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Letter
Ottawa, 2 June 2006
File No: 8622-R11-200515505
By E-mail
reg.affairs@mts.ca
Ms. Teresa Griffin-Muir,
Vice President, Regulatory Affairs
MTS Allstream Inc.
Re: Part VII Application by Rogers Wireless Partnership: Clarification on the Applicability of Retail Digital Network Access (DNA) Link Charges on Competitor Digital Network (CDN) Facilities
MTS Allstream Inc. (MTS Allstream) is requested to provide comprehensive answers, including any supporting information, to the attached interrogatories with respect to the above referenced application by 23 June 2006 . Parties may comment on MTS Allstream 's response, serving a copy on other parties, by 7 July 2006 . MTS Allstream is to file its reply comments, serving a copy on other parties, by 14 July 2006 .
Yours Sincerely,
'Original signed by Y. Davidson'
Yvan Davidson
Senior Manager, Competitor Services and Costing
c.c.:
Ms. Dawn Hunt, Rogers Wireless dawn.hunt@rci.rogers.com
Mr. Jonathan Holmes, Primus regulatory@primustel.ca
Mr. Mirko Bibic, Bell Canada bell.regulatory@bell.ca
Mr. Bill Beckman, Saskatchewan Telecommunications document.control@sasktel.sk.ca
Mr. David Hennessey, Aliant Telecom Inc. regulatory.matters@aliant.ca
Mr. Willie Grieve, TELUS Communications Company willie.grieve@telus.com
Bob Martin, CRTC (819) 953-3361 robert.martin@crtc.gc.ca
Attachment
ATTACHMENT
1) Based on its review of the companies' responses to the Commission's 22 February 2006 and 19 April 2006 questions, Commission staff considers that all, or some, of the companies are either applying, or have applied in the past, link charges in situations where the companies connect their Competitor Digital Network (CDN) services to other Competitor Services they provide. Commission staff also considers that, in the event certain companies incur costs to provide this functionality that are not recovered through rates for the CDN services or other Competitor Services, such costs should be recovered through the rates of a link service that is a Competitor Service.
a) In light of the above, provide the company's view as to whether a link service is required that would be used to connect Competitor Digital Network (CDN) services to other Competitor Services. If the company is of the view that such a service is required, then comment on whether this new service should be a Category I Competitor Service. If not, explain why not.
b) Under the assumption that a new Competitor link service is required that would be used to connect Competitor Digital Network (CDN) services to other Competitor Services, and with reference to the cost studies provided or referred to in response to Commission interrogatories:
i) provide the company's proposed rate, cost study and proposed tariff pages for this new Competitor link service; further provide the supporting rationale for the company's proposed rate;
ii) having regard to the proposed capital costs that are causal to service demand, provide the following information: the costing methodology and assumptions used to determine the equipment capital costs by major resource component, outlining the development of the corresponding cash flows, identifying demand drivers, capital unit cost inputs, economic cost factors, life estimates, fill factor values and cost factors used. Further identify the vintage date of the raw data used to develop the unit cost inputs and explain the methods and assumptions used to express each of the capital unit costs in 2006 dollars as appropriate;
iii) having regard to the proposed expenses that are causal to service demand, provide detailed explanations on how each of the maintenance and service provisioning expense estimates were developed, including a listing of all activities, and the associated costing assumptions (e.g. time estimates, labour unit costs). If the maintenance expense estimates are inconsistent with the Commission's costing determination as specified in paragraph 448 of Decision 2005-6, explain why the company is proposing to deviate from this determination; and
iv) if in response to part a) above, the company identifies the service as a Category I Competitor Service, provide the appropriate service cost study details submitted in response to the 22 February 2006 Commission interrogatories on the public record in accordance with the level of disclosure for Category I Competitor Service costs as set out in Attachment 3 of Commission staff letter dated 30 June 2005.
2) Commission staff also considers that in the event the companies incur costs to connect a CDN and a retail service or another Competitor Service and a retail service that are not recovered through rates of either the Competitor Service or the retail service, such costs should be recovered through the rates of an additional link service.
a) Provide the company's view as to whether any additional link services are required and if so, whether each additional link service should be a Competitor or a retail service, with rationale. If the company is of the view that any of these additional link services should be a Competitor Service, provide the company's view on the appropriate Competitor Service classification of each additional link service, with rationale.
b) For each additional link service identified in response to part a):
i) provide a cost study and a proposed rate and proposed tariff pages in support of this new link service; further provide the supporting rationale for the company's proposed rate;
ii) further to the company's response to 2 b) i), having regard to the proposed capital costs that are causal to service demand, provide the following information: the costing methodology and assumptions used to determine the equipment capital costs by major resource component, outlining the development of the corresponding cash flows, identifying demand drivers, capital unit cost inputs, economic cost factors, life estimates, fill factor values and cost factors used. Further identify the vintage date of the raw data used to develop the unit cost inputs and explain the methods and assumptions used to express each of the capital unit costs in 2006 dollars as appropriate;
iii) further to the company's response to 2 b) i), having regard to the proposed expenses that are causal to service demand, provide detailed explanations on how each of the maintenance and service provisioning expense estimates were developed, including a listing of all activities and associated costing assumptions (e.g. time estimates, labour unit costs). If the maintenance expenses estimate is inconsistent with the Commission's costing determination as specified in paragraph 448 of Decision 2005-6, explain why the company is proposing to deviate from this determination; and
iv) if in response to 2 a) above, the company identifies an additional link service as a Category I Competitor Service, provide the appropriate service cost study details on the public record in accordance with the level of disclosure for Category I Competitor Service costs as set out in Attachment 3 of Commission staff letter dated 30 June 2005.
Date Modified: 2006-06-02
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