ARCHIVED - Telecom Commission Letter - 8661-C12-200807779
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Ottawa, 10 October 2008
Re: Telecom Public Notice CRTC 2008-5, Review of regulatory requirements pertaining to the imputation test for retail services and to costing methodologies for wholesale services
In Telecom Public Notice CRTC 2008-5 (PN 2008-5), the Commission invited parties to comment, in light of the Policy Direction, on the continued appropriateness of the imputation test for retail services as well as wholesale service costing methodologies.
During the proceeding initiated by PN 2008-5, Bell Aliant Regional Communications, Limited Partnership, Bell Canada, and Saskatchewan Telecommunications (the Companies), and TELUS Communications Company ( TCC ) proposed modifications to two costing methodologies: the use of company-specific working fill factors (WFFs)  , and the recovery of past introduction costs not fully recovered .
In its reply comments, Rogers Communications Inc. commented that there could be potential differences and discrepancies among incumbent local exchange companies' (ILECs) WFFs and that unless these differences were addressed, the Commission should continue to apply mandated WFFs in wholesale service costing studies.
In its reply comments, MTS Allstream Inc. submitted that the above-noted costing methodology changes sought by the Companies and TCC required separate examination pursuant to the process identified for costing methodology changes in Section 4 of each ILEC's regulatory economic studies manual.
The Commission notes that the Companies and TCC have not provided sufficient information regarding their proposed modifications to the two costing methodologies noted above for the parties to assess and make submissions on the merits of their proposals or for the Commission to make a determination. Further, the Commission notes that these issues relate to costing methodology changes that can be dealt with separately from the other issues raised in the PN 2008-5 proceeding. In light of the above, the Commission considers it appropriate to exclude the above-noted costing methodologies from the PN 2008-5 proceeding and set out the following process to address them.
The Commission directs the Companies and TCC to submit a detailed submission on their proposed changes to the costing methodologies for the use of company-specific WFFs and the recovery of past introduction costs not fully recovered , with supporting rationale, serving a copy on parties in the Attachment to this letter, by 4 November 2008.
Parties may address interrogatories to the Companies and TCC. Any such interrogatories must be filed with the Commission and served on the relevant party or parties by 14 November 2008
Responses to interrogatories are to be filed with the Commission and served on all parties by 28 November 2008.
All parties may file comments with the Commission, serving a copy on all other parties, by 10 December 2008.
All parties may file reply comments with the Commission, serving a copy on all other parties, by 19 December 2008.
The Commission expects to issue a decision on these two costing issues within 120 days of the close of record.
Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.
Original signed by John Keogh
Robert A. Morin
 TCC also proposed to make adjustments to the mandated working fill factors as an alternative methodology.
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