ARCHIVED - Telecom Commission Letter - 8740-T66-200807472

Letter

Ottawa, 11 June 2008

File No. 8740-T66-200807472

By e-mail

Mr. Terry Connolly
Director -Regulatory Affairs
TELUS Communications Company
21-10020-100 Street NW
Edmonton, Alberta
T5J 0N5
regulatory.affairs@telus.com

Dear Mr. Connolly:

RE:   TELUS Tariff Notice 306

Please find attached interrogatories related to the company's tariff application filed under cover of Tariff Notice 306, in which the company proposed the introduction of CLEC Access to Operational Support Systems (OSS) Service and CLEC Manual Equipment Record Service, respectively Item 229 and Item 230 of TELUS' Carrier Access Tariff (CRTC 21462).  

Responses to these interrogatories are to be filed with the Commission by 11 July 2008. .

Yours sincerely,

Original signed by

Yvan Davidson
Senior Manager, Competitor Services and Costing
Telecommunications

cc:   Patrick Owens, CRTC (819) 953-7159

Attachment

Attachment 

Interrogatories for TCC TN 0306

1.   Appendix 1 of the report on the economic evaluation of the introduction of CLEC Access to Operational Support Systems (OSS) service describes the costs causal to the provision of access to the service.

At page 2 of Appendix 1 of the report on the economic evaluation of the introduction of CLEC Access to Operational Support Systems (OSS) service, the expenses causal to the service are described as "Opex costs related to the development of a billing system for this service". Further, also at page 2 of Appendix 1, under capital causal to the service, one of the costs is identified as software costs and is described as "Capex costs related to the development of a billing system for this service".

a) Identify and explain in detail the nature of the development costs identified in the report.  

b) At paragraph 60 of Telecom Decision 2005-14, Competitive local exchange carrier access to incumbent local exchange carrier operational support systems , 16 March 2005 , (Decision 2005-14) the Commission determined that "each party will be responsible for its own costs for the development and implementation of CLEC access to ILEC OSS." Identify and quantify any of the development costs identified in the economic evaluation that would not relate to the development and implementation costs described by the Commission at paragraph 60 of Decision 2005-14 with supporting rationale.

c) Provide revised PWAC and MEC for the CLEC Access to Operations Support Systems (OSS) service excluding those development and implementation costs that were referenced in paragraph 60 of Decision 2005-14.

2.   Appendix 2 of the report on the economic evaluation of the introduction of CLEC Access to Operational Support Systems (OSS) service provides the costs causal to queries.

At page 2 of Appendix 2, the expenses causal to the service are described as "OPEX costs associated with the creation of a gateway to manage the interface between the CLEC and the Company and development of software." Further, also at page 2 of Appendix 2, the costs included under capital causal to the service are described as "CAPEX costs associated with the creation of a gateway to manage the interface between the CLEC and the Company and the development of software."   

a) Identify and explain in detail the nature of the development costs identified in the report, and describe the activities associated with the creation of a gateway.  

b) Identify and quantify any of these development or gateway creation costs that would not relate to the development and implementation costs described by the Commission at paragraph 60 of Decision 2005-14, with supporting rationale.

c) Provide revised PWAC and MEC for the CLEC Access to Operations Support Systems (OSS) service excluding those development and implementation costs that were referenced in paragraph 60 of Decision 2005-14.

3.   At paragraph 18 of Telecom Decision 2007-61, Competitive local exchange carrier access to incumbent local exchange carrier operational support systems - Manual provisioning of equipment records, 31 July 2007 , the Commission determined that:

".subject to the timing issues discussed in the next paragraph, Bell Canada and TCC are required to continue to manually provide access to equipment records to CLECs that subscribe to their respective OSS access services, but only when they contain information that is not available through electronic access to OSS."

a) At paragraph 14 of Attachment 2 of the report on the economic evaluation of the introduction of CLEC Access to Operational Support Systems (OSS) service the company states that:

  "Where there is a failure in the CLEC Access to OSS Service that extends beyond a period of forty-eight (48) consecutive hours from the time that the Company is advised of the failure, CLECs may request manual equipment records from the Company. "

b) Explain how this condition is consistent with the Commission's determination at paragraph 18 of Decision 2007-61.