‑‑ BCE paid less taxes.
LISTNUM 1 \l 12766 But, in the end, for us to do that, they had to loan us moneys, and it was at a zero rate, and it all gets cleaned up in the wash as part of the review each year. When we do the ROE calculations we have to show the Commission exactly what is in the base, what has been added, and what has been subtracted. This was a temporary loan to make that happen.
LISTNUM 1 \l 12767 There is virtually no impact on the performance of the regulated telco basis of Northwestel in doing this, but it does give an advantage of a couple of points.
LISTNUM 1 \l 12768 MR. RONDEAU: I'm sorry, did you say it was at zero percent interest?
LISTNUM 1 \l 12769 MR. HAMELIN: It may have been tweaked at 2 or 3 percent.
LISTNUM 1 \l 12770 It was 3.5 percent.
LISTNUM 1 \l 12771 MR. RONDEAU: That was my question. Thank you.
LISTNUM 1 \l 12772 MR. HAMELIN: That was to make sure, though, that it was to offset any interest being charged by Revenue Canada to us and/or received by us, in such a way that it would net out totally to zero from an operating point of view and ROE calculation.
LISTNUM 1 \l 12773 It was marginal. It was just to take care of the interest payments on the receipt of funds from Revenue Canada, when they are sending things with interest. We didn't want to calculate interest that was received on behalf of our parent on a tax return, so we imputed ourselves an interest rate of 3.5 to make sure it came out to zero.
LISTNUM 1 \l 12774 MR. RONDEAU: Could you go to page 2 of the same document, "Consolidated Statement of Contributed Surplus".
LISTNUM 1 \l 12775 It says that in 2004 this was $56 million. I have no idea what this contributed surplus means.
LISTNUM 1 \l 12776 What I want to ask you is, how does this affect the bottom line of the company?
LISTNUM 1 \l 12777 MR. HAMELIN: No, it does not impact. It is removed from the ROE calculation.
LISTNUM 1 \l 12778 In a nutshell, to explain this, when BCE purchased this company on December 1, 1988, CN, given that it was previously in a very difficult financial situation and was a Crown corporation, paid taxes on a consolidated basis.
LISTNUM 1 \l 12779 What that means is that you are not looking at your individual subsidiaries as legal persons, as we do here under Northwestel ‑‑ BCE is not a Crown corporation.
LISTNUM 1 \l 12780 What that meant is, because CN was in a loss position, it did not have to use the depreciation for tax purposes to shelter income. Therefore, all of its assets that were being depreciated, not just from an accounting point of view but unused from a tax perspective, built up a reserve, an unused asset, an intangible asset, which became, in essence, part of the valuation of BCE purchasing Northwestel as a corporation.
LISTNUM 1 \l 12781 In the end, what you are getting is, effectively, a tax break in a given year, once BCE bought it, because it was able to shelter total income from previous unused tax sheltering that it purchased from CN.
LISTNUM 1 \l 12782 So it called this "contributed surplus".
LISTNUM 1 \l 12783 Essentially, it is part of, if you will, an equity base that you will be able to realize over time, on a gradual basis, following tax rules.
LISTNUM 1 \l 12784 I am not sure if that makes it clear for you.
LISTNUM 1 \l 12785 Instead of paying the taxman, you issue a special dividend to BCE. In fact, you see that in all of our statements. You see the regular dividend and you see the special dividend. That special dividend is simply the realization of unused capital sheltering for depreciation purposes by the previous owner.
LISTNUM 1 \l 12786 MR. RONDEAU: Thank you. Could you please turn to Northwestel 300 tab, page 1, the appendix.
LISTNUM 1 \l 12787 And what it is that I'm going to ask ‑‑
LISTNUM 1 \l 12788 COMMISSIONER CRAM: I'm sorry...
LISTNUM 1 \l 12789 MR. RONDEAU: But you may not necessarily need it in front of you.
LISTNUM 1 \l 12790 What I'm going to ask you is ‑‑
LISTNUM 1 \l 12791 COMMISSIONER CRAM: Mr. Rondeau, please, could you tell me, you said Northwestel 300?
LISTNUM 1 \l 12792 MR. RONDEAU: Yes, tab 300.
LISTNUM 1 \l 12793 COMMISSIONER CRAM: So, is that in their evidence?
LISTNUM 1 \l 12794 MR. RONDEAU: That's in the first RORs.
LISTNUM 1 \l 12795 COMMISSIONER CRAM: Like, the interrogatory is from whom to Northwestel?
LISTNUM 1 \l 12796 MR. RONDEAU: I'm sorry, I'm not absolutely sure. Maybe we don't need this.
LISTNUM 1 \l 12797 COMMISSIONER CRAM: Okay.
LISTNUM 1 \l 12798 MR. RONDEAU: What I'm requesting is ‑‑ I think I have it in front of me here ‑‑ attachment 1.
LISTNUM 1 \l 12799 MR. WOODLAND: Could that be CRTC 300?
LISTNUM 1 \l 12800 MR. RONDEAU: I think it possibly is.
LISTNUM 1 \l 12801 MR. WOODLAND: Or do they start at 301? There's no such thing, okay.
LISTNUM 1 \l 12802 MR. RONDEAU: What I'm after is that the revenues ‑‑ your revenues forecasted are to drop by $22‑million approximately in 2007. Is that correct?
LISTNUM 1 \l 12803 MR. HAMELIN: It's more like 27, I think.
LISTNUM 1 \l 12804 MR. WOODLAND: Are you talking about 301?
LISTNUM 1 \l 12805 THE CHAIRPERSON: Mr. Rondeau I think is interested in talking about what looks precipitously to the naive observer as a dramatic reduction in your revenues.
LISTNUM 1 \l 12806 You're going to explain that it is something a little different than that. I think that is what you are looking for?
LISTNUM 1 \l 12807 MR. RONDEAU: Yes.
LISTNUM 1 \l 12808 THE CHAIRPERSON: Is that it, Mr. Rondeau?
LISTNUM 1 \l 12809 MR. RONDEAU: That's ‑‑
LISTNUM 1 \l 12810 MR. WOODLAND: CRTC 301 seems to show that.
LISTNUM 1 \l 12811 THE CHAIRPERSON: Okay. Let's ‑‑ but I don't think Mr. Rondeau has it. So, Mr. Rondeau, why don't you just focus on the substance of what you are trying to discover from the panel.
LISTNUM 1 \l 12812 You can even express it in the most general possible terms and we will work down to the specifics if necessary.
LISTNUM 1 \l 12813 MR. RONDEAU: CRTC 301.
LISTNUM 1 \l 12814 THE CHAIRPERSON: Okay, great.
LISTNUM 1 \l 12815 MR. RONDEAU: The specifics for this, I just want to get a handle on ‑‑ or a brief explanation from the panel on why this dramatic drop, be it 22‑million or 27‑million.
LISTNUM 1 \l 12816 MS CHALIFOUX: Sure. I mean, the dramatic drop in revenues in 2007 are primarily to do with our rate proposal, our proposals to remove some of those implicit subsidies in areas like the carrier access tariff rate, proposing to decrease from 7‑cents to .825‑cents, so it's probably the largest example of that.
LISTNUM 1 \l 12817 MR. RONDEAU: Solely the CAT rate or any other areas?
LISTNUM 1 \l 12818 THE CHAIRPERSON: You have evidence where you lay out in detail all the puts and takes.
LISTNUM 1 \l 12819 Would it just be possible for you to find that evidence and refer Mr. Rondeau to it, maybe even give him a copy so that he can eyeball it and then if he has questions on that he could ask them, because he is in fact ‑‑ we are, in fact, going over ground that has been well covered in the existing documentation for the proceeding.
LISTNUM 1 \l 12820 MR. RONDEAU: Thank you. That would be fine.
LISTNUM 1 \l 12821 THE CHAIRPERSON: Do we have it at hand, something we can just put in front of Mr. Rondeau here?
LISTNUM 1 \l 12822 MR. WOODLAND: Yes, we do. They're just digging it out.
LISTNUM 1 \l 12823 THE CHAIRPERSON: Terrific, thank you.
LISTNUM 1 \l 12824 You can wait, Mr. Rondeau. They are going to give it to you and then you can ask questions ‑‑ you can look at it and you can ask questions on it.
LISTNUM 1 \l 12825 MR. RONDEAU: Fine.
LISTNUM 1 \l 12826 THE CHAIRPERSON: I think it is going to be a matter of a minute here, so let's hang on.
LISTNUM 1 \l 12827 MR. ROBERTS: And while they do that, I just reiterate that it represents a move from an implicit to an explicit subsidy, so we're just making the current hidden subsidies more visible with this change.
LISTNUM 1 \l 12828 THE CHAIRPERSON: While we are waiting, Mr. Roberts, what if we explain the different payees to these two ‑‑ as between these two sources of revenue.
LISTNUM 1 \l 12829 Let's just take the $27‑million. Under the hypothesis ‑‑ just to make it clear to everybody, under the hypothesis, under the current situation the 27‑million is made by interconnecting carriers.
LISTNUM 1 \l 12830 The $27‑million is contributed by people paying the CAT, the carrier access tariff and that is interconnecting southern carriers?
LISTNUM 1 \l 12831 MR. ROBERTS: A significant portion of the $27 million, yes.
LISTNUM 1 \l 12832 THE CHAIRPERSON: Where would the rest be?
LISTNUM 1 \l 12833 MR. ROBERTS: We have proposed rate changes to other rates, including digital private lines, so there are retail customers ‑‑
LISTNUM 1 \l 12834 THE CHAIRPERSON: In the $27 million?
LISTNUM 1 \l 12835 MR. ROBERTS: I believe so.
LISTNUM 1 \l 12836 THE CHAIRPERSON: I was just asking you about the CAT adjustment and not about the other ‑‑
LISTNUM 1 \l 12837 MR. ROBERTS: Yes, you are correct.
LISTNUM 1 \l 12838 THE CHAIRPERSON: Okay. Let us just assume for the moment that that $27 million is going to be absorbed in the National Contribution Fund, so instead of inter‑connectors who is going to pay?
LISTNUM 1 \l 12839 MR. ROBERTS: The inter‑connectors and other telecommunications companies in Canada.
LISTNUM 1 \l 12840 THE CHAIRPERSON: Yes, but there will be a different distribution of burdens under the National Contribution Fund than under the inter‑connectors, although they will be substantially the same basic population, that is what you would argue?
LISTNUM 1 \l 12841 MR. ROBERTS: I would agree with that. Although, the important thing too to note here is that it is possible to bypass the current usage‑based mechanism and there is huge incentives to do so versus not being able to bypass the contribution tax.
LISTNUM 1 \l 12842 MR. HAMELIN: Of course, the reduction in the settlements here, the carriers' fees, goes to offset those that are contributing to the..
LISTNUM 1 \l 12843 THE CHAIRPERSON: Yes, I understood. I just wanted to.. This is an editorial exchange, I want to be sure I understand and give you a chance to make sure we all are on the same page here. Now, are we ready to give a document to..?
LISTNUM 1 \l 12844 MR. RONDEAU: I think what we have is sufficient, Mr. Chair.
LISTNUM 1 \l 12845 THE CHAIRPERSON: All right please go ahead, Mr. Rondeau.
LISTNUM 1 \l 12846 MR. RONDEAU: I am satisfied with what I have.
LISTNUM 1 \l 12847 Could you please look at Northwestel CRTC 301, Attachment 1?
LISTNUM 1 \l 12848 MR. HAMELIN: I have it.
LISTNUM 1 \l 12849 MR. RONDEAU: Specifically, Mr. Hamelin, pension expense. My question is, if you look at the attachment, is could you please explain the doubling of the pensioning expense 2004, 2005 and then again in 2006?
LISTNUM 1 \l 12850 MR. HAMELIN: Yes. Well, this is a direct result of, you know, we are in a DB plan, that they call ‑‑
LISTNUM 1 \l 12851 MR. ROBERTS: Defined benefits.
LISTNUM 1 \l 12852 MR. HAMELIN: ‑‑ thank you, defined benefit plan. And what has happened in the assumptions from the actuaries, the primary driver is the reduction in interest rates. What is happening, it means that the promise made when you get into employment by the company is all calculated on, you know, the future, when you are going to retire and so on. And it bears in mind some assumptions about, you know, interest rates such that when you do retire you can buy an annuity at a given interest rate. Well, just imagine if interest rates collapse and become record lows like we have been experiencing recently, it takes a lot more capital now to buy annuities in order to retire.
LISTNUM 1 \l 12853 So what it means then, it translates that in order to meet your promise when you are in this kind of level of interest rates, at record lows, you have to invest more capital than you are accustomed to and you are recording an accrual of an earned day of pension, a future date for a days' work, at a higher rate because the expense is much higher simply because the interest rates are so low.
LISTNUM 1 \l 12854 MR. RONDEAU: In other words, because interest rates are so low, the investment in this pension program is not receiving the money that it once received, is that..?
LISTNUM 1 \l 12855 MR. HAMELIN: No, no. You have to distinguish between the actuarial assumption for return on asset, which is how your investments.. Like your RRSPs, you know, say you have imagined yourself earning a return of 7 per cent let us say, that is one thing. Whether you make 10 or make 3 during the years is a different matter, it is part of the experience, gain or loss.
LISTNUM 1 \l 12856 What I am talking about is the liability that the company has in order to fulfil its promise to its employees regarding pension. That piece of the obligation is computed using long‑term interest rates.
LISTNUM 1 \l 12857 MR. RONDEAU: Can I assume that you are having more of your staff that are retiring? Is this ‑‑
LISTNUM 1 \l 12858 MR. HAMELIN: No, it has no bearing on whether staff is retiring or not. It has a bearing on what the company is experiencing in recording the level of expense given the very nature of the environment today.
LISTNUM 1 \l 12859 MR. RONDEAU: I just have one more question on the finances area and I will move on to cost of equity, which won't take too long.
LISTNUM 1 \l 12860 My last question in the financial area is a general question. Large corporations like yourself, especially ones that are regulated under a rate of return, often use deferrals in various forms; is that correct?
LISTNUM 1 \l 12861 MR. HAMELIN: That is correct.
LISTNUM 1 \l 12862 MR. RONDEAU: And how would this affect your bottom line?
LISTNUM 1 \l 12863 MR. HAMELIN: Well, I mean this is just standard accounting practice. I am not sure which deferral you are talking about. For example, deferred tax credits is simply the difference between the accounting depreciation versus the tax depreciation times the tax rate.
LISTNUM 1 \l 12864 MR. RONDEAU: What I am referring to is if you ‑‑ you can tweak your deferrals to get your under or over ‑‑
LISTNUM 1 \l 12865 MR. HAMELIN: Well, if you are talking about return, accounting return, often deferrals are just nothings in terms of ‑‑ from an accounting point of view they are accounting entries but they are all governed by GAP principles and audited by Deloitte. I am not ‑‑ like cash is king in the real sense, in my world anyways.
LISTNUM 1 \l 12866 From a deferral accounting ‑‑ all you are doing is reflecting as best as possible what the performance of the corporation is, including matching principles between expenses and revenues and so on. You get to an accounting calculation, deriving an ROE calculation. It is accounting income over the equity base.
LISTNUM 1 \l 12867 MR. RONDEAU: Okay, fair enough. I will come back to that in my cost of equity questions a little ways down.
LISTNUM 1 \l 12868 Now when you are ‑‑ I will go right on to cost of equity. When you are getting your formula, risk premium is one of the major considerations you use in determining your ROE; is that correct?
LISTNUM 1 \l 12869 MR. HAMELIN: You are talking the level of allowed ROE as permitted by the Commission?
LISTNUM 1 \l 12870 MR. RONDEAU: Correct.
LISTNUM 1 \l 12871 MR. HAMELIN: Is that what you are trying to say?
LISTNUM 1 \l 12872 MR. RONDEAU: Yes.
LISTNUM 1 \l 12873 MR. HAMELIN: Risk premium ‑‑ I mean obviously there is a big difference between holding a bond ‑‑ and there are different kinds of bonds. A risk‑free bond would be ‑‑ I believe a question that was asked of me this morning ‑‑ would be a long‑term Government of Canada bond.
LISTNUM 1 \l 12874 And by the way, probably by after lunch we will probably have the latest and greatest when it comes to a third‑year bond.
LISTNUM 1 \l 12875 You have got industrial bonds that are more risky and so on.
LISTNUM 1 \l 12876 Bonds is one thing. Equity is another one. And there is a relationship to some degree between ‑‑ depending on the financial model that you do use for calculating equity, cost of equity.
LISTNUM 1 \l 12877 Cost of equity has a lot to do with the nature of the business that you are in. So you can say you want a premium, if you will, for taking on the riskiness of the investment in a business that you are going into.
LISTNUM 1 \l 12878 Ms McShane would have been in a better position to defend her evidence but essentially the way I understand it, the more risk you take, the more return you would like. That is only fair, at least from a financial concept.
LISTNUM 1 \l 12879 MR. RONDEAU: That makes sense, yes.
LISTNUM 1 \l 12880 MR. HAMELIN: But various businesses differ in risk‑taking, if you will, and that is the essence of Ms McShane's evidence. So yes ‑‑ so my ‑‑ I am not sure ‑‑
LISTNUM 1 \l 12881 MR. RONDEAU: That is fine.
LISTNUM 1 \l 12882 MR. HAMELIN: That is fine?
LISTNUM 1 \l 12883 MR. RONDEAU: You have answered my question fine, yes.
LISTNUM 1 \l 12884 My next question. Just above we spoke of deferring costs. Again, I will ask you specifically, does not the use of deferral accounts allow you to capture any over or under estimations in your toll revenue?
LISTNUM 1 \l 12885 MR. HAMELIN: It does in terms of CAT settlements and toll. That was part of ‑‑ again I come back to the regime that we are under and was proposed six years ago. Actually, it was introduced by the Commission.
LISTNUM 1 \l 12886 Because of the uncertainty that would occur relative to the forecasts of these revenues, we were collapsing rates from an abnormally very, very high level for residential. After doing all the rate rebalance you talked about to the max possible, we still had quite a gap in terms of toll rate.
LISTNUM 1 \l 12887 So what we did is propose a great decrease. At the time Dr. Taylor that we brought to the hearings testified that elasticity calculations on demand was simply impossible to predict given that it was not done on an incremental basis, it was like jumping off a cliff in terms of pricing.
LISTNUM 1 \l 12888 So in their wisdom the Commission decided to introduce a deferral mechanism in such a way that if the forecasts of toll settlement and CAT was ‑‑ and in fact it represents about a third of our revenue by the way, and it has been for just about the five, six year, pretty steady actually ‑‑ it would be either a top up would be provided to make the forecast happen or vice versa, if we exceeded the forecast ‑‑ which has happened in some years, in fact I think we are remitting a couple of million dollars to the fund based on if we overran that forecast.
LISTNUM 1 \l 12889 So what it did, it was a mechanism that provided some stability and good guidance in order to be able to offer comparable prices to the North. Comparable prices to the North would not exist without a subsidy, it's as simple as that. Similar comparable services is the huge SIP commitment now.
LISTNUM 1 \l 12890 So that deferral is there for that purpose, it guarantees the forecast.
LISTNUM 1 \l 12891 MR. ROBERTS: Just to elaborate a little bit, it has worked very well under the current regime, which is revenue‑focused. However, it is not part of our proposal going forward as we aren't proposing a rate‑of‑return regime and a revenue deferral arrangement such as we have today would not be entirely consistent with our proposal.
LISTNUM 1 \l 12892 MR. RONDEAU: Okay. What I was looking for was just the yes answer. I appreciate the explanation, but I was looking to find out if deferral accounts could be used to help you gain your toll revenues.
LISTNUM 1 \l 12893 My next question on this is: Would you not say that being allowed to use this particular mechanism reduces your risk?
LISTNUM 1 \l 12894 MR. HAMELIN: In the old regime it did, to some degree. It guaranteed one‑third of the revenue forecast ‑‑ as approved and reviewed by the Commission, by the way. It's not just a "gimme" here. Like what we would have is to submit every year our proposed forecast and it would be reviewed and available for everyone's review for that matter.
LISTNUM 1 \l 12895 MR. RONDEAU: But you are still looking at 10.5 percent. How would it be any different under the new regime?
LISTNUM 1 \l 12896 MR. HAMELIN: That's only for testing of the rate's purposes. We thought that going into the testing of the prices that this would be a reasonable extension of where we are at today, going in tomorrow, subject to check.
LISTNUM 1 \l 12897 I mean, we have the expert review and revisit the level of the cost of equity, if you will, but that's on a total company basis. We did not get the luxury of going through a split rate base mechanism, let alone test it and what have you. It would take quite a while.
LISTNUM 1 \l 12898 MS CHALIFOUX: Perhaps just to explain a little bit there, Mr. Rondeau, when the company was looking at what would be an appropriate ROE to use for testing going in rates, as Mr. Hamelin elaborated, we looked at many things in acknowledging that long‑term bond yields were decreasing. However, offset by changes in our business risk profile, as we elaborated yesterday, as an example we have a significant duplicate network now in the Northwest Territories and in Nunavut providing broadband services. That's one element we have as part of our proposal.
LISTNUM 1 \l 12899 We are proposing to significantly decrease the Carrier Access Tariff rate thereby having more equal access competition entering the market. We have cellular competition coming in, or has been here for a number of years and is growing.
LISTNUM 1 \l 12900 But perhaps again the most significant is the nature of IP that is impacting telcos across the country, and we are not immune to the impacts of IP.
LISTNUM 1 \l 12901 Just looking at some recent stats, we have had 3 percent of our traffic that we are measuring just from our own customers using voice over IP as an illustration.
LISTNUM 1 \l 12902 So again, we took into account a number of things and came up with a recommendation of 10.5 as a reasonable balance.
LISTNUM 1 \l 12903 MR. RONDEAU: I appreciate your explanations here, but what I am after is again the "yes" answer that using deferral accounts can offset the risk factor.
LISTNUM 1 \l 12904 THE CHAIRPERSON Mr. Rondeau, deferral accounts are not in the forward looking proposal.
LISTNUM 1 \l 12905 The thing that is before us today, the proposition doesn't feature deferral accounts. So I am not sure where you are going with this discussion of deferral accounts.
LISTNUM 1 \l 12906 Do you understand?
LISTNUM 1 \l 12907 MR. RONDEAU: Yes.
LISTNUM 1 \l 12908 THE CHAIRPERSON: The proposal that Northwestel has put forward does not include the continued use of deferral accounts.
LISTNUM 1 \l 12909 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12910 MR. HAMELIN: If it may help, Mr. Rondeau, what my colleague here just mentioned about all the increased business risks since the year 2000, these considerations are all reflected in Ms McShane's evidence. She proposes a higher ROE. She is proposing 11.75.
LISTNUM 1 \l 12911 In the end, as a matter of judgment, this work was done in parallel to us elaborating and developing our proposal. We felt that it is a matter of judgment to look at this as a total package, and we decided to retain 10.5 percent.
LISTNUM 1 \l 12912 If people want us to try and revisit and increase to 11.75, I would be more than happy to.
LISTNUM 1 \l 12913 MR. RONDEAU: Yes, I'm sure.
LISTNUM 1 \l 12914 Maybe I am going off here on this as well. The funding mechanism that you plan on using as well, this will affect your allowable earnings. Is that correct?
LISTNUM 1 \l 12915 MR. HAMELIN: It will be part of ‑‑
LISTNUM 1 \l 12916 MR. RONDEAU: It will be giving you your allowable earnings.
LISTNUM 1 \l 12917 Does not this offset your risk as well?
LISTNUM 1 \l 12918 MR. HAMELIN: Well, partly. I mean, the subsidy we are talking about is cost based. These costs are not going to go away.
LISTNUM 1 \l 12919 You can increase your business rates to a hundred bucks if you want, or put them to zero. It is the same subsidy we are talking about. It is cost based. It has nothing to do with the rates. It is just a proposal to set us in a position to earn what we think is 10.5 percent. We feel that we are still exposed, that we haven't gone far enough by any stretch.
LISTNUM 1 \l 12920 But considering everything that is at play as a package, I think it makes sense.
LISTNUM 1 \l 12921 So in one month ‑‑
LISTNUM 1 \l 12922 MR. ROBERTS: If I may, for instance, we are very dependent right now on the CAT rate. It is approximately 60 times higher than a comparable direct connect rate in Bell Canada operating territory.
LISTNUM 1 \l 12923 So just for clarity, to terminate a call in Whitehorse, for instance, a carrier is paying this higher rate that is 60 times higher and the facilities that are associated with things like toll connect and that aren't even used.
LISTNUM 1 \l 12924 So a comparable rate is effectively the DC rate for our major centres.
LISTNUM 1 \l 12925 We are suggesting that because of the market changes that have happened since 2000 when the current regime was put in place, including things like technology, things like parallel networks, et cetera, we are concerned that we can no longer sustain this form of implicit subsidy, this 60 times rate going forward.
LISTNUM 1 \l 12926 So we need to make that explicit. It doesn't change the overall amount of revenue materially. It is just a matter of trying to come up with a way to do it on a sustained basis going forward.
LISTNUM 1 \l 12927 MR. RONDEAU: Thank you.
LISTNUM 1 \l 12928 I gather that there are no other regulated telcos to see what the average rate of return is.
LISTNUM 1 \l 12929 Are you aware of other regulated agencies ‑‑ the electrical utilities are what I am after ‑‑ what type of rate of return they have received in the last number of years?
LISTNUM 1 \l 12930 MR. HAMELIN: Different businesses call for different risks and different returns. I am sure that electricity is probably a lot less risky than telcos are, so they would probably be at a lesser level than telcos.
LISTNUM 1 \l 12931 MR. RONDEAU: Maybe I could have you intervene in the electrical rate hearings.
‑‑‑ Laughter / Rires
LISTNUM 1 \l 12932 MR. RONDEAU: From what I have researched, the rates being charged in the electrical utilities now are somewhere in the 9.5 to 10 percent range. Why should you be asking for more than they are?
LISTNUM 1 \l 12933 MR. HAMELIN: I think I have just explained that. It is the nature of the risk. It is as simple as that.
LISTNUM 1 \l 12934 The same way that your balance sheet would look different. You can go a lot more in debt if you are in a much more stable business. Most of these companies that you are talking about are probably at 20 or 30 percent equity, compared to a 55 level that exists primarily in the telco.
LISTNUM 1 \l 12935 As per Ms McShane's evidence, it is pretty predominant right now. Every telco is pretty much at that level.
LISTNUM 1 \l 12936 If you were in the reg business it would be different. You would probably be at 80 or 90 percent equity.
LISTNUM 1 \l 12937 MR. ROBERTS: A specific example of the difference is the rate of technology change. There is not as much rampant replacement of technology in the electrical sector versus the telecom sector.
LISTNUM 1 \l 12938 MR. RONDEAU: I have only one more question. There was one thing I forgot to add on, and it will go very quickly.
LISTNUM 1 \l 12939 I have a few questions on wholesale rates.
LISTNUM 1 \l 12940 Are they regulated?
LISTNUM 1 \l 12941 MS CHALIFOUX: Some are.
LISTNUM 1 \l 12942 MR. RONDEAU: Can you give us a little more information? Which ones ‑‑
LISTNUM 1 \l 12943 MS CHALIFOUX: Our Carrier Access Tariff Rate is a tariffed rate. It is a rate that we offer to wholesale competitors in the toll business.
LISTNUM 1 \l 12944 Is that what you were referring to?
LISTNUM 1 \l 12945 MR. RONDEAU: Specifically ‑‑ and I may be going off in the wrong area here ‑‑ broadband rates.
LISTNUM 1 \l 12946 MS CHALIFOUX: Our I‑gate service?
LISTNUM 1 \l 12947 MR. RONDEAU: Yes.
LISTNUM 1 \l 12948 MS CHALIFOUX: Internet services are forborne.
LISTNUM 1 \l 12949 MR. RONDEAU: Yes.
LISTNUM 1 \l 12950 MS CHALIFOUX: So the answer is no.
LISTNUM 1 \l 12951 MR. RONDEAU: What I am trying to get at is, how do you expect competition to roll in in these areas if these rates are not regulated?
LISTNUM 1 \l 12952 MR. HAMELIN: The rates have been brought down significantly. The CAT rate that we are proposing is .08 cents instead of 7 cents, so it should encourage equal access, which was discussed with the Marketing Panel yesterday.
LISTNUM 1 \l 12953 MS CHALIFOUX: I would also like to elaborate that, specific to your question, Mr. Rondeau, wholesale internet gateway rates are currently under review by the Commission in a separate Part VII proceeding and are specifically out of the scope of this proceeding.
LISTNUM 1 \l 12954 MR. RONDEAU: Thank you very much, panel.
LISTNUM 1 \l 12955 THE CHAIRPERSON: Thank you, Mr. Rondeau.
LISTNUM 1 \l 12956 We will see each other at two o'clock, please. Thank you very much.
‑‑‑ Upon recessing at 1230 / Suspension à 1230
‑‑‑ Upon resuming at 1400 / Reprise à 1400
LISTNUM 1 \l 12957 LE PRÉSIDENT: Madame La Secrétaire.
LISTNUM 1 \l 12958 LE SECRÉTAIRE: Merci.
LISTNUM 1 \l 12959 Thank you, Mr. Chairman.
LISTNUM 1 \l 12960 The next panel to cross‑examine the finance panel of Northwestel will be Telus ‑‑ I'm sorry, Government of Yukon.
LISTNUM 1 \l 12961 MR. PRATT: Thank you, Mr. Chairman. Jim Pratt and Steve Rose for the Government of Yukon.
EXAMINATION / INTERROGATOIRE
LISTNUM 1 \l 12962 MR. PRATT: Good afternoon, gentlemen and ladies.
LISTNUM 1 \l 12963 Let me apologize in advance for not giving you an opportunity to talk about productivity, but if we have some time left at the end you may want to do that.
LISTNUM 1 \l 12964 But I would like to ask just a couple of questions related to the mark‑up topic and ask you to turn your response to CRTC's 16.01, specifically page 2 of 4.
LISTNUM 1 \l 12965 This passage starting with:
"Northwestel's 137 microwave radio stations..." (As read)
LISTNUM 1 \l 12966 I found that to be a fairly succinct description of what was involved in common and fixed costs with some helpful examples, and I wanted to just ask you a couple of questions around this to make sure that my understanding is consistent with the facts.
LISTNUM 1 \l 12967 The second sentence there notes that 22 per cent of the plant and service is related to fixed structures that are not included in phase 2 cost studies.
LISTNUM 1 \l 12968 Now, I assume that's because those costs are not causally related to any specific services?
LISTNUM 1 \l 12969 MS CHALIFOUX: That's right, they're not causal to the service nor can they be defined as causal to demand.
LISTNUM 1 \l 12970 MR. PRATT: So, that when ‑‑ and the purpose really of marking up in order to recover that is for pricing; correct?
LISTNUM 1 \l 12971 MS CHALIFOUX: Yes, that's correct.
LISTNUM 1 \l 12972 MR. PRATT: So, for your pricing and for your ultimately total revenue requirement, if you allow me the archaic term, you need to mark up by a percentage in order to cover those costs?
LISTNUM 1 \l 12973 MS CHALIFOUX: That's correct.
LISTNUM 1 \l 12974 MR. PRATT: And you described earlier today how you came up with the 25 per cent. What happens if 25 per cent isn't enough?
LISTNUM 1 \l 12975 MS CHALIFOUX: Well, I mean, what happens is at the end of the day you find yourself with, in the case of a shortfall, an overall shortfall in the company, so then you would have to look to certain services to recover more than a 25 per cent mark‑up.
LISTNUM 1 \l 12976 I mean, it's sort of a broad range but, you know, there's going to be some services that are less and some services that are more, but if over time you find yourself more on the side of less of a mark‑up you will be tasked with finding, you know, new services, new sources of revenue or rate increases where you can to help recover those costs.
LISTNUM 1 \l 12977 MR. PRATT: But you wouldn't really be able to tell if it was the delta in demand or the causally related costs or the allocation of fixed and common that was the differentiating factor in not being able to meet the anticipated target; right?
LISTNUM 1 \l 12978 MS CHALIFOUX: That's probably a fair statement. It would be difficult to exactly derive.
LISTNUM 1 \l 12979 MR. PRATT: So even though it is theoretically possible, it is not practically practical or likely, you might be going back and revising the allocation of ‑‑ revising the mark‑up level; is that fair?
LISTNUM 1 \l 12980 MS CHALIFOUX: For what in particular?
LISTNUM 1 \l 12981 MR. PRATT: Well, in the scenario we are just speaking of, if things didn't balance out the way you expected on a service basis or total company basis, you would probably look to making other adjustments before you would go back and try and change the mark‑up on that?
LISTNUM 1 \l 12982 MR. WOODLAND: I think that would be addressed on a case‑by‑case basis. If we found ourselves in that situation we would have to do some investigation in order to determine what the important factors really were in that particular case and then that would direct us towards either specific actions on rates or potentially expenses or I think the large or reserve case would be to possibly revisit something like a mark‑up rate.
LISTNUM 1 \l 12983 MR. PRATT: Fair enough. And those costs, the fixed and common costs are presently recovered by a combination of the rates in the subsidy; correct?
LISTNUM 1 \l 12984 MR. WOODLAND: That is correct.
LISTNUM 1 \l 12985 MR. PRATT: So if a new project or a new service were added, so if you invested new capital or added a new service, does that change the allocation of the mark‑up so that presumably you are positing a scenario where you add a service that doesn't ‑‑ that truly is incremental, doesn't add to the fixed costs? You would still use 25 per cent mark‑up on that service in order to make things pencil out, you wouldn't use some reduced amount because there is a broader base of services sharing the common costs?
LISTNUM 1 \l 12986 MR. WOODLAND: I think that is correct as a rule of thumb.
LISTNUM 1 \l 12987 MR. PRATT: Could I ask you now to look at the response to YG‑10.
LISTNUM 1 \l 12988 This was a question relating to the toll connect trunks, and hopefully, Mr. Chairman, I will not be replowing well tilled ground. I will try to keep it focused here.
LISTNUM 1 \l 12989 I think the specific concern identified by the Yukon Government in this question was the implications inherent in your proposal and including the toll connect costs as part of the subsidy eligible costs. And if those were to be excluded, what would be the impact, first of all, on customer rates?
LISTNUM 1 \l 12990 MR. WOODLAND: I am sorry, I think I heard a couple of different questions. Could you break that up for me into a couple of pieces?
LISTNUM 1 \l 12991 MR. PRATT: Sure. If the toll connect costs were not included, as you have proposed ‑‑
LISTNUM 1 \l 12992 MR. WOODLAND: You mean not subject to a subsidy?
LISTNUM 1 \l 12993 MR. PRATT: Correct ‑‑ what would be the implications for customer rates?
LISTNUM 1 \l 12994 MS CHALIFOUX: Well, this brings us to the very nature of the toll connect costs and the dilemma we are facing. For example, toll connect, we have talked about the number of earth stations as well as the number of microwave stations and the kilometres of routes therein being high cost, but again, not all of the toll traffic necessarily uses those high‑cost facilities. The portion that hits Whitehorse/Yellowknife, for instance, just the toll connect is in essence a little link.
LISTNUM 1 \l 12995 This is a very complicated topic and we actually prepared a little exhibit that might speak to the nature of toll connect facilities and more specifically about the cost and therefore the pricing implications. So if you will, I would like to share that exhibit just so we can be very clear on when we are talking toll connect the actual cost that we are talking about, as well as the recovery of those costs today and the dilemma in the future. Could I..?
LISTNUM 1 \l 12996 THE CHAIRPERSON: Please go ahead, assuming Mr. Pratt has no objection of..
LISTNUM 1 \l 12997 MR. PRATT: No, I have no objection, Mr. Chair.
LISTNUM 1 \l 12998 THE SECRETARY: This exhibit will be Northwestel Exhibit No. 2.
LISTNUM 1 \l 12999 THE CHAIRPERSON: And you will ensure that this panel, as opposed to that panel, gets a copy?
LISTNUM 1 \l 13000 MR. WOODLAND: If everybody has a copy I will begin a bit of a walk‑through.
LISTNUM 1 \l 13001 What this is trying to show is very simple, very high level, the handling of toll traffic at Northwestel and, in particular, with regards to toll connect.
LISTNUM 1 \l 13002 Oh, I am sorry, Commissioner. Do the interveners all have a copy? Okay.
LISTNUM 1 \l 13003 So all we have tried to show here is how 100 per cent of our toll traffic is handled by three class 4, class 5 switches. We have three switches in Whitehorse, Yellowknife and Fort Nelson that perform both the role of a toll switch and a local switch. Of that 100 per cent of the toll traffic 47.7 per cent of it terminates or originates right there on those three switches and thus incurs none of the toll connect costs.
LISTNUM 1 \l 13004 Where we are talking about toll connect, keep in mind that what we mean is very specifically to transport facilities between the class 4 and the class 5 switch. So then of the remainder of that traffic ‑‑ well, actually 24.5 per cent of the total of that toll traffic terminates or originates in our satellite locations, which is 42 communities and that cost is 71 per cent of the total toll connect cost. And finally, 27.8 per cent of that total toll traffic originates or terminates on our terrestrial class 5s outside of the three major centres and that is 51 communities and 29 per cent of the toll connect cost.
LISTNUM 1 \l 13005 In a nutshell, our dilemma was trying to recover these costs through minute‑based rates, is that one of two things. If it is an averaged cost then we are putting that 0.0265 cents, 0.027 cents a minute of cost onto three communities with half the traffic, where they don't actually incur the cost. If we de‑average the cost of these three different categories and made, for instance, satellite communities bear the complete cost of that, their CAT rate would be on the order of 0.10 cents.
LISTNUM 1 \l 13006 MS CHALIFOUX: And just to elaborate on that, I mean the dilemma and the challenge faced by Northwestel is those three larger centres that today are bearing a large portion of that cost, even though they don't incur the cost and therefore are contributing to the cost, this is where we are most susceptible to competition. You know, we have a large national carrier today offering a 0.03 cent‑a‑minute rate to a national customer. A 0.03 cent‑per‑minute rate we cannot compete in Whitehorse and Yellowknife, it is very difficult.
LISTNUM 1 \l 13007 But what we are saying is, you know, at a minimum we have to eliminate the need to cross‑subsidize so that we can at least, you know, be able to price closer to the actual cost of operating toll in these territories and that is just traditional toll. Now we are faced with competing with Voice over IP and Voice over IP in the north is significantly impacting the toll business.
LISTNUM 1 \l 13008 The customers that are finding Voice over IP most attractive today are those customers who are using it to reach friends, family, business, branch office, headquarters, what not. They are using it to communicate on a distance basis, so it is displacing the toll business. And that is just going to continue to happen, that is going to grow. So you can see the challenge there is the ability to maintain that inherent cost subsidy in our major centres is just not sustainable in the future.
LISTNUM 1 \l 13009 MR. ROBERTS: And further, I guess if you look at competitors' retail rates again, as Ms Chalifoux indicated, they are pricing essentially below cost in our market, particularly in Whitehorse and Yellowknife, and having this high loading of these costs that are not associated with the major communities in our market has the potential to push our competitors to IP as well. Both existing competitors and future competitors would have a significant incentive to adopt IP technologies that would bypass the CAT instead of using traditional legacy technology.
LISTNUM 1 \l 13010 MR. HAMELIN: I think it's important to note that the subsidy of $10.8 million that we are talking about here would exist for these facilities even if we had zero business attached to this.
LISTNUM 1 \l 13011 What we are saying is, in order to provide connectivity, basic service objectives to residents that are in spur small communities thousands of miles away ‑‑ because this interconnect toll connect thing has the equivalent, at least for the microwave, as I mentioned it is back and forth Ottawa‑Victoria ‑‑ you know, it wouldn't happen.
LISTNUM 1 \l 13012 So we are providing the smallest element possible for connectivity, which I think is DS1 I believe.
LISTNUM 1 \l 13013 MR. WOODLAND: Yes.
LISTNUM 1 \l 13014 MR. HAMELIN: If it was just for res the cost would be there in full because it's a sunk, fixed common cost to provide this thing, regardless of whether you have business or not. That is the smallest cost possible to connect these people and provide them basic service objectives of toll connectivity.
LISTNUM 1 \l 13015 Did you want to say something?
LISTNUM 1 \l 13016 MR. WOODLAND: No, you have it.
LISTNUM 1 \l 13017 MR. HAMELIN: I got it.
LISTNUM 1 \l 13018 MR. PRATT: So no one has anything to add?
LISTNUM 1 \l 13019 We may have bypassed the initial intent of my question, but if I understand ‑‑ I was starting out interested in the impacts on customers and it's helpful to have this data.
LISTNUM 1 \l 13020 If I understood what you have all told us, the impact would first be on the CAT rather than on customers directly.
LISTNUM 1 \l 13021 Is that fair?
LISTNUM 1 \l 13022 Remember back to my hypothetical that if the toll connect costs were not included in the subsidy calculation.
LISTNUM 1 \l 13023 MS CHALIFOUX: Well, I think at the end of the day the ultimate impact on customers is going to be that we are going to be forced to be competitive and more competitive in particular in our major centre. So I think the impact is going to be truly the ability to maintain affordable rates and high quality service in the rural and remote communities.
LISTNUM 1 \l 13024 MR. PRATT: Sure. I understand that.
LISTNUM 1 \l 13025 But I think the first order of responses that the panel gave with respect to the impacts related to how much of an increase in the CAT would be required in order to make up for those costs not being subsidized.
LISTNUM 1 \l 13026 MS CHALIFOUX: Well, it would, in my mind, you know, ultimately lead to higher pricing of the toll business in general possibly in the remote communities or in less competitive segments.
LISTNUM 1 \l 13027 MR. PRATT: So you would be more likely to change prices than you would to revise the CAT?
LISTNUM 1 \l 13028 MS CHALIFOUX: Well, the CAT may be one element we would have to look at.
LISTNUM 1 \l 13029 MR. PRATT: All right. That moves nicely into the next area that I wanted to talk to you about.
LISTNUM 1 \l 13030 In your response to CRTC 1301 you were asked to look at the implications of a selective implementation of the current framework, and along the same lines that we were just discussing I wonder if you could help me out any more in terms of the implications of ‑‑ well, first of all, if the rate changes that you have proposed were not allowed, what would be the implications, then, for the rest of your proposal?
LISTNUM 1 \l 13031 MS CHALIFOUX: I'm sorry, Mr. Pratt, you are referring to 1301, the undertaking we have that we are ‑‑
LISTNUM 1 \l 13032 MR. PRATT: No. I was looking at your response to the interrogatory 1301.
‑‑‑ Pause
LISTNUM 1 \l 13033 MR. ROBERTS: Again, as outlined in response to 1301, it is a package that we have put forward. As you can understand, we are trying to close the gap to facilitate a more significant, more aggressive move to price caps from a pure rate of return regime.
LISTNUM 1 \l 13034 As we determined the cost‑based subsidy amount, we had to work backwards and determined the rate at which we were constrained in bringing rates closer to costs for other services.
LISTNUM 1 \l 13035 If we have a selective application or a current framework changing that balance, then we have to revisit everything, including the relative degree of rate restructuring, for instance, and re‑assess with what we are left with as to whether or not it would be sustainable.
LISTNUM 1 \l 13036 The biggest challenge here is trying to come up with something that is sustainable.
LISTNUM 1 \l 13037 MR. PRATT: Why can't we have just half the package or some portion thereof?
LISTNUM 1 \l 13038 MR. ROBERTS: Half the package. Well, I guess it has to stay in balance. If you go in one direction with one part of the package, then it has to be offset in another area.
LISTNUM 1 \l 13039 It is like in some ways stepping on a balloon but only with regard to the rate restructuring. It is separate and apart from the cost‑based subsidies. The cost‑based subsidies are fixed by their costs. The costs are there. They are what they are. And the ability to I guess deal with those costs in a traditional manner through rates is something that has been established as being different for Northwestel.
LISTNUM 1 \l 13040 We would suggest that it is not possible to move parts of the proposal and have that balance things out automatically. So again, you have to revisit everything.
LISTNUM 1 \l 13041 I don't know if that addresses it.
LISTNUM 1 \l 13042 MS CHALIFOUX: If I could just add, for instance, half of the package is related to our Carrier Access Tariff rate proposal.
LISTNUM 1 \l 13043 So of that attachment in 1301 there, half of the revenue impact is due to the CAT, about 50 percent.
LISTNUM 1 \l 13044 As an example, what half is going to give you is maintaining the high levels of contribution, the 7‑cent CAT, no equal access competitive entry.
LISTNUM 1 \l 13045 Again with the continued evolution of IP, our customers are already using this technology so the level of implicit subsidies is just going to decline de facto.
LISTNUM 1 \l 13046 Again, half the package will get you so far in one year but the financial situation is just going to worsen over time. The need for the subsidy does not go away. If we don't address that issue properly, that is going to occur. So the need for subsidy will increase over time.
LISTNUM 1 \l 13047 MR. PRATT: Could I ask you to look at a few questions related to construction program, so your response to CRTC‑203, Attachment 4. I believe the spreadsheet is 4B.
LISTNUM 1 \l 13048 MR. HAMELIN: I have it.
LISTNUM 1 \l 13049 MR. PRATT: Did I read this correctly, that the projects listed for these two years, 2006 and 2007, this is the 2006 view compared to the 2004 view?
LISTNUM 1 \l 13050 MR. HAMELIN: That is correct.
LISTNUM 1 \l 13051 MR. PRATT: And these are differences in the view that was taken two years ago?
LISTNUM 1 \l 13052 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13053 MR. PRATT: Is the net effect to reduce the capital expenditures in both 2006 and 2007 compared to the 2004 view?
LISTNUM 1 \l 13054 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13055 MR. PRATT: Subject to check, it looks to me like it was around $6.7 million for 2006 and $6.4 million or $6.5 million for 2007.
LISTNUM 1 \l 13056 MR. WOODLAND: Subject to check.
LISTNUM 1 \l 13057 In fact, there is an interrog that answered that specific question.
LISTNUM 1 \l 13058 If you look at CRTC‑208, that answers that question specifically.
LISTNUM 1 \l 13059 MR. PRATT: Is there a general theme behind why there is a reduction of $12 million or $13 million in capital investment over those two years?
LISTNUM 1 \l 13060 MR. WOODLAND: The general theme would be a desire to build a plan that meets the standard objectives of meeting demand and growth in existing services, and meeting quality of service requirements, meeting productivity requirements through a program of efficiency projects, and demand for new and enhanced services, but the general gist here, really, is the removal of a lot of relatively large and uncertain strategic revenue opportunities from the view.
LISTNUM 1 \l 13061 MR. PRATT: So the revenue expectations are worse in 2006 than they were in 2004?
LISTNUM 1 \l 13062 MR. WOODLAND: I wouldn't say that specifically. It is more a recognition of the relative uncertainty of moving forward on some of those large opportunities.
LISTNUM 1 \l 13063 MR. PRATT: So you have a clearer view now than you did in 2004.
LISTNUM 1 \l 13064 MR. WOODLAND: Yes, and some of those opportunities are now being pursued through affiliate companies, as opposed to by Northwestel directly.
LISTNUM 1 \l 13065 MR. PRATT: That was a question that I wondered about, as well. From the Yukon Government's point of view, we are certainly interested in ensuring that there is continued investment in infrastructure in the North, and in particular in the Yukon.
LISTNUM 1 \l 13066 Can you point me to where you have already answered this, if you have, or just tell me now what the net change is in investment from Northwestel and affiliated companies over that same period of time, 2006 compared to the 2004 view?
LISTNUM 1 \l 13067 Excuse me, Mr. Chairman, I think there is an easier way of doing this.
LISTNUM 1 \l 13068 How much of that $12 million or $13 million will be invested by affiliates?
LISTNUM 1 \l 13069 MR. WOODLAND: I think we would have to undertake to answer that. I don't have it right at hand.
LISTNUM 1 \l 13070 In fact, it may be more appropriate for the Policy Panel, and we could endeavour to prepare the Policy Panel properly for that.
LISTNUM 1 \l 13071 MR. PRATT: I would appreciate if you would do that.
LISTNUM 1 \l 13072 I would ask you to look quickly at your response to CRTC‑203, Attachment 6.
LISTNUM 1 \l 13073 MR. WOODLAND: I have it.
‑‑‑ Pause
LISTNUM 1 \l 13074 MR. PRATT: I am not sure that I do, but this, I believe, shows the actual capital expenditure for 2005 compared to the forecast for 2005.
LISTNUM 1 \l 13075 Is that correct?
LISTNUM 1 \l 13076 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13077 MR. PRATT: With the unknown of the mystery project, which we don't know the name or the amount of, I reckoned that the actual expenditure was about $2.2 million more than the estimate for 2005.
LISTNUM 1 \l 13078 MR. WOODLAND: Subject to check, I will agree.
LISTNUM 1 \l 13079 MR. PRATT: Is there an obvious explanation for that?
LISTNUM 1 \l 13080 MR. WOODLAND: It would be, essentially, a reallocation within the complete portfolio of projects over the course of the year. Some projects accelerate or cost more, others delay or cost less, in particular within a given period and throughout the course of the year we shuffle things around to, you know, maximize our return, maximize our goals in terms of achieving projects.
LISTNUM 1 \l 13081 MR. PRATT: So, this is a normal expected variation in...
LISTNUM 1 \l 13082 MR. WOODLAND: Yes.
LISTNUM 1 \l 13083 MR. PRATT: Was the same factor of projects being pursued through affiliates occurring in 2005?
LISTNUM 1 \l 13084 MR. WOODLAND: Specifically in 2005?
LISTNUM 1 \l 13085 MR. PRATT: Correct.
LISTNUM 1 \l 13086 MR. WOODLAND: With regards to these changes?
LISTNUM 1 \l 13087 MR. PRATT: Well, with regard to the ‑‑ was the situation in 2005 the same as it is in 2006 with respect to the number of projects that may have been undertaken by affiliates rather than by Northwestel?
LISTNUM 1 \l 13088 MR. WOODLAND: I'm not actually sure about that. I know there were projects undertaken by affiliates, but I don't know that any of those had anything to do with the shifts between projects or within individual projects as noted in this particular submission.
LISTNUM 1 \l 13089 MR. PRATT: Sorry, I may be obscure in this, but what I was trying to pin down is if there is a point in time at which there was an effective change where more affiliates ‑‑ more of these projects were undertaken by affiliates than by the company?
LISTNUM 1 \l 13090 MR. WOODLAND: I don't know about a specific point in time, but it's certainly been an evolving process over time.
LISTNUM 1 \l 13091 And, in particular, I think one of the reasons is, as was mentioned yesterday I believe in the marketing panel, has a lot to do with the constraints from the customers essentially in terms of requiring participation of other groups, First Nations groups and the like.
LISTNUM 1 \l 13092 MR. PRATT: Just following on from that, where there are projects that other entities contribute to or contribute capital, how is that managed? Is a rate of return applied to that contributed capital when you do the project costing?
LISTNUM 1 \l 13093 MR. HAMELIN: Maybe I can interject here, Jody.
LISTNUM 1 \l 13094 If you're talking affiliates, existing affiliate, a good one for example would be Latitude is a good one.
LISTNUM 1 \l 13095 Latitude came about, at the embryonic stage really, we are just starting to deploy some cellular. First of all, it's outside the regulatory realm.
LISTNUM 1 \l 13096 MR. PRATT: Sure.
LISTNUM 1 \l 13097 MR. HAMELIN: Secondly, it's with a partner, in this case Dakwakada, part of First Nations.
LISTNUM 1 \l 13098 They're investing, we're investing. It's as a result of an RFP that was set out by YTG and the idea here is to provide service in 17 communities outside of Whitehorse.
LISTNUM 1 \l 13099 Now, just to put things in perspective, all of Yukon is about 30,000 people, Whitehorse is about 22 ‑‑ 20, 22, so we are talking about 8,000 people here, we're trying to communicate, spread out in 17 communities.
LISTNUM 1 \l 13100 So, let's not exaggerate the point of it being a super duper, big time project here, it is very consequential for Northwestel, indeed but, you know, this RFQ was circulated down south.
LISTNUM 1 \l 13101 I notice that Bell Mobility did not bid, neither did Telus, neither did anybody for that matter.
LISTNUM 1 \l 13102 So, we ended up with Ice submitting a proposal and Northwestel, and at the end Northwestel got it, so...
LISTNUM 1 \l 13103 I should add also ‑‑ my colleagues are reminding me here ‑‑ all the financing is independent of telco, so there's no cross‑relationship, there's nothing, other than any tariff, you know ‑‑ sorry, there was mention yesterday of carrying, you know, some traffic on Northwestel's network and so on and that, indeed, is what happens and it's all at tariff rates and, so...
LISTNUM 1 \l 13104 MR. PRATT: So, if Northwestel needed to install other facilities in order to provide those services ‑‑ those tariff services that would be ‑‑ how would that be accounted for?
LISTNUM 1 \l 13105 MR. HAMELIN: I'm not ‑‑
LISTNUM 1 \l 13106 MR. PRATT: Would the venture then need to make some contribution towards the capital investment that you're incurring ‑‑ that Northwestel is incurring in order to provide those additional services for the venture.
LISTNUM 1 \l 13107 MS CHALIFOUX: I mean, perhaps if it is just like any other customer, if they come to Northwestel and say I want, you know, product, I want six of those, let us just say six T1s. And if that is beyond our normal capital planning process, you know, what we often do is negotiate with the customer a potential for a capital contribution, a capital DNG.
LISTNUM 1 \l 13108 But if it is just part of our normal service offering, then again we would provide the customer ‑‑ we would ensure we have necessarily facilities and our normal capital program includes a regular forecast of demand. And we do get customer input on some of these large projects, so we are usually not taken aback, we build that in and then we charge them our tariff rates.
LISTNUM 1 \l 13109 MR. PRATT: Sure. And on that contributed capital, Ms Chalifoux, is that treated in the same way that the rest of the capital program would be? Like, does it attract return and all that sort of thing?
LISTNUM 1 \l 13110 MS CHALIFOUX: No, it is just treated as a credit to capital.
LISTNUM 1 \l 13111 MR. PRATT: I guess it would be a matter of negotiation, depending on the circumstance, but the lifecycle of those facilities might also come up in terms of identifying a contribution to replacement cost or that type of thing, depreciation, is that correct?
LISTNUM 1 \l 13112 MS CHALIFOUX: I mean, I wouldn't say depreciation wouldn't be a good concept to use in a sense. But take, for example ‑‑ you know, we have had examples like this before where a customer says I want to attach to this tower and we do have regular tariffs for that, but we say well the tower cannot withstand that additional burden without reinforcement. So if you are willing to contribute to reinforcing that tower, the cost of reinforcing that tower, then yes we will allow you to attach to our tower at tariff rates.
LISTNUM 1 \l 13113 MR. PRATT: Yes, and you discuss whatever the allocation is or the causality of the additional expense?
LISTNUM 1 \l 13114 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13115 MR. PRATT: Okay. I have no further questions, Mr. Chairman. Thank you, panel.
LISTNUM 1 \l 13116 THE CHAIRPERSON: Mr. Pratt, Mr. Rose, thank you very much.
LISTNUM 1 \l 13117 Madame la sécrétaire.
LISTNUM 1 \l 13118 THE SECRETARY: Thank you, Mr. Chairman.
LISTNUM 1 \l 13119 The next panel will be TELUS.
LISTNUM 1 \l 13120 MR. RYAN: Thank you, Mr. Chairman.
LISTNUM 1 \l 13121 THE CHAIRPERSON: Mr. Ryan.
LISTNUM 1 \l 13122 MR. RYAN: Ladies and gentlemen, good afternoon.
LISTNUM 1 \l 13123 I propose first to refer to a document that I passed to you through your counsel yesterday called proposed switch connect rate, which I see now traverses some of the same ground as TELUS‑2, which you have just presented and we will make every effort I assure both you, Mr. Chairman and the Panel, to make sure that there is no unnecessary replication of questions. But there are some items that I would like to raise with you with reference to this proposed switch connect rate document.
LISTNUM 1 \l 13124 As I said, I did listen to the explanation that we got in connection with Northwestel Exhibit 2 and that was quite helpful and I hope will allow us to accelerate this part of the questioning.
LISTNUM 1 \l 13125 But one thing you could immediately clarify ‑‑ you will see I have tried, as you did in Northwestel Exhibit 2, to present a representation of part of your network showing the toll switch and the local switches, the class 4 and the class 5s. I have appended a few things onto them, including wireless device, business establishment and residential establishment and I have labelled the connections between what I have called the class 4 and the class 5 with the letter "A" and the connection between the class 4 and the point of interconnection with another carrier is what I mean by the POI at the bottom of the page as "B."
LISTNUM 1 \l 13126 I take it you refer to the link that I have shown as "A" as a toll connect?
LISTNUM 1 \l 13127 MR. WOODLAND: That is correct.
LISTNUM 1 \l 13128 MR. RYAN: And what about the link that I have labelled "B"?
LISTNUM 1 \l 13129 MR. WOODLAND: Well, that would typically be either feature group D circuits or other data type circuits or ‑‑ are there any other options?
LISTNUM 1 \l 13130 MS CHALIFOUX: Well, in the ‑‑
LISTNUM 1 \l 13131 MR. RYAN: So ‑‑
LISTNUM 1 \l 13132 MS CHALIFOUX: ‑‑ of an interconnecting carrier, it could just be the transport rates that we charge ‑‑
LISTNUM 1 \l 13133 MR. RYAN: Right.
LISTNUM 1 \l 13134 MS CHALIFOUX: ‑‑ Telus, for example.
LISTNUM 1 \l 13135 MR. RYAN: For the purposes of this discussion about the toll connect rate, does "B" figure in this at all?
LISTNUM 1 \l 13136 MR. WOODLAND: No, it does not.
LISTNUM 1 \l 13137 MR. RYAN: Okay.
LISTNUM 1 \l 13138 MR. ROBERTS: If I may though, just to back up, "A" would only relate to where there wasn't a class 4/5.
LISTNUM 1 \l 13139 MR. RYAN: Yes, I will come to the class 4/5, thank you.
LISTNUM 1 \l 13140 So if we take, for example, the traffic emanating from a southern ILEC, let's say Bell or Telus, it would come in through the point of interconnection along circuit "B" and would terminate on a class 5 via one of these toll connect trunks that I have labelled "A"? Do I understand the mechanics of it all right?
LISTNUM 1 \l 13141 MR. WOODLAND: Yes.
LISTNUM 1 \l 13142 MR. RYAN: And this same sort of routing that I have just described would apply if we were talking about a private line; is that right?
LISTNUM 1 \l 13143 MR. WOODLAND: You mean a data circuit that happened to ‑‑
LISTNUM 1 \l 13144 MR. RYAN: Well, let's say a large customer, a large national customer has a private line from Montreal into Whitehorse, this would also describe that sort of arrangement?
LISTNUM 1 \l 13145 MR. WOODLAND: Well, there wouldn't be the "A" component involved in that. That would really only apply if that private line went beyond one of those communities to, say, Haines Junction or Beaver Creek.
LISTNUM 1 \l 13146 MR. RYAN: Because at Whitehorse you have a class 4/5; is that right?
LISTNUM 1 \l 13147 MR. WOODLAND: I mean they could ‑‑ yes, it is ‑‑ I may be muddying the picture here. The class 4/5 isn't required in order to do the data switching. It is just if we are talking about something that shares the same facilities as what we are calling toll connect traffic, i.e. the traffic between a class 4 and a class 5, then in order to be on those specific transport facilities the data circuit would have to go to one of the communities that is actually served by those facilities.
LISTNUM 1 \l 13148 MR. RYAN: So could you give me an example outside of a community where you have a class 4/5?
LISTNUM 1 \l 13149 MR. WOODLAND: Sure, Beaver Creek.
LISTNUM 1 \l 13150 MR. RYAN: Okay. So what would the configuration look like for a private line from Montreal to Beaver Creek, looking at the document I have just put in front of you? How would you amend this or how would it track through on the document I have given you?
LISTNUM 1 \l 13151 MR. WOODLAND: Well, if it was a terrestrial data circuit from Montreal to Beaver Creek, it would come through the Whitehorse CO. It would not be on any of the class 4 or class 5 switching facilities. It would be on data switching facilities. It would be switched on data facilities in Whitehorse, go back onto the transport network out to Beaver Creek and then on whatever equipment is in Beaver Creek, be brought down out of the main transport backbone and then put onto some kind of local circuit access type product in order to connect to the customer location.
LISTNUM 1 \l 13152 MR. RYAN: And would it go at any point along what you have called the toll connect?
LISTNUM 1 \l 13153 MR. WOODLAND: Well, it would go along the transport facilities that the toll connect facilities are carried on. Would it help if I was more clear about what I meant by that?
LISTNUM 1 \l 13154 MR. RYAN: No, but I am only interested in this from a cost standpoint. So when you talk about the costs of toll connect ‑‑
LISTNUM 1 \l 13155 MR. WOODLAND: Yes.
LISTNUM 1 \l 13156 MR. RYAN: ‑‑ are the costs we are talking about engaged by that sort of traffic or ‑‑
LISTNUM 1 \l 13157 MR. WOODLAND: No, they are not. No, no, not at all. Essentially what you have is a transport pipe and what I have done with all of our different route segments of transport pipe is I have looked at the capacity, I have looked at the perspective incremental costs for those and I have assigned those costs to that capacity. Then toll transport itself only takes its appropriate share by capacity of that per capacity cost.
LISTNUM 1 \l 13158 MR. RYAN: Okay, I think I understand that.
LISTNUM 1 \l 13159 Now let's say we have, as indicated in the Telus document in front of you, a call initiated on a wireless network, let's say initiated in this case in Northwestel territory, and exiting to, say, somebody in Montreal.
LISTNUM 1 \l 13160 Have we properly represented in the Telus document how that traffic would be routed?
LISTNUM 1 \l 13161 MR. WOODLAND: Routed, yes. Just the clarification that I would make is that from your point of interconnect by the cellular customer, presumably there would be some kind of cellular device in the CO or close by. But from that point, from that particular piece of equipment back, what has usually been the case is dedicated facilities purchased by the cellular carrier in order to carry their minutes. Those dedicated facilities are not the same as the toll connect facilities.
LISTNUM 1 \l 13162 Maybe just to be clear, the toll connect facilities that I'm talking about are very specifically coming out of a class 5 switch on a DS1 card, putting the transport required in between to go to a DS1 card in the class 4 switch. There is no really good way to get into that DS1 to make use of it for anything else.
LISTNUM 1 \l 13163 MR. RYAN: Now let's talk about a call originating at one of the houses I have represented graphically, a toll call made to Montreal.
LISTNUM 1 \l 13164 What facilities on this document would be engaged by such a call?
LISTNUM 1 \l 13165 MR. WOODLAND: Whose customer?
LISTNUM 1 \l 13166 MR. RYAN: Well, you have a Northwestel customer in the little house on the left there calling somebody in Montreal who is not on the sheet of paper.
LISTNUM 1 \l 13167 MR. WOODLAND: Okay. The local access facilities between the house and the class 5 switch would be used; the switching facilities themselves in that class 5 would be used; the transport facilities which you have labelled as "A" would be used; and then in the class 4 switch, the switching components there would also be utilized; and then from there the facilities you have labelled "B" would be used as well to the point of interconnect.
LISTNUM 1 \l 13168 I will just point out that in our toll imputation test filings which are in some of the marketing interrogatories that toll transport cost and various other interconnection and settlement costs ‑‑ in other words, how we make use of other people's networks ‑‑ are all included there.
LISTNUM 1 \l 13169 MR. RYAN: Yes. Now, let's say ‑‑
LISTNUM 1 \l 13170 MR. ROBERTS: Just for clarity, that would be Beaver Creek again as opposed to the class 5 being Whitehorse where the facilities in "A" would not be used.
LISTNUM 1 \l 13171 MS CHALIFOUX: Just one more point of ‑‑
LISTNUM 1 \l 13172 MR. RYAN: Just one at a time, please. I will come back to you.
LISTNUM 1 \l 13173 Let's say this device now, the wireless device, is used to place a call to the residential establishment as shown on the right of the page, which is also in Northwestel territory, how would that call be routed?
LISTNUM 1 \l 13174 Let's say at Beaver Creek as Mr. Roberts suggested.
LISTNUM 1 \l 13175 MR. WOODLAND: All right. Given that these are separate class 5s and if we use the structure of your diagram, it would follow pretty much the routing that you have talked about and would incorporate both legs shown as "A".
LISTNUM 1 \l 13176 MR. RYAN: All right.
LISTNUM 1 \l 13177 MR. WOODLAND: Just one thing we should point out is that an awful lot of our toll connect facilities don't look quite like this. I mean, they could be graphically represented like this, but the satellite facilities really bounce up to the sky and then back down. So the class 4 is at one end of that hop and the class 5 is at the other end of that hop.
LISTNUM 1 \l 13178 MR. RYAN: And how many class 4s do you have in your territory?
LISTNUM 1 \l 13179 MR. WOODLAND: Ninety‑six. Well ‑‑
LISTNUM 1 \l 13180 MR. RYAN: Class 4s?
LISTNUM 1 \l 13181 MR. WOODLAND: Oh, sorry, class 4s. My mistake.
LISTNUM 1 \l 13182 MR. RYAN: Class 4s.
LISTNUM 1 \l 13183 MR. WOODLAND: Well, class 4/5s. We have three class 4/5s.
LISTNUM 1 \l 13184 MR. RYAN: My next question relates to your reference in some of your documentation to settlement. Sometimes you talk about a bundled CAT rate, sometimes you talk about settlement.
LISTNUM 1 \l 13185 Could you start by telling me when you refer to a bundled CAT rate what's bundled?
LISTNUM 1 \l 13186 MS CHALIFOUX: Certainly. I can address that.
LISTNUM 1 \l 13187 In our framework decision in 2007‑45 there were a number of components at the time being addressed. There were equal access start‑up costs ‑‑
LISTNUM 1 \l 13188 MR. RYAN: Yes?
LISTNUM 1 \l 13189 MS CHALIFOUX: ‑‑ there was a contribution component ‑‑
LISTNUM 1 \l 13190 MR. RYAN: Right.
LISTNUM 1 \l 13191 MS CHALIFOUX: ‑‑ and then there was switching and aggregation.
LISTNUM 1 \l 13192 MR. RYAN: Right.
LISTNUM 1 \l 13193 MS CHALIFOUX: When we received the decision from the Commission we were given a bundled CAT with no distinction between those three components, so in essence those three components are embedded in that one rate.
LISTNUM 1 \l 13194 MR. RYAN: All right.
LISTNUM 1 \l 13195 MR. ROBERTS: Right in the context of 99‑16, though, I would suggest that given the treatment of the toll connect facilities and their inclusion in monopoly access and the reliance on monopoly to determine contribution requirements that in fact the bundled CAT amounts to recovery of equal access, switching and aggregation and then a non‑specific form of supplemental funding that's implicit, supplemented by an explicit supplemental funding from the National Contribution Fund also provided for in N2746.
LISTNUM 1 \l 13196 MR. RYAN: Could we look next at your evidence, Appendix 6, page 5. I think that is where I want to be.
‑‑‑ Pause
LISTNUM 1 \l 13197 MR. RYAN: Are you with me?
LISTNUM 1 \l 13198 If you look at the middle of the page under the heading "Network", there is a reference to the CAT, and you indicate that you expect revenues of about $1.7 million in 2006. And immediately above that there is a reference to settlement and the amount forecast for the current year is $23.733 million.
LISTNUM 1 \l 13199 My understanding of the record to date is that you are proposing to replace both of those sources of revenue with the new switch connect rate.
LISTNUM 1 \l 13200 Is that correct?
LISTNUM 1 \l 13201 MS CHALIFOUX: Yes. Just to be clear, the settlement includes a number of components; the CAT rate as well as transport rate. Then the CAT listed there is our equal access competitor CAT revenues.
LISTNUM 1 \l 13202 Obviously all our interconnecting carriers assess the CAT for traffic in our territory.
LISTNUM 1 \l 13203 MR. RYAN: This is the thing I would like to have a little bit more clarity on.
LISTNUM 1 \l 13204 What is settlement in this context?
LISTNUM 1 \l 13205 MS CHALIFOUX: Settlement in this context is toll settlement. It is settlement with our main carriers, TELUS, Bell, a number of the appellants. It is a method where we exchange toll traffic. When we terminate a call say on TELUS' network, we pay your terminating rate. And then similarly when you terminate a call on our network, we charge you our terminating rate, which is our CAT rate.
LISTNUM 1 \l 13206 MR. RYAN: That is where I get confused because you have revenues for settlement and revenues for CAT. And you say when the call is terminated for TELUS, you charge the CAT rate.
LISTNUM 1 \l 13207 What does the settlement spring from? What revenues does that ‑‑
LISTNUM 1 \l 13208 MS CHALIFOUX: Inter‑carrier traffic that is just exchanged, whereas the CAT revenue referenced on that line is specific to equal access carrier, an equal access arrangement.
LISTNUM 1 \l 13209 MR. RYAN: Okay. Would it be fair to say that you have not always used the reference to CAT in exactly the same way in the course of this proceeding?
LISTNUM 1 \l 13210 MS CHALIFOUX: When we refer to CAT in this proceeding, we mean CAT as it is labelled CAT on that line, as well as what is embodied in our settlement.
LISTNUM 1 \l 13211 MR. ROBERTS: Just for greater clarity, going back to your diagram ‑‑
LISTNUM 1 \l 13212 MR. RYAN: Just before we get to the diagram ‑‑ and I will come back to you ‑‑ I am still trying to understand this page of the financial information.
LISTNUM 1 \l 13213 The CAT listed here, the $1.7 million, that relates entirely to the CAT charged to equal access service providers.
LISTNUM 1 \l 13214 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13215 MR. RYAN: And you sometimes refer to a CAT that embraces both what on this particular piece of paper is referred to as settlement and CAT.
LISTNUM 1 \l 13216 Is that right?
LISTNUM 1 \l 13217 MS CHALIFOUX: Yes, although again just to be clear, settlement includes more fees than just CAT. And there is also the fees that we pay you.
LISTNUM 1 \l 13218 MR. RYAN: Right.
LISTNUM 1 \l 13219 MR. ROBERTS: So again with your diagram, the terminating rate that is described as settlement in the financials would incorporate CAT at the Class 4 there and would incorporate also a transport component, which is essentially "B".
LISTNUM 1 \l 13220 MR. RYAN: Right, which accounts for my initial question about "B", because it seemed to me that somehow this figured in the discussion of CAT one way or another.
LISTNUM 1 \l 13221 So when you talk ‑‑
LISTNUM 1 \l 13222 MR. ROBERTS: Just for clarity, "B" is not in CAT. "B" is charged in addition to CAT. That is our transport rate for termination. So that is what encompasses the settlement line.
LISTNUM 1 \l 13223 MR. RYAN: So that comes in with the settlement line on Appendix 6, page 5.
LISTNUM 1 \l 13224 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13225 THE CHAIRPERSON: Mr. Ryan, just further on this because I am confused, did I hear you correctly, Madam Chalifoux, say that on occasion, or frequently, you refer to CAT, in the generic sense, as including both settlement and what is regarded as CAT in this document?
LISTNUM 1 \l 13226 No? Yes?
LISTNUM 1 \l 13227 Shall I repeat the question?
LISTNUM 1 \l 13228 MS CHALIFOUX: Yes, if you would.
LISTNUM 1 \l 13229 THE CHAIRPERSON: I am confused, and I think that Mr. Ryan may also be confused for the same reason, although he is probably illuminated by now and I am still not illuminated.
LISTNUM 1 \l 13230 Did you say in response to his question that on occasion you would refer to CAT revenues as including both what is in this document, Appendix 6, page 5, referred to on the one hand as settlement, and on the other hand as CAT?
LISTNUM 1 \l 13231 MS CHALIFOUX: Yes, that's right.
LISTNUM 1 \l 13232 Again, you have to go back. What is included in our CAT, for instance, is the switching aggregation cost, what is now termed down South as an AT or a DC rate.
LISTNUM 1 \l 13233 Those rates are embedded in our bundled CAT.
LISTNUM 1 \l 13234 We also have contribution in there. Again, down South ‑‑ you know, that was pre‑2000 and there was a regime, or there was a per‑minute contribution rate.
LISTNUM 1 \l 13235 All of these charges are applied to the toll market everywhere. It is just that, in Northwestel's case, it is embodied in this bundled CAT.
LISTNUM 1 \l 13236 THE CHAIRPERSON: Bundled CAT.
LISTNUM 1 \l 13237 MS CHALIFOUX: Yes, using the Commission's term in Decision 2002‑45.
LISTNUM 1 \l 13238 THE CHAIRPERSON: Good. Which I, no doubt, should know, but don't.
LISTNUM 1 \l 13239 Then, to follow up ‑‑ and Mr. Ryan can complete, I don't want to get in his way ‑‑ revenue from the B circuit is toll revenue, or is it part of the settlement revenue?
LISTNUM 1 \l 13240 MS CHALIFOUX: If it is an intercarrier ‑‑ an interconnecting carrier like TELUS or Bell, we charge them a per‑minute transport rate from the point of their facility to where it connects with our facility, and then we haul it up to our Class 4 or 5, say, in Whitehorse or Yellowknife. So we charge that transport rate included in the settlement ‑‑ the revenues go into that settlement line.
LISTNUM 1 \l 13241 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 13242 MR. RYAN: If we look at the left‑hand margin, which I presented as the actual situation, we have a bundled CAT rate of 7 cents a minute, which runs from the point of interconnection to the point of termination.
LISTNUM 1 \l 13243 Is that accurate in the case of voice toll traffic?
LISTNUM 1 \l 13244 MR. WOODLAND: A quick inspection would say no, because the $23.73 million that you have taken off the list, which is shown as "Settlement", includes other charges that are not CAT‑rate charges.
LISTNUM 1 \l 13245 The distinction that we fail to make here ‑‑
LISTNUM 1 \l 13246 MR. RYAN: How big are those other items?
LISTNUM 1 \l 13247 MR. WOODLAND: I don't know. I have asked the support people if we have a breakdown of that settlement line, and we don't have it here with us.
LISTNUM 1 \l 13248 MR. RYAN: By the way, just to add a bit of confusion to this otherwise perfectly clear discussion, I note that I have an arithmetic error in my total on the revenue line. I think the $24.48 million should be $25.48 million.
LISTNUM 1 \l 13249 Subject to that, I think we will have to set aside that part of the discussion for the moment. You say that that revenue line isn't a perfect match for the CAT rate of 7 cents a minute ‑‑
LISTNUM 1 \l 13250 MS CHALIFOUX: Subject to check, I would be comfortable with giving an estimate in the area of, say, 60 percent.
LISTNUM 1 \l 13251 MR. RYAN: Sixty percent of the 23.73?
LISTNUM 1 \l 13252 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13253 MR. RYAN: If we go to the right‑hand side of the page, we have your proposed way of dealing with charging for the same routing of traffic. Your switch connect rate of .00825 dollars per minute would generate a revenue of $7.09 million, as I understand your evidence.
LISTNUM 1 \l 13254 Is that right?
LISTNUM 1 \l 13255 MR. WOODLAND: Where are you taking the volumes from?
LISTNUM 1 \l 13256 MR. RYAN: I am taking the dollars from Appendix 6, page 5, the $6.869 million plus the $219,000 ‑‑
LISTNUM 1 \l 13257 MS CHALIFOUX: Right. So you would have the same dilemma. Transport revenues, as an example, would be in there.
LISTNUM 1 \l 13258 MR. RYAN: Okay. Sort of a 60 per cent factor?
LISTNUM 1 \l 13259 MR. ROBERTS: Well, no, because you've now shrunk one portion of it and the other portion has stayed at the same per minute rate, so we would have to do the calculations to tell you what that change really was.
LISTNUM 1 \l 13260 MR. RYAN: Okay. Well, before I ask you to do anything like that I'll just take this a little bit further.
LISTNUM 1 \l 13261 Now, my understanding is that ‑‑ and I think the best place to look is appendix 6, page 5 again, you will, as a result of the introduction of the switch connect rate to replace the existing regime, whether we call it bundled CAT, CAT, CAT plus settlement, but we'll call it the existing regime, your revenues from providing this service to other carriers will fall from the sum of 23.733‑million plus 1.750‑million to, going over to the 2007 forecast, 6.869‑million plus 219‑thousand; is that right?
LISTNUM 1 \l 13262 MS CHALIFOUX: Right. So that's, again, the combined impact of two proposed rate changes, the replacement of the 7‑cent CAT with our switch connect rate.
LISTNUM 1 \l 13263 MR. RYAN: Right.
LISTNUM 1 \l 13264 MS CHALIFOUX: As well as a reduction in our transport rate.
LISTNUM 1 \l 13265 MR. RYAN: And is the reduction in transport rate reflected in the response to CRTC 13.01?
LISTNUM 1 \l 13266 MS CHALIFOUX: Yes, it is.
LISTNUM 1 \l 13267 MR. RYAN: Okay. I didn't take note of that not having understood exactly how this worked before. Could you, looking at 13.01, show me where that is.
LISTNUM 1 \l 13268 MS CHALIFOUX: Certainly. When you see the line proposed 2007 rate changes.
LISTNUM 1 \l 13269 MR. RYAN: Yes.
LISTNUM 1 \l 13270 MS CHALIFOUX: The line at the very bottom there, toll settlement impact of rate changes.
LISTNUM 1 \l 13271 MR. RYAN: Right.
LISTNUM 1 \l 13272 MS CHALIFOUX: Sixteen eight six four.
LISTNUM 1 \l 13273 MR. RYAN: Right.
LISTNUM 1 \l 13274 MS CHALIFOUX: So, that revenue reduction is partially related to the replacement of the CAT with the .8‑cent direct connect ‑‑ switch connect, as well as the proposed reduction in the transport rate reduction.
LISTNUM 1 \l 13275 MR. RYAN: Okay. It doesn't break out the transport rate reduction, that's just the combination of the numbers I was already referring to in appendix 6.
LISTNUM 1 \l 13276 MS CHALIFOUX: That's right. I mean, the ‑‑
LISTNUM 1 \l 13277 MR. RYAN: It doesn't break out the transport ‑‑
LISTNUM 1 \l 13278 MS CHALIFOUX: Fair to say that reducing the CAT from 7‑cents to .8‑cents is the lion's share, you know, roughly say three‑quarters.
LISTNUM 1 \l 13279 MR. RYAN: Well, I think, with your permission, Mr. Chairman, I would like an undertaking that breaks out these numbers so I can understand which part of this is pure CAT and which part is the reduction in the toll, toll connect ‑‑ or, sorry, the toll transport rate.
LISTNUM 1 \l 13280 MS CHALIFOUX: Well, the toll transport rate is a negotiated rate and we filed that rate in confidence, that particular proposal in confidence.
LISTNUM 1 \l 13281 MR. RYAN: Well, if you would take the undertaking, respond to my question and claim confidentiality where you think appropriate and file it with the Commission, we can then deal with that.
LISTNUM 1 \l 13282 MS CHALIFOUX: We have, in fact, filed details of that with the Commission already in existing interrogs.
LISTNUM 1 \l 13283 We could reference ‑‑ we could find the appropriate reference for you. Would that be appropriate?
LISTNUM 1 \l 13284 MR. RYAN: Since it's confidential it's obviously escaped my attention, but perhaps one way or another you could provide that information to me on the record, either by referring me to an existing interrogatory, the contents of which were not apparent to me, or by providing new information subject or not to confidentiality as you think appropriate in the first instance.
LISTNUM 1 \l 13285 Does that make any sense to anybody?
LISTNUM 1 \l 13286 THE CHAIRPERSON: I mean, you do understand what the purpose of the question is and you have also pointed out, no doubt appropriately, that there are confidential elements.
LISTNUM 1 \l 13287 I think the request, therefore, is do you think that it would be appropriate, or possible to produce something meaningful for Mr. Ryan in the light of the confidentiality constraints?
LISTNUM 1 \l 13288 Surely the answer to that is yes.
LISTNUM 1 \l 13289 MS CHALIFOUX: Yes. I mean, I know we have provided extensive detail already on the record.
LISTNUM 1 \l 13290 THE CHAIRPERSON: Yes.
LISTNUM 1 \l 13291 MS CHALIFOUX: So, it's just a matter of, I'll go back and look and see what ‑‑
LISTNUM 1 \l 13292 THE CHAIRPERSON: Yes, if you can ‑‑
LISTNUM 1 \l 13293 MS CHALIFOUX: ‑‑ was retained in confidence.
LISTNUM 1 \l 13294 THE CHAIRPERSON: Yes. If you can marshall that and if it is not clear to the ‑‑ it might be perfectly clear to you, but it might not be clear to the Commission or to Mr. Ryan or other participants, so if it is not sufficiently clear by the aggregation of different interrogatory answers, spell it out with due respect to confidentiality.
LISTNUM 1 \l 13295 MS CHALIFOUX: Fair enough.
LISTNUM 1 \l 13296 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 13297 MR. RYAN: Thank you very much.
LISTNUM 1 \l 13298 Now, the proposed switch connect rate, as I have understood it to date, would cover the switching element or the switching functions that take place in the class 4, class 5, but would not include any of the costs associated with the A‑links, wherever those happen to be used?
LISTNUM 1 \l 13299 MR. WOODLAND: By A‑links you mean the A‑links on your diagram?
LISTNUM 1 \l 13300 MR. RYAN: On my diagram.
LISTNUM 1 \l 13301 MR. WOODLAND: Okay. That is correct.
LISTNUM 1 \l 13302 MR. RYAN: So when Mr. Roberts, as he has occasionally referred to the switch connect rate as a cost‑based rate, it is a cost‑based rate subject to the explanation that it is only ‑‑
LISTNUM 1 \l 13303 MR. WOODLAND: Switching components.
LISTNUM 1 \l 13304 MR. RYAN: ‑‑ relating to some of the costs. Yes, not the whole costs that are depicted in the network presented in the TELUS document in front of you?
LISTNUM 1 \l 13305 MR. WOODLAND: Costs incurred in our major centres.
LISTNUM 1 \l 13306 MR. RYAN: For switching only?
LISTNUM 1 \l 13307 MR. WOODLAND: Class 4/5.
LISTNUM 1 \l 13308 MR. ROBERTS: Yes, that is correct.
LISTNUM 1 \l 13309 MR. RYAN: Now, the Commission asked you in interrogatory 26.02 to add in the costs associated with the A‑links, as I understood their question, and you came up with a revised switch connect rate of 0.0415 cents, is that correct?
LISTNUM 1 \l 13310 MR. ROBERTS: That is correct.
LISTNUM 1 \l 13311 MR. RYAN: So that 0.0415 cents would include what had already been included in what you called the switch connect rate plus the A‑links?
LISTNUM 1 \l 13312 MR. ROBERTS: Yes, it includes the facilities that we have called toll connect and that we have costed in that fashion.
LISTNUM 1 \l 13313 MR. RYAN: I don't see anywhere in the record an indication of how much revenue that change would make. See the new switch connect rate ‑‑ but can you tell me what the revenue associated with that would be?
LISTNUM 1 \l 13314 MR. ROBERTS: I thought we had, but I can't recall off the top of my head what that would be. Actually, ‑‑
LISTNUM 1 \l 13315 MR. RYAN: See, my understanding ‑‑
LISTNUM 1 \l 13316 MR. ROBERTS: ‑‑ Attachment 1 does show that, but it was filed in confidence.
LISTNUM 1 \l 13317 MR. RYAN: Okay. So that information is with the Commission at least?
LISTNUM 1 \l 13318 MR. ROBERTS: That is correct.
LISTNUM 1 \l 13319 MR. RYAN: Now your proposal is to replace the permanent charges associated with these facilities effectively with a subsidy from the National Contribution Fund?
LISTNUM 1 \l 13320 MR. ROBERTS: Correct. Actually, that is not a fair characterization. We don't have a direct linkage between the bundled CAT and the costs associated with these facilities. We merely have a subsidy requirement attributable to the treatment of these facilities as a monopoly access that is funded in part by a permanent rate, amongst other things. That is also correct.
LISTNUM 1 \l 13321 MR. RYAN: Well, I think between the two correct answers that I was offered Mr. Woodland might have been closer to the truth, Mr. Roberts. You I think made it perfectly clear in Appendix 4 to your evidence, page 2 of 2, that the subsidy you are looking for is a subsidy to cover the cost of toll connection. You called it the toll connection subsidy calculation.
LISTNUM 1 \l 13322 MR. ROBERTS: That is correct. The part where I was departing with your characterization of the situation is that we have a current permanent rate that covers this. In fact, we just have a subsidy requirement associated with this today and we have a permanent rate that is a form of implicit subsidy. The allocation of that subsidy versus the allocation of our supplementary funding is unclear.
LISTNUM 1 \l 13323 MR. RYAN: Could you say the last part again please?
LISTNUM 1 \l 13324 MR. ROBERTS: The allocation of the implicit subsidy associated with our bundled CAT rate and the allocation of our supplementary funding is unclear. It is merely a subsidy requirement that is achieved by an implicit subsidy in the form of a permanent rate and an explicit subsidy in the form of funding from the National Contribution Fund.
LISTNUM 1 \l 13325 MR. RYAN: Well, let me put it this way, and maybe Mr. Woodland could relate more to my way of putting it than you do, but you have toll connect facilities with respect to which you currently levy charges that you intend to eliminate, at least with respect to the A facilities. And at the same time you are asking the Commission to authorize the payment from the National Contribution Fund of the amount of $10.8 million essentially to replace the revenue that is foregone as a result of that rate change.
LISTNUM 1 \l 13326 MR. ROBERTS: Again, to be very clear, the bundled CAT is assessed to all minutes in Northwestel's operating territory regardless of whether or not they touch the toll connect facilities. In fact, a significant proportion of our minutes do not touch those facilities and yet they incur that charge.
LISTNUM 1 \l 13327 The charge is, again, just a form of usage‑based subsidy ‑‑ usage‑based contribution, as was permitted in the ‑‑ or I guess facilitated in the previous regime in the south prior to 2000‑745, in which the Commission, for every other telephone company, went to a revenue tax basis for the necessary subsidies.
LISTNUM 1 \l 13328 MR. RYAN: If you take a look at Northwestel Exhibit 2, which is the diagram that you provided for Mr. Pratt, as I understand you, you are saying, as I think you explained to Mr. Pratt, not all of the relevant traffic uses all of the facilities that you have presented there. In particular, although 100 per cent of the toll traffic comes into the class 4 or class 5, only 24.5 per cent goes ‑‑ for instance, the class 5 satellite, only 27.8 goes to the class 5 terrestrials. Is that the point you are making?
LISTNUM 1 \l 13329 MR. WOODLAND: Yes.
LISTNUM 1 \l 13330 MR. RYAN: But at the end of the day what you would like to do is stop collecting money from the carriers that use these toll connecting facilities and move instead to an arrangement under which you obtain compensation for the costs related to providing those facilities from the National Contribution Fund; is that a fair statement?
LISTNUM 1 \l 13331 MR. ROBERTS: Again, there is not the clear linkage between the usage of the facilities. I would categorize it as we want the implicit subsidy that is paid by these carriers on all of our minutes to be converted to an explicit subsidy that is sustainable.
LISTNUM 1 \l 13332 MR. RYAN: And how would you answer that question, Mr. Woodland?
LISTNUM 1 \l 13333 MR. WOODLAND: Sorry to say, pretty much the same way as Mr. Roberts because I think the other part that is key is that the current CAT charges are implicit in our toll rates as well and we are talking about removing that implicit subsidy and converting it to a form of explicit subsidy for these high‑cost facilities that have been treated by the Commission in the past as an extension of our monopoly local network.
LISTNUM 1 \l 13334 MR. RYAN: Okay. The net result of this would be that the wireless carriers that I referred to in the earlier part of our discussion or the toll carriers that use these facilities would pay a rate of zero for the use of link A and instead, assuming they are all Canadian carriers, would pay into a National Contribution Fund and you would draw a compensating amount from that fund?
LISTNUM 1 \l 13335 MR. WOODLAND: As far as I understand it, that is how it would work, yes.
LISTNUM 1 \l 13336 MS CHALIFOUX: You were referring to in your example wireless carriers or just all carriers?
LISTNUM 1 \l 13337 MR. RYAN: Wireless carriers or any other carrier that uses ‑‑
LISTNUM 1 \l 13338 MS CHALIFOUX: Okay.
LISTNUM 1 \l 13339 MR. RYAN: Yes.
LISTNUM 1 \l 13340 MS CHALIFOUX: Because again, as Mr. Woodland pointed out, wireless carriers generally don't use our toll connect facilities, they use our digital private line facilities.
LISTNUM 1 \l 13341 MR. RYAN: Well, we had a bit of a discussion about that. There are circumstances in which Mr. Woodland has confirmed that some traffic was routed using all these facilities and perhaps in other cases not all the same facilities were used. So I will just rely on the record in that respect for whatever clarity it offers on that point.
LISTNUM 1 \l 13342 MR. WOODLAND: Well, if you like, I could expand on that then because ‑‑
LISTNUM 1 \l 13343 MR. RYAN: I don't know that that will help me. I think I have got it more or less.
LISTNUM 1 \l 13344 MR. WOODLAND: Well, just very quickly. Some cellular customers would hit their dedicated facilities all the way back to wherever their switch is ‑‑
LISTNUM 1 \l 13345 MR. RYAN: Yes.
LISTNUM 1 \l 13346 MR. WOODLAND: ‑‑ and then come back to Northwestel on whatever facilities they might have for routing those calls to us and then possibly ride over our toll connect facilities but not necessarily.
LISTNUM 1 \l 13347 MR. RYAN: Okay. Well, since you reintroduced the subject, what does Bell Mobility do? Do they construct their own facilities or do they use yours?
LISTNUM 1 \l 13348 MR. WOODLAND: Bell Mobility uses our facilities by purchasing dedicated circuits to backhaul their traffic.
LISTNUM 1 \l 13349 MR. RYAN: Okay.
LISTNUM 1 \l 13350 Could we go to CRTC 2000‑2602, which I referred to earlier?
‑‑‑ Pause
LISTNUM 1 \l 13351 MR. RYAN: I'm interested in particular in page 6 of 7.
LISTNUM 1 \l 13352 As I understand the question the Commission asked you and as you answered it, the general thrust of it was: If you redo the switch connect rate to include the toll connect facilities, does that mean we can get rid of the $10.8 million subsidy from the National Contribution Fund?
LISTNUM 1 \l 13353 You say in your answer on page 6 of 7 under sub 4, "Not quite". Even if you do that you say there is a resulting residual subsidy requirement of $2.3 million. So the whole $2.8 million wouldn't go away.
LISTNUM 1 \l 13354 Have I reasonably accurately characterized what you told the Commission there?
LISTNUM 1 \l 13355 MR. ROBERTS: With the omission that the resulting rate would also be unsustainable going forward.
LISTNUM 1 \l 13356 MR. RYAN: Well, if I characterize what the question and the answer up to that point was, then I will come to my question.
LISTNUM 1 \l 13357 If you change the toll connect rate in the way the Commission proposed in the question ‑‑ and I think that yielded a new rate of 4.1 cents ‑‑ would that eliminate the need for the $10.8 million subsidy? You said:
"Not quite. There is still a residual subsidy requirement of $2.3 million." (As read)
LISTNUM 1 \l 13358 Up to that point am I accurately relating what has been said? Then I will come to my question.
LISTNUM 1 \l 13359 MR. ROBERTS: My colleagues confirm that that's ‑‑
LISTNUM 1 \l 13360 MR. RYAN: All right. So in the middle of the paragraph, as I say, you say:
"There is still a residual subsidy requirement of $2.3 million." (As read)
LISTNUM 1 \l 13361 It's what that subsidy requirement is that I'm trying to understand. You say:
"NOTE: The residual subsidy requirement arises as the switch connect rate is higher, but the company's model includes maintaining previously proposed toll rates necessary to ensure sustainability of revenues and provide more comparable rates." (As read)
LISTNUM 1 \l 13362 I just don't understand what you are saying.
LISTNUM 1 \l 13363 Could you explain it again?
LISTNUM 1 \l 13364 MR. ROBERTS: As we tried to explain to YTG, the package that we were proposing is presented as a whole. There are a number of cross impacts. With the proposal ‑‑ with the suggested scenario, hypothetical scenario posed by the Commission ‑‑ we noted that we didn't revisit the toll rates. There was room to pass the imputation test for our retail toll rates and we felt that we had to, at the very least, make the modest reductions that we had proposed with regard to the business toll rates regardless of this change.
LISTNUM 1 \l 13365 That said, it remains our view that this scenario as posed is not sustainable.
LISTNUM 1 \l 13366 MR. RYAN: Yes, okay. That's understood to be your evidence.
LISTNUM 1 \l 13367 If I can try summing up, then: If we adopt the toll connect rate as suggested in the particular Commission interrogatory, the requirement for the $10.8 million toll connect subsidy would disappear, but you would like to make some adjustments to your toll rates as a consequence of that that would generate a new subsidy requirement of $2.3 million.
LISTNUM 1 \l 13368 Is that fair?
LISTNUM 1 \l 13369 MR. ROBERTS: No, that's not fair, as you can imagine, in our view.
LISTNUM 1 \l 13370 If you take a step back, our proposal is, I guess again, an overall package. We did arrive at a balance going in at $10.5 million given a certain blend of rates. We were constrained in making those rate changes and in our view they don't go far enough.
LISTNUM 1 \l 13371 So the idea of increasing or lessening the reductions to our retail rates is not reasonable here.
LISTNUM 1 \l 13372 Again, I come back to this notion that the ‑‑
LISTNUM 1 \l 13373 MR. RYAN: Retail rates for what?
LISTNUM 1 \l 13374 MR. ROBERTS: For business toll in particular.
LISTNUM 1 \l 13375 MR. RYAN; All right.
LISTNUM 1 \l 13376 MR. ROBERTS: But I come back to this point of the current switch connect rate just not being sustainable.
LISTNUM 1 \l 13377 MR. RYAN: No. Let's not do the sustainability. We have your evidence on that and it is perfectly clear what your view is on that.
LISTNUM 1 \l 13378 MR. ROBERTS: Okay.
LISTNUM 1 \l 13379 MR. RYAN: If you can add any more explanation as to $2.3 million, I am interested in that. But I think maybe we have gone as far as we can on that too.
LISTNUM 1 \l 13380 MR. ROBERTS: I guess what I am having a fundamental problem with is your linkage of the subsidy amount and some sort of implication that it is tied to revenue requirements.
LISTNUM 1 \l 13381 This is a hypothetical that we did not view as reasonable, as sustainable. In this hypothetical we demonstrate that it doesn't balance. It is not a balanced proposal as ours is.
LISTNUM 1 \l 13382 We are not trying to make a linkage to subsidy requirement with our rate changes either; rather we are again maintaining that our subsidies are cost‑based. Instead, we are just saying look, this would leave a deficit. It is not a balanced approach under your proposed hypothetical.
LISTNUM 1 \l 13383 MR. RYAN: I think I will leave it at that.
LISTNUM 1 \l 13384 Could we go to Appendix 5, page 4, to your evidence.
LISTNUM 1 \l 13385 You have an entry towards the bottom ‑‑ first of all, let me say by way of explanation for those that are just turning to it, this I understand is a summary of your proposed rate changes.
LISTNUM 1 \l 13386 Is that correct?
LISTNUM 1 \l 13387 MS CHALIFOUX: Yes, it is.
LISTNUM 1 \l 13388 MR. RYAN: There is an entry in bold face towards the bottom of the table: "Wireless Service Provider Network Access".
LISTNUM 1 \l 13389 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13390 MR. RYAN: As I understand it, just to take the first line under "lineside access", you are proposing, for instance, to reduce the seven‑digit numbers assigned item from $.943 to $.472.
LISTNUM 1 \l 13391 And you have a number of similar, sometimes quite large, percentage reductions in various rates shown under that heading.
LISTNUM 1 \l 13392 Is that right?
LISTNUM 1 \l 13393 MS CHALIFOUX: That's right.
LISTNUM 1 \l 13394 MR. RYAN: Could you tell me, first of all, what a wireless service provider network access is?
LISTNUM 1 \l 13395 MS CHALIFOUX: It is the tariff that applies when a wireless service provider interconnects with the PSTN.
LISTNUM 1 \l 13396 MR. RYAN: Can we relate the service you are providing under that heading to anything that we see on the proposed switch connect rate document that I produced earlier?
LISTNUM 1 \l 13397 MS CHALIFOUX: I guess technically connection into our toll switch, our Class 4; but not anything to do with the toll connect, no.
LISTNUM 1 \l 13398 MR. RYAN: No, I am not talking about the toll connect now. In explaining to me what you are providing there, is this document helpful or not?
LISTNUM 1 \l 13399 MR. WOODLAND: Not really because you don't show the cellular switch.
LISTNUM 1 \l 13400 MR. RYAN: Okay.
LISTNUM 1 \l 13401 MR. WOODLAND: It is really about connecting the cellular switch back to the PSTN.
LISTNUM 1 \l 13402 MR. RYAN: If you look at the mobile phone that I have depicted there and the reference to POI, would that represent the cellular switch?
LISTNUM 1 \l 13403 MR. WOODLAND: Not in my way of thinking about it. Your diagram as shown would represent the cell site.
LISTNUM 1 \l 13404 MR. RYAN: Yes.
LISTNUM 1 \l 13405 MR. WOODLAND: The actual radio connection to the cell phone. In our standard implementations anyway, then there are dedicated facilities from that cell site, whether it is in our location or not, back to the cellular provider's switch. And from there they then route the calls back out, however it is that call is being terminated.
LISTNUM 1 \l 13406 MR. RYAN: Okay.
LISTNUM 1 \l 13407 Could we look next at CRTC‑1404.
LISTNUM 1 \l 13408 This is just to clarify in my mind ‑‑ and you may have addressed this earlier, Mr. Woodland, but perhaps not in precisely the terms I am going to raise the point now.
LISTNUM 1 \l 13409 The Commission asked you in 1404 to provide for the wireless service provider network access, and a variety of the other elements for which you propose to change the rates as depicted in that rate change summary table we have just been looking at, with cost justification.
LISTNUM 1 \l 13410 And specifically they asked you for a cost study for each of those items.
LISTNUM 1 \l 13411 As I understand it, you provided a cost study for one of those items, and you don't have a cost study that demonstrates the compensatoriness of any of the other rates.
LISTNUM 1 \l 13412 Is that correct?
LISTNUM 1 \l 13413 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13414 MR. RYAN: That, Mr. Chairman, I am sure you will be relieved to hear, is all I have for this panel.
LISTNUM 1 \l 13415 THE CHAIRPERSON: Thank you, Mr. Ryan.
LISTNUM 1 \l 13416 MR. RYAN: Thank you, ladies and gentlemen.
LISTNUM 1 \l 13417 THE SECRETARY: Mr. Chairman, is it possible to provide an exhibit number for the TELUS document?
LISTNUM 1 \l 13418 THE CHAIRPERSON: I hope so, because my colleague is deeply concerned that it is unnumbered at the moment.
LISTNUM 1 \l 13419 THE SECRETARY: It is called "Proposed Switch Connect Rate," and it will be TELUS Exhibit No. 5.
EXHIBIT NO. TELUS‑5: Document entitled "Proposed Switch Connect Rate"
LISTNUM 1 \l 13420 THE CHAIRPERSON: I think we will rise for the moment and reconvene at 3:45 p.m. Thank you.
‑‑‑ Upon recessing at 1530 / Suspension à 1530
‑‑‑ Upon resuming at 1545 / Reprise à 1545
LISTNUM 1 \l 13421 THE CHAIRPERSON: I understand that Mr. Rogers, representing TELUS, has some preliminary matters that he would like to deal with.
LISTNUM 1 \l 13422 MR. ROGERS: I am representing Northwestel.
LISTNUM 1 \l 13423 THE CHAIRPERSON: Forgive me.
LISTNUM 1 \l 13424 MR. ROGERS: At least as far as I am aware, unless there has been a change in counsel.
‑‑‑ Laughter / Rires
LISTNUM 1 \l 13425 MR. ROGERS: I had better check with Mr. Ryan on that.
LISTNUM 1 \l 13426 This is very much a housekeeping matter, Mr. Chairman. There were, as I mentioned briefly this morning, some transcript errors, which are fairly routine and minor, and I think pretty non‑contentious.
LISTNUM 1 \l 13427 We have given a hard copy to the court reporters, and I understand that there will be transcription changes. We will give a hard copy to anyone in the room who wants to get one. They can speak to us, and they can see the changes we propose to make.
LISTNUM 1 \l 13428 Secondly, in the morning's discussion there were some further interrogatories that came to us from the Commission staff, and there was some discussion about dates at which responses could be given, and certain dates were indicated by Commission counsel, Mr. McCallum. We can meet all of those dates, but we are prepared to move up the date and provide earlier the material in respect of the interrogatories on depreciation. I understand that those are of some particular interest to TELUS, so we will undertake to have the answers to those by next Wednesday, rather than the date originally suggested.
LISTNUM 1 \l 13429 The other dates apply, as indicated by Mr. McCallum.
LISTNUM 1 \l 13430 Lastly, this morning there was some discussion on an item regarding a series of years of expenses. I think it came up in the discussion with Mr. Rondeau. We gave an undertaking, and we have that ready. It is ready for filing.
LISTNUM 1 \l 13431 THE CHAIRPERSON: Thank you very much, Mr. Rogers.
LISTNUM 1 \l 13432 There were one, two or three undertakings that we will deal with at the end of this session. There is a commitment to the undertakings, but there are no real time deadlines, so we will just make sure that it is clear in everyone's mind.
LISTNUM 1 \l 13433 Before we proceed to questions from the CRTC staff and members for the panel, with respect to the planning of the proceeding, I am advised that we remain optimistic that we can conclude interrogatories and cross‑examination by sometime on Thursday, and it would be, at least in principle, assuming we achieve that objective, our intention to rise on Thursday and proceed to oral argument for Friday morning, if that suits parties and if there is no overriding concern or argument about that.
LISTNUM 1 \l 13434 I repeat, all of this is conditional on not discovering some sudden barrier to our forward progress in the next 48 hours.
LISTNUM 1 \l 13435 At the moment, I repeat, it looks like we are heading to conclude the cross‑examination part of the process at some point on Thursday, and we would expect, all other things being equal, to proceed to oral argument on Friday morning.
LISTNUM 1 \l 13436 Are there any comments or questions on that, so that parties can feel free to raise any issues or problems that that might raise in their minds?
LISTNUM 1 \l 13437 Hearing none, we will go ahead and proceed on that basic hypothesis.
LISTNUM 1 \l 13438 Madame la Secrétaire.
LISTNUM 1 \l 13439 THE SECRETARY: Yes. The document, the undertaking ‑‑ the exhibit from the undertakings that Northwestel just gave me will be numbered Northwestel No. 3.
LISTNUM 1 \l 13440 THE CHAIRPERSON: Thank you.
EXHIBIT NWTEL‑3: Operating expenses 2001-2005 (Requested by UCG)
LISTNUM 1 \l 13441 THE CHAIRPERSON: I believe we are now ready to proceed with questions from the CRTC Staff for the finance panel.
LISTNUM 1 \l 13442 MR. McCALLUM: Thank you, Mr. Chair.
EXAMINATION / INTERROGATOIRE
LISTNUM 1 \l 13443 MR. McCALLUM: Just a clarification, and if you said this I just didn't hear it.
LISTNUM 1 \l 13444 With respect to Northwestel Exhibit 2 which you filed earlier this afternoon and you listed the three communities, I didn't hear what the third community is.
LISTNUM 1 \l 13445 I heard Whitehorse and Yellowknife, but I didn't hear if you said the third community.
LISTNUM 1 \l 13446 MR. WOODLAND: Fort Nelson.
LISTNUM 1 \l 13447 MR. McCALLUM: Thank you. With respect to the productivity offset there was, as you know, some discussion this morning with respect to it and the reliability of the data underlying the proposed productivity offset.
LISTNUM 1 \l 13448 We don't want to take up or re‑examine those issues now, but I just want to do one short follow up and that would be, what it would take to develop the productivity offset based on more data points than you have.
LISTNUM 1 \l 13449 You have two data points right now, 1998 and 2006. If the Commission did think it was important to have a productivity offset based on more data points, what would it take in terms of time and resources to develop that?
LISTNUM 1 \l 13450 MR. WOODLAND: To be honest, Mr. McCallum, I think it would take the passage of a few years in which we tracked the relevant unit costs that would be needed to develop repeated studies over future years.
LISTNUM 1 \l 13451 My rationale for that being that we don't have the history of the relevant unit costs to reconstruct, as it were, studies either in the intervening period or prior to 1998.
LISTNUM 1 \l 13452 So, if the mechanism is the one that was used in these interrogatories, I honestly can't see any way other than allowing the passage of time to allow us to build up that trail of data.
LISTNUM 1 \l 13453 In some ways that same issue would apply to a total factor productivity calculation as well in terms of we don't have the data going back far enough, nor do we have it developed in some cases specifically for Northwestel.
LISTNUM 1 \l 13454 MR. McCALLUM: So, you are saying essentially you do not have the data itself, the underlying data?
LISTNUM 1 \l 13455 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13456 MR. McCALLUM: If you did have the data, what would it take in terms of time and resources and would you have to hire a consultant, or would you be able to do it in‑house?
LISTNUM 1 \l 13457 MR. WOODLAND: If we did have the data, if we did have the data we could do it in‑house. It would take longer than it would ‑‑ we would probably look to hire a consultant more for the ‑‑ more to make it quicker.
LISTNUM 1 \l 13458 MR. McCALLUM: And just in terms of what is lacking in terms of the data, could you just be a bit more specific in terms of what is lacking?
LISTNUM 1 \l 13459 MR. WOODLAND: Unit costs for ‑‑ installed first costs for capital components, that would be the primary gap.
LISTNUM 1 \l 13460 MR. McCALLUM: Is it, for example, the material costs or the transport costs or the labour costs? Again, I'm just trying to be ‑‑
LISTNUM 1 \l 13461 MR. WOODLAND: Okay. Well, given that any one study is supposed to be a prospective incremental study, what I don't have available to me now, for instance, is what the prospective cost to do a transport build in the year 2001 would have been, for instance.
LISTNUM 1 \l 13462 MR. McCALLUM: So, then effectively you're saying it's kind of a combination of all those components; is that right?
LISTNUM 1 \l 13463 MR. WOODLAND: That's right.
LISTNUM 1 \l 13464 MR. McCALLUM: I have a few questions related to interrogatory CRTC 6.03, so I wondered if you could get that handy.
LISTNUM 1 \l 13465 MR. WOODLAND: I have it.
LISTNUM 1 \l 13466 MR. McCALLUM: I'm looking in particular at attachment 1 and I think you've provided an abridged version of that for the public record and there's certain information for which you claim confidentiality that the Commission has.
LISTNUM 1 \l 13467 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13468 MR. McCALLUM: If I take the first page of attachment 1, for example, I see per NAS unit cost and, under that, I see loop installed first costs per network access service, NAS. I see non‑SIP and then below that I see SIP. And then I see a number of bullets as to what may be included under the loop IFC per NAS. Is that right so far?
LISTNUM 1 \l 13469 MR. WOODLAND: Yes.
LISTNUM 1 \l 13470 MR. McCALLUM: Could you explain where tower costs are included?
LISTNUM 1 \l 13471 MR. WOODLAND: Tower costs are not included in residential loop costs or residential CO costs or residential costs period actually.
LISTNUM 1 \l 13472 MR. McCALLUM: Can you explain why not please?
LISTNUM 1 \l 13473 MR. WOODLAND: Typically towers are part of our transport network.
LISTNUM 1 \l 13474 MR. McCALLUM: Therefore they are not used for residential NAS?
LISTNUM 1 \l 13475 MR. WOODLAND: That is correct.
LISTNUM 1 \l 13476 MR. McCALLUM: What about power generation costs? Can you explain where those are included?
LISTNUM 1 \l 13477 MR. WOODLAND: Power generation costs are included I believe later in the interrogatory.. Actually, they are not shown in this particular interrogatory which, if you looked in the model, Attachment 2..
LISTNUM 1 \l 13478 I would have to go ‑‑ if you give me a minute I will find the specific reference.
LISTNUM 1 \l 13479 I am sorry, I have confused myself. If you look on page 2 you can see ‑‑
LISTNUM 1 \l 13480 MR. McCALLUM: I am sorry, are we looking at Attachment 1 or Attachment 2?
LISTNUM 1 \l 13481 MR. WOODLAND: I am sorry, Attachment 1, page 2. We have power components under OT capital causal to demand and other power expense in ongoing expenses causal do demand.
LISTNUM 1 \l 13482 MR. McCALLUM: Could you state what is included in each of those? I am looking at both of them. First, per NAS unit cost power and also, below that, residential COE operating expense ‑‑
LISTNUM 1 \l 13483 MR. WOODLAND: Both of those ‑‑
LISTNUM 1 \l 13484 MR. McCALLUM: ‑‑ other power expense.
LISTNUM 1 \l 13485 MR. WOODLAND: ‑‑ both of those were derived through the use of cost factors. The capital causal to demand was derived by looking at the investment in power‑related assets and calculating a ratio of that to other relevant asset classes that tend to make use of those power assets, for instance microwave radio, switching equipment, data switching equipment.
LISTNUM 1 \l 13486 So we calculated a structure cost factor basically as a ratio of that and then applied that to the incremental capital required in residential PES. And then for power, an operating expense ratio to power equipment investment was determined and then used to calculate the operating expense.
LISTNUM 1 \l 13487 MR. McCALLUM: Can you given an example of how you did the calculation?
LISTNUM 1 \l 13488 MR. WOODLAND: Not at this time. I could undertake to do so.
LISTNUM 1 \l 13489 MR. McCALLUM: With the indulgence of the Chair, I take that as an undertaking.
LISTNUM 1 \l 13490 And just, again, on page 1 of Attachment 1 of 603 under loop IFC per NAS you have asset code 640, you have power and then per NAS unit cost you have (power). Can you explain what that means?
LISTNUM 1 \l 13491 MR. WOODLAND: Why that is in brackets? No. I think it is just an artefact of the way that this model was put together. It doesn't mean anything specifically.
LISTNUM 1 \l 13492 MR. McCALLUM: But what is the power for, what is included in the power, what does it mean?
LISTNUM 1 \l 13493 MR. WOODLAND: Oh, in the case of loop costs, very specifically, when there are carrier systems used to provide say feeder facilities those carrier systems draw power and have a power component included with them.
LISTNUM 1 \l 13494 If I am not being clear, a carrier system is an electronic system that multiplexes many, many lines onto a single set of facilities, say, two pairs or a fibre facility or something like that and so the nature of that electronic equipment is that it requires power.
LISTNUM 1 \l 13495 MR. McCALLUM: Would that be shown in the illustrative example that you will provide, for example?
LISTNUM 1 \l 13496 MR. WOODLAND: It will now.
LISTNUM 1 \l 13497 MR. McCALLUM: Thank you. I may have one other in this area but I will come back to it in a minute.
LISTNUM 1 \l 13498 I still have some more on 603 but to understand the next series of questions it would also be helpful if you can get 2608 in front of you.
LISTNUM 1 \l 13499 MR. WOODLAND: I have it.
LISTNUM 1 \l 13500 MR. McCALLUM: I am looking at page 304 in 2608 where you talk about the weighting and what you stated there was that the different capital cost results for community sizes in each province or territory, as presented in response to 603, are:
"...not the result of having geographically disaggregated unit cost information but rather are the result of different relative weighting of the relevant NAS or NAS per switch type in each community size range."
LISTNUM 1 \l 13501 (As read)
LISTNUM 1 \l 13502 Could you explain a bit what this weighting process was?
LISTNUM 1 \l 13503 MR. WOODLAND: Yes. In determining the information that was provided in 603, a number of communities were studied for loops and loop costs, and for COE costs we looked at specific implementations of our four main types of switches, red coms, DMS‑10s, the DMS‑100 and the GDD‑5s.
LISTNUM 1 \l 13504 Now, any given community has one switch type or another in particular and when we weighted up the amounts ‑‑ you have to keep in mind that we only studied some communities. So we looked at ‑‑ in a particular geographic group and exchange size band there may have been two communities studied for loops and loop costs and then we looked at, well, one of them may have been a red com and one of them may have been a DMS‑10 and if their NAS were 300 for one and 200 for the other, then the weighting together of those switch costs would result in a different result than another geographical group and exchange size band that might have the same two switches in the studied communities but with a different weighting of NAS across those switches.
LISTNUM 1 \l 13505 So the results that are shown in 603 where they are different for different geographical regions or community size groups, it is simply a result of that weighting. It is not a result of having specific information that says that it cost us 25 per cent more to instal the switch components in community X versus community Y.
LISTNUM 1 \l 13506 MR. McCALLUM: Maybe you answered it but the quote had two alternative methods. One was weighting the relevant NAS and the other alternative was or NAS per switch type in each community size range and I didn't quite get a handle on how the different alternative weightings seemed to work according to what I quoted from 2608.
LISTNUM 1 \l 13507 MR. WOODLAND: Correct. I would say that that is a typo. It is not meant to be an alternative. It is ‑‑ I often type the way that I talk, with parenthetical additions. So what I really should have just said was NAS per switch type.
LISTNUM 1 \l 13508 MR. McCALLUM: So when you are looking at switch type, are you looking at the response to interrogatory 1606 for the different switch types?
LISTNUM 1 \l 13509 MR. WOODLAND: Not right now. Could you clarify, please?
LISTNUM 1 \l 13510 MR. McCALLUM: Well perhaps you can turn to 1606.
LISTNUM 1 \l 13511 Again, I'm going to keep these things open at the same time, but 1606 has a list of switch types I believe.
‑‑‑ Pause
LISTNUM 1 \l 13512 MR. WOODLAND: Which part of 1606 are you referring to?
LISTNUM 1 \l 13513 MR. McCALLUM: I think it's the attachment, because you have listed ‑‑
LISTNUM 1 \l 13514 MR. WOODLAND: All right.
LISTNUM 1 \l 13515 MR. McCALLUM: ‑‑ wire centres, areas and densities.
LISTNUM 1 \l 13516 MR. WOODLAND: Yes.
LISTNUM 1 \l 13517 MR. McCALLUM: Some of the information you have provided in confidence and some you have not, but the switch types are not in confidence.
LISTNUM 1 \l 13518 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13519 MR. McCALLUM: Nor is the rate group designation on the far right according to, I think, the methodology set out in 2001‑238.
LISTNUM 1 \l 13520 Could you just give an example of how the factors would work done together? Say I took one that was Group E for example. I see Carcross as Group E with a DMS SRSC switch.
LISTNUM 1 \l 13521 How would you do that in terms of the weighting, just as an illustration?
LISTNUM 1 \l 13522 MR. WOODLAND: You mean the weightings that resulted in the results shown in 603?
LISTNUM 1 \l 13523 MR. McCALLUM: Yes, taking the information from 1606 how does it translate into 603?
LISTNUM 1 \l 13524 MR. WOODLAND: It would only do that if Carcross, say, were the communities studied in the particular grouping. So if we looked at Yukon and Annex X between 500 and 1,500, if Carcross had been the studied community we would have taken the DMS IFC costs, the NAS ‑‑ sorry, I looked at the Annex X and called it NAS ‑‑ and then weight that according to its NAS with whatever other communities happen to have been studied in that particular Yukon and between 500 and 1,500 NAS grouping.
LISTNUM 1 \l 13525 So if the other community had been, say, I don't know, Beaver Creek, which had a certain amount of NAS that was less or more than Carcross, would be less than Carcross', then the result for the Yukon and that community size would be weighted more towards Carcross' costs, including its loop costs, because Carcross has more NAS.
LISTNUM 1 \l 13526 MR. McCALLUM: When you say "NAS", it's total NAS I take it, which is the total of columns A and B of 1606?
LISTNUM 1 \l 13527 MR. WOODLAND: Correct.
LISTNUM 1 \l 13528 MR. McCALLUM: When you are referring to exchange size on Interrogatory 603, again just taking the first one for example, you had three examples, less than 500, 500 to 1,500 and more than 5,000 NAS. Those were the exchange size the way you did it that way.
LISTNUM 1 \l 13529 Is that correct?
LISTNUM 1 \l 13530 MR. WOODLAND: Yes. Those are the only three examples available in the Yukon.
LISTNUM 1 \l 13531 MR. McCALLUM: If I look again at that very first table in 603, and if I look at "Outside Plant Equipment", can you explain how the weighting factor was applied for outside plant equipment?
LISTNUM 1 \l 13532 MR. WOODLAND: Well, specifically the studied communities ‑‑ and we provided an example of the detail for studied communities I believe in 2606 ‑‑ and I think the IFCs for loops was Attachment 1 ‑‑ where again we only sampled some communities to determine loop costs and we tried to pick communities that we thought would be representative of other communities roughly their same size.
LISTNUM 1 \l 13533 Then, where more than one communities was studied within the group, the costs of the two of them were weighted together according to their NAS, the same as with the switching components.
LISTNUM 1 \l 13534 MR. McCALLUM: Would you also have weighted the outside plant costs based on the percentage of NAS served by copper versus fibre?
LISTNUM 1 \l 13535 MR. WOODLAND: I don't think so.
LISTNUM 1 \l 13536 MR. McCALLUM: Is there just one technology? For example, is it just copper?
LISTNUM 1 \l 13537 MR. WOODLAND: No, there is not just one technology, but there is no reason to weight them particularly.
LISTNUM 1 \l 13538 MR. McCALLUM: So the type of material used did not figure in the weighting. Is that what you are saying?
LISTNUM 1 \l 13539 MR. WOODLAND: Subject to check, I don't think so.
LISTNUM 1 \l 13540 We do not have an extensive amount of fibre in our outside plant.
LISTNUM 1 \l 13541 MR. McCALLUM: Just to take a totally hypothetical example, if the cost of copper was $500 and the cost of fibre was $1,000, would you have weighted them according to those costs?
LISTNUM 1 \l 13542 MR. WOODLAND: I am going to have to go back and check in the model.
LISTNUM 1 \l 13543 MR. McCALLUM: So I will take that as an undertaking to check and verify.
LISTNUM 1 \l 13544 MR. WOODLAND: Sure.
‑‑‑ Pause
LISTNUM 1 \l 13545 MR. McCALLUM: If I look at central office equipment, which would be on page 2 of Attachment 1 to 603, would the weighting done there for central office equipment have been done according to the different switching technologies?
LISTNUM 1 \l 13546 MR. WOODLAND: That is correct.
LISTNUM 1 \l 13547 MR. McCALLUM: It is easy to make the link between that one and 1606 which has the list of the different types of switching technologies, such as DMS‑10, RedCom, et cetera.
LISTNUM 1 \l 13548 MR. WOODLAND: I suppose, yes.
LISTNUM 1 \l 13549 MR. McCALLUM: Would an electronic version with formulas of the response to Interrogatory 2606, Attachments 1 to 8, explain the methodology in greater detail used to derive the installed first cost per NAS based on the weighting process mentioned?
LISTNUM 1 \l 13550 MR. WOODLAND: There is no single version of that. That is extracts from several different study files.
LISTNUM 1 \l 13551 MR. McCALLUM: Would you be able to provide the different electronic versions with formulas for the Commission?
LISTNUM 1 \l 13552 MR. WOODLAND: Yes.
LISTNUM 1 \l 13553 MR. McCALLUM: I will take that as an undertaking as well, if I may.
‑‑‑ Pause
LISTNUM 1 \l 13554 MR. McCALLUM: Again if we look at 1606, could you specify which one of the switch types in the different locations have access tandem switches?
LISTNUM 1 \l 13555 MR. WOODLAND: Whitehorse, Yellowknife and Fort Nelson.
LISTNUM 1 \l 13556 MR. McCALLUM: The same three as referred to in Northwestel Exhibit 2 that you produced a little earlier.
LISTNUM 1 \l 13557 MR. WOODLAND: Correct.
LISTNUM 1 \l 13558 MR. McCALLUM: Does the company have any DMS‑250 IXC functionality in its switching network?
LISTNUM 1 \l 13559 MR. WOODLAND: Subject to check, I don't think so.
LISTNUM 1 \l 13560 Technically, our DMS‑100 is a DMS‑100/200. The 200 represents the Class 4 functionality; the 100 represents the Class 5 functionality.
LISTNUM 1 \l 13561 And beyond that, you have exceeded my depth of knowledge with regards to switching.
LISTNUM 1 \l 13562 MR. McCALLUM: I'm sorry, was that for the three switches that you just mentioned, Whitehorse ‑‑
LISTNUM 1 \l 13563 MR. WOODLAND: DMS‑200 is in Whitehorse, and the switches in Yellowknife and Fort Nelson are GDD‑5s, which, effectively, have the same functionality. They are Class 4/5 switches.
LISTNUM 1 \l 13564 MR. McCALLUM: So, effectively, those three switches are Class 4/5 switches.
LISTNUM 1 \l 13565 Is that right?
LISTNUM 1 \l 13566 MR. WOODLAND: Correct.
LISTNUM 1 \l 13567 MR. McCALLUM: I will take an undertaking for you to check if any of those switches have DMS‑IXC functionality.
LISTNUM 1 \l 13568 MR. WOODLAND: Could you repeat the acronym, please?
LISTNUM 1 \l 13569 MR. McCALLUM: DMS‑250 IXC ‑‑ for "interexchange carrier", I guess ‑‑ functionality.
LISTNUM 1 \l 13570 Of course, if you don't mind, if there is any DMS‑250 IXC functionality, I would appreciate it if you would include where it exists.
LISTNUM 1 \l 13571 MR. WOODLAND: Certainly.
LISTNUM 1 \l 13572 MR. McCALLUM: I don't know if you have to consult it, but in Interrogatory 2501 you set out the six locations where CCS‑7 is available, and I think the six locations were Whitehorse, Yellowknife, Fort Nelson, Inuvik, Iqaluit and Norman Wells.
LISTNUM 1 \l 13573 That is right so far?
LISTNUM 1 \l 13574 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13575 MR. McCALLUM: Could the company implement DMS‑250 IXC functionality in any of those switches? If so, could you give some idea as to the costs?
LISTNUM 1 \l 13576 MR. ROBERTS: If possible, we could undertake to take this up again tomorrow with the Policy Panel and have time to be equipped to answer that question at that time.
LISTNUM 1 \l 13577 I believe there is a linkage to the local competition broadly.
LISTNUM 1 \l 13578 MR. McCALLUM: Yes, I appreciate that. I can do it with you or with them.
LISTNUM 1 \l 13579 Because I wanted to know an approximation of the costs, I thought it might be worth asking this panel, but if it is better asked to the other one, then so be it.
LISTNUM 1 \l 13580 Could you also clarify for the record where equal access is available?
LISTNUM 1 \l 13581 MS CHALIFOUX: In the four locations: Whitehorse, Yellowknife, Fort Nelson and Iqaluit.
LISTNUM 1 \l 13582 MR. McCALLUM: Are there equal access providers in those locations?
LISTNUM 1 \l 13583 MS CHALIFOUX: In three of the four, not Iqaluit.
LISTNUM 1 \l 13584 MR. McCALLUM: Do you have any idea why only in three locations?
LISTNUM 1 \l 13585 MS CHALIFOUX: It is just based on the requests of where the carrier chooses to interconnect with us on an equal access basis.
LISTNUM 1 \l 13586 MR. McCALLUM: If I could make one quick return to the tower costs that we discussed a bit earlier, those were referred to, as we know, and I asked if they were included anywhere in 603, and I think you said no.
LISTNUM 1 \l 13587 I wondered if they were included anywhere in Interrogatory 2602, and in particular ‑‑
LISTNUM 1 \l 13588 When you have Interrogatory 2602, let me know.
‑‑‑ Pause
LISTNUM 1 \l 13589 MR. McCALLUM: I am looking in particular at page 2 and if the tower costs are included in any of the rates that are specified there?
LISTNUM 1 \l 13590 MR. WOODLAND: No, tower costs were treated as fixed costs that were not incremental to service.
LISTNUM 1 \l 13591 MR. McCALLUM: So, tower costs are not included in the toll connect facilities set out in page 2 of interrogatory 26.02?
LISTNUM 1 \l 13592 MR. WOODLAND: That's correct.
LISTNUM 1 \l 13593 MR. McCALLUM: Thank you. I wondered if I can clarify something that came out of the discussion, I think it was mostly with Mr. Roberts yesterday.
LISTNUM 1 \l 13594 There's several references in the transcript to, the revenue per line excluding supplemental funding is approximately 1.5 times in Northwestel's operating area versus the average rate in Canada.
LISTNUM 1 \l 13595 I think Mr. Roberts said that several times yesterday; is that right?
LISTNUM 1 \l 13596 MR. ROBERTS: Yes, I did.
LISTNUM 1 \l 13597 MR. McCALLUM: What I couldn't recall, maybe you can help me, was where, if anywhere that's stated in the evidence?
LISTNUM 1 \l 13598 MR. ROBERTS: It's actually in the evidence. If you give me a second I'll cite it specifically as to paragraph.
LISTNUM 1 \l 13599 I'm afraid I'm not finding it quickly, but it is in fact in our evidence and it was a calculation in regard to the data presented in the October, 2005 report to the Governor‑in‑Council created by the Commission.
LISTNUM 1 \l 13600 MR. McCALLUM: So, I'll take it as a undertaking that you'll just find the location and provide it to us in due course?
LISTNUM 1 \l 13601 MR. ROBERTS: Fair enough.
LISTNUM 1 \l 13602 MR. McCALLUM: I have a series of questions based on it, but I'm hoping that you can respond to them even though we don't have it handy.
LISTNUM 1 \l 13603 If you don't, then I may have to take undertakings for several of the questions.
LISTNUM 1 \l 13604 First of all, is the calculation of the 1.5 in the evidence, to the best of your recollection?
LISTNUM 1 \l 13605 MR. ROBERTS: Yes, it is in the evidence.
LISTNUM 1 \l 13606 MR. McCALLUM: And when you're referring to the 1.5 times, are you referring to total revenue per line including local and toll, residential and business, excluding supplemental funding, divided by the total network access services; is that the way it is?
LISTNUM 1 \l 13607 MR. ROBERTS: That's the calculation for the amount of Northwestel's revenue and the denominator is, I guess the comparator for Canada is the wire line average revenue per NAS cited in the report to Governor‑in‑Council.
LISTNUM 1 \l 13608 MR. McCALLUM: And that's based on the existing rates?
LISTNUM 1 \l 13609 MR. ROBERTS: That is correct.
LISTNUM 1 \l 13610 MR. McCALLUM: Sorry, I wasn't quite clear, when ‑‑ or your answer wasn't quite clear to me, maybe it is, but you're comparing comparables, you're comparing ‑‑ the numerator and the denominator are the same in both Northwestel territory and southern Canada; is that it?
LISTNUM 1 \l 13611 MR. ROBERTS: That's correct, I misspoke. They're comparatives and the Governor‑in‑Council report includes an average revenue per line for wire line and wireless separately.
LISTNUM 1 \l 13612 We have compared ours to the wire line.
LISTNUM 1 \l 13613 MR. McCALLUM: Thank you. Can you say what the equivalent number would be based on Northwestel's proposed rates as compared to the south?
LISTNUM 1 \l 13614 MR. ROBERTS: I can undertake to do that tomorrow.
LISTNUM 1 \l 13615 MR. McCALLUM: Thank you, that's helpful.
LISTNUM 1 \l 13616 Could you also state what would be the equivalent number, Northwestel as compared to the south, if we were to compare basic exchange and optional services per NAS, network access service?
LISTNUM 1 \l 13617 THE CHAIRPERSON: Mr. McCallum, just to put the record straight, my colleague has found the place in the evidence at which this ‑‑
LISTNUM 1 \l 13618 COMMISSIONER NOÉL: It's paragraph 204 and 205 of your evidence where you refer to $98 as an average revenue per line in the south, or across Canada and $152 at paragraph 205 for Northwestel.
LISTNUM 1 \l 13619 MR. McCALLUM: Thank you.
LISTNUM 1 \l 13620 MR. ROBERTS: I'm grateful.
LISTNUM 1 \l 13621 MR. McCALLUM: So, what I just asked about, and I'll just repeat the question just for clarity. I was asking what the equivalent number would be as compared to the south if we were to compare basic exchange and optional services per NAS?
LISTNUM 1 \l 13622 MR. ROBERTS: I will have to find the relevant comparator in that Governing Council report. If it is available, I can provide the comparison. I am not certain that it is there, but..
LISTNUM 1 \l 13623 MR. McCALLUM: Thank you. Well, I will take that as an undertaking on a best efforts approach to check and do what you can.
LISTNUM 1 \l 13624 I have one final question in this series. This question, of course, pertains to residential service. And my final question in this series of questions is what would be the equivalent number, Northwestel territory as compared to the south, if we were to compare the proposed Northwestel basic exchange residential service rates, including optional services per NAS?
LISTNUM 1 \l 13625 MR. ROBERTS: Okay, again, we will do that a best effort basis.
LISTNUM 1 \l 13626 MR. McCALLUM: Thank you very much.
LISTNUM 1 \l 13627 Panel and Mr. Chair, I now have a series of questions about depreciation and so to respond to them perhaps you could put 13.06 in front of you.
LISTNUM 1 \l 13628 MS CHALIFOUX: I believe we have it.
LISTNUM 1 \l 13629 MR. McCALLUM: Could I take you to Attachment 1 please?
LISTNUM 1 \l 13630 I am looking at column 3, whole life depreciation, and I am looking at cable plant, code 60. On the first line it says 20 years and the whole life depreciation is roughly $2.465 million, is that right?
LISTNUM 1 \l 13631 MS CHALIFOUX: That is correct.
LISTNUM 1 \l 13632 MR. McCALLUM: Down at the bottom of the page for the same code, code 60, for 22 years I seem to see the same number, $2.465 million. Is that number correct?
LISTNUM 1 \l 13633 MS CHALIFOUX: Yes.
LISTNUM 1 \l 13634 MR. McCALLUM: Right below it I see cable plant 60, 24 years, and again the same number, $2.465 million. I must confess, I am a little puzzled as to why the same number is there for 20, 22 and 24 years and I am hoping that you can assist.
LISTNUM 1 \l 13635 MS CHALIFOUX: Right, so this comes from our depreciation studies, it is the unadjusted rate. So then that is, in essence, your starting point and then you adjust there for your ‑‑ like, the remaining life adjustments.
LISTNUM 1 \l 13636 MR. McCALLUM: Maybe I am wrong, but I thought that numbers should be different. Given that they are different average surface lives, I thought the numbers should, frankly, be different, that 20 years would have the biggest number, 22 would have a middle number and 24 would have a smaller number and I wondered if the amounts were simply reproduced in error in this table by chance.
LISTNUM 1 \l 13637 MS CHALIFOUX: No. The adjustments come in in the later columns where you see, for instance, the impact of the remaining life adjustment.
LISTNUM 1 \l 13638 MR. McCALLUM: I am sorry, which column are you referring to, please?
LISTNUM 1 \l 13639 MS CHALIFOUX: The column 5.
LISTNUM 1 \l 13640 MR. McCALLUM: Could you explain how that works then? How does it ‑‑ when you take the same amount away, how does it result in different numbers for the remaining life adjustment? Could you just run me through an example?
‑‑‑ Pause
LISTNUM 1 \l 13641 MR. HAMELIN: Are you looking for the actual depreciation for the year based on those three different lives?
LISTNUM 1 \l 13642 MR. McCALLUM: Well frankly, what I would have thought is that if you have three different hypotheses, in other words, three different ASLs, average service lives, I would have thought that a change in the ASL would have resulted in a change in the whole life depreciation amount and in this table it seems not to do so and it surprised me a bit, so I am trying to get some clarity. If by any chance this was an error, then I would like to give you the opportunity to correct the error.
LISTNUM 1 \l 13643 MS CHALIFOUX: No, it is not an error. Maybe to your point we can walk through an example.
LISTNUM 1 \l 13644 So you start with your whole life depreciation, your unadjusted amount, and then what you have to add from there is the adjustment due to the over‑ or under‑accruals, essentially the depreciation reserve deficiency. So it is that balance that will change as a result of the proposed life change.
LISTNUM 1 \l 13645 So if you want to walk through the first example, you take your whole life depreciation. So let's just round that to $2.5 million and let's just set that aside for a minute.
LISTNUM 1 \l 13646 And then you go over to column 8, the account over/under‑accrual. This is in essence the depreciation reserve deficiency. And you take that amount and you divide it over your average remaining life to come up with the adjustment that is applicable for the year.
LISTNUM 1 \l 13647 So then you add that to your whole life depreciation amount and the net of those two. So now you are adding column 3 and column 5 and that equals your account depreciation.
LISTNUM 1 \l 13648 MR. McCALLUM: So for 20 years I would take $2.5 million and add to it a negative 697,000?
LISTNUM 1 \l 13649 MS CHALIFOUX: Well, these numbers are consistently presented this way but in essence you are taking ‑‑ the formula shows you take the whole life, subtract the remaining life adjustment. So in this case it is a negative, so you are adding the positive, so thus your 3.163 in the far right.
LISTNUM 1 \l 13650 MR. McCALLUM: And so the far right column is the depreciation expense for the year, is that it or ‑‑
LISTNUM 1 \l 13651 MS CHALIFOUX: Yes, that is right.
LISTNUM 1 \l 13652 MR. HAMELIN: That follows the pattern you were expecting. That is where I was going to.
LISTNUM 1 \l 13653 MR. McCALLUM: So for the first year it is 3.163 if it is 20 years and for 22 years it would be 2.8 and for 24 years it would be 2.5; is that right?
LISTNUM 1 \l 13654 MS CHALIFOUX: Yes.
‑‑‑ Pause
LISTNUM 1 \l 13655 MR. McCALLUM: Thank you.
LISTNUM 1 \l 13656 Could I take you, then, to Attachment 2 of 1306?
‑‑‑ Pause
LISTNUM 1 \l 13657 MS CHALIFOUX: We have it.
LISTNUM 1 \l 13658 MR. McCALLUM: In the question that the Commission asked, the Commission asked Northwestel to provide certain information about calculating the depreciation reserve deficiency according to the method set out in December 97‑9, namely on a straight‑line basis.
LISTNUM 1 \l 13659 What I notice in the line DRD amortization method according to Decision 97‑9 DRD over ARL in Attachment 2 is that the amounts are not level but rather they are the same amount, $7.1 million for the first two years and then in 2009 they decline to $4.4 million and to $4.1 million in 2010.
LISTNUM 1 \l 13660 Can you explain why the numbers are lower in 2009‑2010?
LISTNUM 1 \l 13661 MS CHALIFOUX: Sure. I mean, this would be driven by the profile of our accounts. The methodology, as you know, is applied on an asset‑code by asset‑code basis and it is at the asset code level where you get the straight line impact, if you will.
LISTNUM 1 \l 13662 But in Northwestel's situation we do have a couple of anomalies in the sense we have some asset codes that when you apply the recovery of the depreciation reserve deficiency over the average remaining life, that average remaining life is very small for a couple of asset codes that happen to have a large depreciation reserve deficiency, therefore the adjustment under that methodology is quite big.
LISTNUM 1 \l 13663 So if you want to go back to Attachment 1, just to illustrate an example of that anomaly, take asset code 490, the average remaining life is 2 years, that two years in column 4.
LISTNUM 1 \l 13664 Do you see that?
LISTNUM 1 \l 13665 MR. McCALLUM: Yes, I do.
LISTNUM 1 \l 13666 MS CHALIFOUX: And the depreciation reserve deficiency amount for this particular asset code is $2.4 million in column 8.
LISTNUM 1 \l 13667 So when you amortize the size of that deficiency over the average remaining life, you are just taking it divided by two, so yes, it will be on a straight‑line basis for that particular asset code, but because of the magnitude of it ‑‑ and again, the susceptibility that Northwestel has sometimes to big adjustments on generally small numbers ‑‑ you end up with the depreciation reserve deficiency for this particular year to be $7 million.
LISTNUM 1 \l 13668 But you will see within two years for instance, back to that asset code, that depreciation reserve deficiency would have been eliminated. We just happen to have a number of examples, asset code 570, satellite earth stations with an average remaining life of 2.2 years.
LISTNUM 1 \l 13669 What's another one? Test equipment for instance, 2.4 years. So again, it's just the nature of our particular asset base and the state of ‑‑ the mix, if you will, of our depreciation reserve deficiency.
LISTNUM 1 \l 13670 MR. McCALLUM: If you can provide it that would be extremely helpful, that is if you can provide the detailed calculations that were used to derive the DRD amortization amounts for those two years 2009 and 2010 and the electronic spreadsheets with the formulas. If you have that and can provide it, that would be of great assistance to us.
LISTNUM 1 \l 13671 MS CHALIFOUX: We can look at that. I believe it might have even been asked in one of the interrogatories we received.
LISTNUM 1 \l 13672 Anyway, yes, we can do that.
LISTNUM 1 \l 13673 MR. McCALLUM: Thank you. I appreciate that very much.
LISTNUM 1 \l 13674 Finally, looking again at those figures, and again eyeballing them and doing some very preliminary math, what would you think about the Commission taking those numbers, 7.1, 7.1, 4.4 and 4.1 and saying, "All right, 97.9 looked for a straight line amount in the DRD.
LISTNUM 1 \l 13675 Let's just take those four amounts and divide by four and come up with a number. It takes you to about $5.68 million per year.
LISTNUM 1 \l 13676 What would you think of the Commission doing that for the DRD?
LISTNUM 1 \l 13677 MR. HAMELIN: I would think that would be a good move.
LISTNUM 1 \l 13678 MR. McCALLUM: I'm sorry, say that again, please.
LISTNUM 1 \l 13679 MR. HAMELIN: That would be fine.
LISTNUM 1 \l 13680 MR. McCALLUM: Thank you.
LISTNUM 1 \l 13681 Those are my questions, Mr. Chair.
LISTNUM 1 \l 13682 THE CHAIRPERSON: Thank you, Mr. McCallum.
LISTNUM 1 \l 13683 Commissioner Cram.
LISTNUM 1 \l 13684 COMMISSIONER CRAM: Thank you.
LISTNUM 1 \l 13685 I would like to take you to Appendix 5 of your evidence. It is the new proposed rate restructuring.
LISTNUM 1 \l 13686 MR. HAMELIN: I have Appendix 5.
LISTNUM 1 \l 13687 COMMISSIONER CRAM: I just wanted to be clear. In all of these rates for either the present or the proposed, there is only one item for which you have done a cost study and for which you are aware whether they are compensatory or compensatory with the mark‑up.
LISTNUM 1 \l 13688 MS CHALIFOUX: We have done cost studies on the toll market as well as the exchange services.
LISTNUM 1 \l 13689 COMMISSIONER CRAM: So on the wireless service provider network access, is it fair to say you don't know if the present amounts are compensatory, nor if the proposed rates are compensatory?
LISTNUM 1 \l 13690 That is items ‑‑ they are not numbered. They are at the bottom.
‑‑‑ Pause
LISTNUM 1 \l 13691 MS CHALIFOUX: What we have done there ‑‑ and again given the limited resources that we have at Northwestel costing department here, and particularly with the lineside access rates for the wireless network access tariff, it is a very complicated study to undertake.
LISTNUM 1 \l 13692 What we have done is a benchmarking study, and that has been accepted in previous tariff filings by the Commission.
LISTNUM 1 \l 13693 We looked at our rates relative to the ILECs, as well as Northern and Télébec, and discovered a very significant discrepancy. And even with these proposed rate reductions, they would still be double, twice that of the ILECs, and 18 percent above what Télébec and Northern charge.
LISTNUM 1 \l 13694 So based on that evidence, we derived that our rates would indeed be compensatory.
LISTNUM 1 \l 13695 COMMISSIONER CRAM: I guess I am looking at this and they really are quite striking reductions. I am mindful that those reductions will be going into primarily the pockets of your affiliates and your mother's other daughter.
LISTNUM 1 \l 13696 I am asking if there is a problem right now. There doesn't appear to be a problem.
LISTNUM 1 \l 13697 So why would we not keep this implicit subsidy because it really is a shifting of numbers between various companies.
LISTNUM 1 \l 13698 MS CHALIFOUX: Again, we have received a number of complaints from the customers in this case. Having looked at our tariff and seen ‑‑ the other issue, besides being much higher obviously, is that we inadvertently created a bit of an anomaly when we introduced our trunkside rates.
LISTNUM 1 \l 13699 We just recently went through a process ‑‑ well, maybe not recently; maybe two years ago ‑‑ of introducing trunkside rates for wireless network access and ended up at the time benchmarking to Télébec's rates. Those rates were approved, which was fine. That is what the customer had asked for.
LISTNUM 1 \l 13700 Then they went back and looked at the line side rates, and they clearly pointed out that the relationship between our line side rates and our trunk side rates were the exact opposite of what you see down South.
LISTNUM 1 \l 13701 So, again, we endeavoured to take a look at that and do some proper benchmarking, and talk to a number of folks in the industry about the nature of this service, the difference between line side and trunk side, and we came to the conclusion that our price structure was, indeed, inconsistent with how it is priced in the South.
LISTNUM 1 \l 13702 So we definitely had to address this issue at some point.
LISTNUM 1 \l 13703 MR. ROBERTS: It is also important to note that there are other wireless service providers operating, including New North Networks and ICE Wireless.
LISTNUM 1 \l 13704 In addition, I would suggest that it may not be fair to impose an additional burden on Bell Canada. They are also the largest payer into the national subsidy fund, and they are, again, one of the two significant payers of the current implicit subsidy that is embedded in the CAT rate, as well.
LISTNUM 1 \l 13705 So to penalize them based on the relationship is, again, perhaps not reasonable. In our view, the current rates represent an extraordinary mark‑up or contribution versus the still healthy mark‑up of the proposed rate.
LISTNUM 1 \l 13706 COMMISSIONER CRAM: What percentage of the market do you understand ICE and New North ‑‑
LISTNUM 1 \l 13707 New North is not the one that was rolled into Bell Mobility.
LISTNUM 1 \l 13708 New North, what percentage of the market do they have?
LISTNUM 1 \l 13709 MR. ROBERTS: New North Network would be, I guess, a major player in Inuvik. I don't know the percentage of market.
LISTNUM 1 \l 13710 I also neglected to mention TELUS Mobility, which is extremely active in the very busy corridor in northern B.C., which is driven by a lot of oil and gas activity.
LISTNUM 1 \l 13711 Again, there are a large number of minutes also associated with TELUS' wireless activity in our operating territory.
LISTNUM 1 \l 13712 COMMISSIONER CRAM: It would seem to be six of one and half a dozen of another, though, in your argument about Bell, Mr. Roberts. If they are still a large payer into the national fund, it might be six of one and half a dozen of another whether they would be paying more now or then.
LISTNUM 1 \l 13713 Would you not agree with that?
LISTNUM 1 \l 13714 MR. ROBERTS: Taking things to a little bit higher level, we are also trying to make things a bit more explicit and clear, to make it obvious to everybody how much is being paid and by whom.
LISTNUM 1 \l 13715 COMMISSIONER CRAM: My concern, in a lot of ways, is not necessarily with the economics of cellphones in the North when we are talking about being able to maintain a company that is the provider of last resort for basic service.
LISTNUM 1 \l 13716 When I weigh those issues, I then ask myself what is the most important thing we are doing here, and should we worry about cell competition to the detriment of res rates and affordability and other issues like that.
LISTNUM 1 \l 13717 MR. ROBERTS: Again, I would suggest that there is merit from an economic perspective and from a transparency perspective to make any subsidies explicit, instead of burying them, where possible, in indirect implicit subsidies.
LISTNUM 1 \l 13718 COMMISSIONER CRAM: We soon learn in this job that we can't be purists very much.
LISTNUM 1 \l 13719 Mr. Rondeau was asking you about wanting the ability to raise rates by $1 a year, and I can't remember, are you requesting the same thing for business rates?
LISTNUM 1 \l 13720 THE CHAIRPERSON: Could I remind my colleague that the rates in question were those for optional features, they were not basic service rates.
LISTNUM 1 \l 13721 COMMISSIONER CRAM: They were just optional.
LISTNUM 1 \l 13722 THE CHAIRPERSON: They were just optional features, they were not basic service rates.
LISTNUM 1 \l 13723 COMMISSIONER CRAM: All right.
LISTNUM 1 \l 13724 Under what circumstances would you raise the rates? What would be the circumstances when you would raise them?
LISTNUM 1 \l 13725 MR. ROBERTS: You are referring to optional service rates?
LISTNUM 1 \l 13726 COMMISSIONER CRAM: Yes.
LISTNUM 1 \l 13727 MR. ROBERTS: I guess that the long‑established principle for this class of service has been to maximize contribution to try and come up with a net benefit.
LISTNUM 1 \l 13728 We would assess the market and determine whether or not we could actually yield more contribution out of this set of services.
LISTNUM 1 \l 13729 Our challenge is that we've been very aggressive, as demonstrated by the detailed marketing information we put on the record and we've tied this aggressive marketing to the roll‑out of new services to new communities.
LISTNUM 1 \l 13730 We don't have any further roll‑out and we feel that we've hit the point of diminishing returns as far as the aggressive campaigns we've been running, but cost more to run.
LISTNUM 1 \l 13731 You have to appreciate that the customer base in the north is extremely small, and when you run calling campaigns from a call centre, it doesn't take very long at all until you hit everybody.
LISTNUM 1 \l 13732 So this, coupled with the outlook for NAS, puts I guess a damper on our future prospects there.
LISTNUM 1 \l 13733 COMMISSIONER CRAM: So, the question was, in what circumstances would you raise them? And is the answer, if price sensitivity would allow you to, the elasticity studies would allow you to?
LISTNUM 1 \l 13734 Is that what it comes down to, if you think the market can bear it?
LISTNUM 1 \l 13735 MR. ROBERTS: On a total bill basis, yes.
LISTNUM 1 \l 13736 COMMISSIONER CRAM: And then Mr. Rondeau was talking to you about the issue of deferral accounts and that kind of issue.
LISTNUM 1 \l 13737 And clearly the difference is with price cap there is no deferral, so if you make more money above the 10.5 you keep it and your shareholders get it.
LISTNUM 1 \l 13738 And I am going to suggest to you that that is a very substantial motivation.
LISTNUM 1 \l 13739 In price cap 2 we learned that the return on equity, when we gave going‑in rates of 10, 11 per cent were, in some cases it was alleged for example with Telus, 22 per cent.
LISTNUM 1 \l 13740 So, how much of a factor should I put into the fact that you will now have a motivation to exceed your targets and, you know, that you will be capitalist about productivity, pushing optionals, worried about losing your customers?
LISTNUM 1 \l 13741 And I think about, you know, you lose a customer you lose a customer, you lose the ability to up‑sell and, you know, potentially...
LISTNUM 1 \l 13742 So, what kind of a factor, how should I put that in when I know that Telus doubled theirs?
LISTNUM 1 \l 13743 MR. ROBERTS: Well, we need to put things into context.
LISTNUM 1 \l 13744 COMMISSIONER CRAM: You are not a capitalist?
LISTNUM 1 \l 13745 MR. ROBERTS: We are indeed capitalists, however, we are in a situation where we are currently getting 1.5 times the revenue per line. That will be reduced somewhat but still be far higher than in the south, as we'll demonstrate explicitly tomorrow.
LISTNUM 1 \l 13746 In addition, we need to keep in mind that there's a number of other changes that are happening with regard to our business risk, in particular, that the current mechanism ‑‑ not only through the revenue deferral account as explored by UCG, but also through our settlement rates, tends to keep us more or less whole in the event of alternative TDM toll.
LISTNUM 1 \l 13747 Given our proposed switch connect rates we will, in fact, feel any additional competitive loss on the bottom line in a way that we wouldn't have before, so in fact we are taking on a far greater degree of risk and there's the lack of upside.
LISTNUM 1 \l 13748 There's also the broader issue of timing. I would suggest that the introduction of new services like ADSL was timed in a way to benefit other telephone companies in a way that it's not going to benefit Northwestel.
LISTNUM 1 \l 13749 These revenues are already embedded in our base to the extent that we are going to be able to volt them out to new areas, and with regard to the remaining communities in our areas, we've actually been beaten to those markets through a disruptive competitive government‑funded network.
LISTNUM 1 \l 13750 So, again, it's very different circumstances that we're in and I would suggest that the opportunity for windfall profits is not what you would have inferred.
LISTNUM 1 \l 13751 COMMISSIONER CRAM: So, compared to the south, would I say that your opportunity to be a good capitalist is one tenth that of the south, 20 per cent, 30 per cent, 40 per cent?
LISTNUM 1 \l 13752 MR. ROBERTS: As we've suggested repeatedly, our concern is even to sustaining things going forward, given our high dependence on the implicit margins that remain after a rate restructuring.
LISTNUM 1 \l 13753 The total impact of the wholesale changes that we are suggesting hasn't been flown through in its entirety to our retail rates due to our need to meet 10.5 and the extent to which we are constrained by the finite amount of the cost‑based subsidy. So we are left again with exposure there.
LISTNUM 1 \l 13754 Now, we did choose, however, to be more aggressive on the wholesale rates because we are concerned about this potential for a significant, sudden and sustained impact of one or two carriers making a choice that could have, again, immediate impacts that are very material.
LISTNUM 1 \l 13755 COMMISSIONER CRAM: And building their own facilities?
LISTNUM 1 \l 13756 MR. ROBERTS: Building their own facilities or adopting IP bypass technologies. Again, the implicit subsidy is tied to legacy network services only.
LISTNUM 1 \l 13757 COMMISSIONER CRAM: Thank you. Thank you, Mr. Chair.
LISTNUM 1 \l 13758 THE CHAIRPERSON: Mr. Williams.
LISTNUM 1 \l 13759 COMMISSIONER WILLIAMS: Good afternoon, Mr. Hamelin and panel.
LISTNUM 1 \l 13760 I am just trying to get a better understanding on the level of competition in Northwestel's territory and particularly north of the 60th parallel, excluding northern B.C.
LISTNUM 1 \l 13761 You talked about, just a couple minutes ago, with Commissioner Cram about New North Networks being a major player in Inuvik. What would a major player in Inuvik enjoy in the way of say cellular customers and/or revenue in your best estimation?
LISTNUM 1 \l 13762 MR. ROBERTS: I have no particular knowledge of Inuvik's specific cellular market. Northwestel is not a cellular provider in that area.
LISTNUM 1 \l 13763 COMMISSIONER WILLIAMS: You are not a cellular provider in Inuvik?
LISTNUM 1 \l 13764 MR. ROBERTS: Northwestel is not.
LISTNUM 1 \l 13765 COMMISSIONER WILLIAMS: Okay, I wasn't aware of that.
LISTNUM 1 \l 13766 MR. ROBERTS: Bell Mobility and Northwestel Mobility is a related company, but I don't speak to ‑‑
LISTNUM 1 \l 13767 COMMISSIONER WILLIAMS: But you don't have access to that?
LISTNUM 1 \l 13768 MR. ROBERTS: Yes.
LISTNUM 1 \l 13769 COMMISSIONER WILLIAMS: What would Northwestel's revenue be out of a community the size of Inuvik?
LISTNUM 1 \l 13770 MR. HAMELIN: Any specific service you are thinking about?
LISTNUM 1 \l 13771 COMMISSIONER WILLIAMS: Just gross revenue. Inuvik as a revenue contributing centre would be approximately how much? You can even use a per cent, you don't need to use a number.
LISTNUM 1 \l 13772 MR. HAMELIN: Just a moment please.
LISTNUM 1 \l 13773 MR. ROBERTS: I would suggest it may be very difficult to give you any kind of meaningful number there. Things like private line services would have two different ends, but I don't know how to allocate that revenue on things like a toll call. Again, we would have two different ends, so it is very difficult for us to quantify that within a meaningful level and certainly without a huge degree of effort and thought.
LISTNUM 1 \l 13774 COMMISSIONER WILLIAMS: Would it represent less than 10 per cent of Northwestel's $160 million?
LISTNUM 1 \l 13775 MR. WOODLAND: If I were to have to hazard a guess, and I am not going to put this in terms of actual numbers, I would say that Inuvik's revenue is probably larger than its share of population, in particular because of the activity that is going on up there and the kinds of data facilities that have been ordered by many of the companies working in that area, that kind of thing. So whatever Inuvik's proportion of our population is, you could ballpark a certain amount of revenue as being ‑‑
LISTNUM 1 \l 13776 COMMISSIONER WILLIAMS: It is about 3 per cent or a little less than 3 per cent.
LISTNUM 1 \l 13777 MR. WOODLAND: Yes, so it is probably something slightly higher than that. I mean, Inuvik would be a better than average community for Northwestel.
LISTNUM 1 \l 13778 COMMISSIONER WILLIAMS: Is that the only community where a non‑affiliated to Northwestel is competing?
LISTNUM 1 \l 13779 MR. ROBERTS: Well again, there is northern B.C. and that represents a ‑‑
LISTNUM 1 \l 13780 COMMISSIONER WILLIAMS: Other than TELUS and others in northern B.C.?
LISTNUM 1 \l 13781 MR. ROBERTS: Well, there is other forms of competition too. Are you interested specifically in wireless or just competition in general?
LISTNUM 1 \l 13782 COMMISSIONER WILLIAMS: Yes, I am just trying ‑‑ like, you are talking a bit about the competitive threat and to me it seems pretty small, I guess that is what I ‑‑
LISTNUM 1 \l 13783 MR. ROBERTS: Okay, well let me elaborate in general terms then. We do have facilities competition, competitive microwave systems into Fort Nelson. There is, again, a government‑funded transport network through the National Satellite Initiative that reaches 25 to 26 communities in Nunavut and 31 of 33 communities in the Northwest Territories. So that is extremely significant of the majority of our communities.
LISTNUM 1 \l 13784 In addition, we have IP‑based competition. We have a number if ISPs that are engaged in competition against Northwestel and there are also the application service providers that are going after legacy services on the high-speed internet connections provided by others, including Northwestel. So there could be largely southern-based competitors that are riding on these high-speed internet lines.
LISTNUM 1 \l 13785 COMMISSIONER WILLIAMS: Okay, that is helpful. Thank you.
LISTNUM 1 \l 13786 That is my question, Mr. Chair.
LISTNUM 1 \l 13787 THE CHAIRPERSON: Just a brief word to you before we go through the undertakings.
LISTNUM 1 \l 13788 You have told us with respect to productivity that you don't have the data required to improve in any significant way the case that you are making to the Commission with respect to the role of productivity in the price cap regime.
LISTNUM 1 \l 13789 All I will say to you is that I would suggest to you respectfully that you go and consider overnight whether that is absolutely correct, whether there is nothing that Northwestel can do in the next three to four months to better substantiate its case with respect to productivity.
LISTNUM 1 \l 13790 I think that the Commission can fairly be said to be uneasy and uncomfortable with what you have provided us thus far and if you don't feel you can do better, well you can't do better, that is fair enough. I would just rather you drew that conclusion after considering it together and not simply have to make it in a situation where it is suddenly thrown across the table at you.
LISTNUM 1 \l 13791 I am not going to ask the question again, I am not going to raise it again, and if you don't raise it again, it won't be raised again, at least not by anyone on the panel, on this panel. But I would, I repeat, suggest to you respectfully that it would be worth your while sitting down together collectively and asking yourselves whether you can't offer the Commission something more convincing and more compelling than what you have been able to do so far.
LISTNUM 1 \l 13792 Who is going to go through the undertakings? Mr. McCallum, you are going to work your way through the undertakings or Madame Bisson?
LISTNUM 1 \l 13793 THE SECRETARY: I have them listed.
LISTNUM 1 \l 13794 The first one was yesterday, Undertaking No. 1 was PIAC to Northwestel (Marketing), Median Savings per residential subscribers under Northwestel proposal.
LISTNUM 1 \l 13795 Undertaking No. 2, CRTC to Northwestel (Finance), To provide sensitivity on rate restructuring.
LISTNUM 1 \l 13796 THE CHAIRPERSON: Wait, Madame Bisson. Each one, we are going to ask the panel when they expect to be able to respond to those.
LISTNUM 1 \l 13797 THE SECRETARY: Okay, sorry.
LISTNUM 1 \l 13798 THE CHAIRPERSON: We are going to come to a conclusion and we will go on to the next one. So could you just go through the first one again, please?
LISTNUM 1 \l 13799 THE SECRETARY: PIAC to Northwestel (Marketing), Median Savings per residential subscribers under Northwestel proposal.
LISTNUM 1 \l 13800 THE CHAIRPERSON: When might we expect something, Mr. Roberts?
LISTNUM 1 \l 13801 MR. ROBERTS: It is difficult. This is an undertaking of the Marketing Panel.
LISTNUM 1 \l 13802 THE CHAIRPERSON: Oh, I am sorry. Yes, you are absolutely right. Mr. Rogers?
LISTNUM 1 \l 13803 MR. ROGERS: I was just going to make the same observation as the Finance Panel. I think they can speak for finance issues.
LISTNUM 1 \l 13804 THE CHAIRPERSON: Well, tomorrow you will bring us an undertaking about the undertaking with respect to the ones that were undertaken by the Marketing Panel and we apologize for having failed to cover that when we excused the Marketing Panel.
LISTNUM 1 \l 13805 MR. ROGERS: Sure, we will come to common ground as to when those responses will be provided.
LISTNUM 1 \l 13806 THE CHAIRPERSON: Great, thank you.
LISTNUM 1 \l 13807 I would just like, while the panel is here, if you agree, that we will go through the Finance ones, Madame Bisson ‑‑
LISTNUM 1 \l 13808 THE SECRETARY: Yes.
LISTNUM 1 \l 13809 THE CHAIRPERSON: ‑‑ with this panel.
LISTNUM 1 \l 13810 THE SECRETARY: CRTC to Northwestel Finance: To provide sensitivity on rate restructuring.
LISTNUM 1 \l 13811 THE CHAIRPERSON: Yes, sensitivity analysis with respect to certain hypotheses offered by the staff on rate restructuring.
LISTNUM 1 \l 13812 MS CHALIFOUX: Again, that undertaking was from yesterday, the Marketing Panel.
LISTNUM 1 \l 13813 THE CHAIRPERSON: You are absolutely right, it was yesterday.
LISTNUM 1 \l 13814 THE SECRETARY: Okay. PIAC to Northwestel (Finance), Provide information on long term Government of Canada Bonds.
LISTNUM 1 \l 13815 MR. HAMELIN: Tomorrow.
LISTNUM 1 \l 13816 THE CHAIRPERSON: Tomorrow. Thank you.
LISTNUM 1 \l 13817 Next?
LISTNUM 1 \l 13818 THE SECRETARY: UCG, you responded with the undertakings with your Exhibit No. 3. It was UCG to Northwestel (Finance) Operating Expenses 2001-2005.
LISTNUM 1 \l 13819 Telus to Northwestel (Finance), Details on settlement and CAT revenues resulting from reduction in CAT and settlement rates.
LISTNUM 1 \l 13820 MS CHALIFOUX: We can provide that tomorrow morning.
LISTNUM 1 \l 13821 THE SECRETARY: CRTC to Northwestel (Finance), Re: response to interrogatory NWTel(CRTC) 20Mar06-603 Attachment 1, Power costs, details.
LISTNUM 1 \l 13822 MR. WOODLAND: Tomorrow.
LISTNUM 1 \l 13823 THE SECRETARY: CRTC to Northwestel (Finance), verification of model re: if there is weighting for material costs, i.e. copper versus fibre.
LISTNUM 1 \l 13824 MR. WOODLAND: Can I ask a prioritization I guess to Mr. McCallum?
LISTNUM 1 \l 13825 Would you prefer that I deal with the undertakings first or the interrogatories?
LISTNUM 1 \l 13826 MR. McCALLUM: I suspect the undertakings will take a little bit less time so perhaps in terms of prioritization do the ones that are faster first.
LISTNUM 1 \l 13827 MR. WOODLAND: All right.
LISTNUM 1 \l 13828 Then I will say tomorrow for this one as well.
LISTNUM 1 \l 13829 THE SECRETARY: CRTC to Northwestel (Finance), Provide electronic version of response to interrogatory Northwestel(CRTC) 02Jun06-2606.
LISTNUM 1 \l 13830 MR. WOODLAND: This is the all the files used one?
LISTNUM 1 \l 13831 I have to go to a number of other people so I'm going to say Friday for that one.
LISTNUM 1 \l 13832 THE SECRETARY: CRTC to Northwestel (Finance), Whether any of the switches have DMS - IXC functionality.
LISTNUM 1 \l 13833 MR. ROBERTS: Tomorrow.
LISTNUM 1 \l 13834 THE SECRETARY: CRTC to Northwestel (Finance), Equivalent number to the south for revenue per NAS based on proposed rates.
LISTNUM 1 \l 13835 THE CHAIRPERSON: I think that was the comparison where you remove the impact of the SIP on the revenue and the expense and compare it ‑‑ excuse me, toll.
LISTNUM 1 \l 13836 Was it toll? Toll, forgive me.
LISTNUM 1 \l 13837 Whose question was this?
LISTNUM 1 \l 13838 Peter, would you just make sure that what is going on here is accurate?
‑‑‑ Pause
LISTNUM 1 \l 13839 MR. ROBERTS: Is this is the 1.5 times revenue recalculation for ‑‑
LISTNUM 1 \l 13840 THE CHAIRPERSON: Yes, it is.
LISTNUM 1 \l 13841 MR. ROBERTS: Okay. We will do that again on ‑‑
LISTNUM 1 \l 13842 THE CHAIRPERSON: Do we have a common understanding of what it was, because I'm sorry, I can't clarify it.
LISTNUM 1 \l 13843 MR. ROBERTS: I think we do and, on a best-efforts basis again, tomorrow.
LISTNUM 1 \l 13844 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 13845 THE SECRETARY: CRTC to Northwestel (Finance), Equivalent number to the south for revenue per NAS based on just basic access and optional services.
LISTNUM 1 \l 13846 MR. ROBERTS: I take that as part of the same, yes. So again, tomorrow.
LISTNUM 1 \l 13847 THE SECRETARY: All right.
LISTNUM 1 \l 13848 The last one is CRTC to Northwestel (Finance), Details on DRD. Provide electronic spreadsheet with formula.
LISTNUM 1 \l 13849 THE CHAIRPERSON: It was your spreadsheet on the DRD calculations with ‑‑
LISTNUM 1 \l 13850 MR. ROBERTS: Before next Wednesday.
LISTNUM 1 \l 13851 THE SECRETARY: Next Wednesday, all right.
LISTNUM 1 \l 13852 That was the last one.
LISTNUM 1 \l 13853 THE CHAIRPERSON: Have we covered, Ms Lott, the explanation for why your calculation ‑‑ I'm not going to remember what it was exactly ‑‑
LISTNUM 1 \l 13854 We have not covered it or have we covered it?
LISTNUM 1 \l 13855 MS LOTT: No, we haven't yet.
LISTNUM 1 \l 13856 THE CHAIRPERSON: So can you ‑‑
LISTNUM 1 \l 13857 MS LOTT: That was going to be an undertaking from Finance.
LISTNUM 1 \l 13858 THE CHAIRPERSON: Yes. Could you re‑articulate it so that the panel knows what it is, because I'm sorry I don't have it at hand. I remember it, but I don't remember the references, and so forth.
LISTNUM 1 \l 13859 MS LOTT: We recall.
LISTNUM 1 \l 13860 THE CHAIRPERSON: You know what the undertaking was?
LISTNUM 1 \l 13861 MS LOTT: Yes.
LISTNUM 1 \l 13862 THE CHAIRPERSON: Yes. It was probably a non-quantitative explanation of what the flaws in the calculation in the exhibit submitted by the Consumers Groups.
LISTNUM 1 \l 13863 MS LOTT: Yes. We could do it for tomorrow morning, yes.
LISTNUM 1 \l 13864 THE CHAIRPERSON: Great. And it will be tomorrow?
LISTNUM 1 \l 13865 MS LOTT: Thank you.
LISTNUM 1 \l 13866 THE CHAIRPERSON: Thank you.
LISTNUM 1 \l 13867 MS LOTT: Thank you. Thank you for ‑‑
LISTNUM 1 \l 13868 THE CHAIRPERSON: Anything more?
LISTNUM 1 \l 13869 THE SECRETARY: That's it.
LISTNUM 1 \l 13870 THE CHAIRPERSON: Thank you very much.
LISTNUM 1 \l 13871 We will see one another tomorrow at 9 o'clock.
‑‑‑ Whereupon the hearing adjourned at 1709, to resume
on Wednesday, July 12, 2006 at 0900 / L'audience
est ajournée à 1709, pour reprendre le mercredi
12 juillet 2006 à 0900
REPORTERS
______________________ ______________________
Richard Johansson Lynda Johansson
______________________ ______________________
Jean Desaulniers Fiona Potvin
______________________ ______________________
Sue Villeneuve Beverley Dillabough
- Date modified: