ARCHIVED - Telecom Commission Letter - 8661-T66-200807240

Letter

Ottawa, 29 July 2008

File No.:   8661-T66-200807240

BY EMail

Mr. Ted Woodhead
Vice-President- Regulatory Affairs
Telecom Policy & Regulatory Affairs
TELUS Communication Company
215 Slater Street, 8 th Floor
Ottawa, Ontario   K1P 0A6
regulatory.affairs@telus.com  

Re:   Wireless Number Portability

On 21 May 2008, the Commission received an application by TELUS Communications Company (TCC) requesting that it be allowed to recover that portion of the costs incurred by the company to modify the wireline network to enable wireless number portability (WNP).   Additionally, TCC filed responses to Commission interrogatories on 11 July 2008.

TCC is requested to provide responses to additional interrogatories as set out in the Attachment by 30 August 2008.

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager,
Tariffs

cc:    Interested Parties to PN 2006-3
        B.Natraj (Nat Natraj) (CRTC) 819-953-5081

Attachment

1)     With reference to the response to interrogatory TELUS(CRTC)18Jun08-1, provide details of the following costs.

a)   With reference to Item 6.4.1, Expenses causal to service - Other:

i)    With respect to the Inter-Carrier bulk porting PWAC costs estimate, explain the steps involved in Inter-Carrier bulk porting process as it applies to wireless number portability (WNP).   Additionally, provide a breakdown of the PWAC cost estimate into its individual resource elements.   For each resource element, indicate how the costs were estimated by providing details of the labour unit costs and the associated labour hours, the unit costs and the applicable demand drivers, etc.

ii)    With respect to the CLOGv6 (Canadian Local Ordering Guidelines, Version 6) project development PWAC cost estimate, explain, with supporting rationale, why project development costs associated with implementing CLOGv6 applies specifically to WNP.   Additionally, provide a breakdown of the PWAC cost estimate into its individual resource elements.   For each resource element, indicate how the costs were estimated by providing details of the labour unit costs and the associated labour hours, the unit costs and the applicable demand drivers, etc.   If the costs associated with implementing CLOGv6 apply to services other than WNP provide the percentage assigned to WNP, explain, with supporting rationale.

b)   With reference to Item 6.4.2, Capital causal to service-Software, explain, with supporting rationale, which updates are required to TCC's Local Service Request system and related systems interfaces to accommodate changes outlined in CLOGv6 pertaining specifically to WNP.   If this software applies to services other than WNP, provide the percentage assigned to WNP indicating the methodology used along with supporting calculations.

c)   With reference to Item 6.4.3, Capital causal to demand -Switching (Signal Transfer point), explain the functionality provided for each of Tekelec and Geoprobe costs, and explain why these are considered causal to WNP.   Additionally, for each of Tekelec and Geoprobe, indicate how these costs were estimated, providing a break-down of the PWAC's into their individual resource elements.   For each resource element, indicate how the costs were estimated by providing details of the labour unit costs and the associated labour hours, the unit costs and the applicable demand drivers, etc.

2)      Refer to paragraph 13 of TELUS' revised Part VII application dated 11 July 2008 regarding increasing the rate ceiling for forborne residential services by $0.07/month.

Explain,  with supporting rationale,  how this proposal is consistent with paragraph 454 of Telecom Decision CRTC 2006-15, in which the Commission found it appropriate to maintain its powers and duties under subsection 27(1) of the Telecommunications Act to the extent necessary to impose a price ceiling on stand-alone residential PES.   The Commission considered that such a ceiling would provide vulnerable and uncontested customers with a safeguard against unreasonable rate increases in a forborne environment without a pricing safeguard.