ARCHIVED - Telecom Commission Letter - 8663-K1-200809494

Letter

Ottawa, 27 October 2008

File No.: 8663-K1-200809494

By E-mail

Mr. Stace Gander
Manager, Carrier Access Services
Kenora Municipal Telephone System
110 Matheson Street South
Kenora, Ontario
P9N 1T8
sgander@kmts.biz      

Dear Mr. Gander

RE:   KMTS' implementation plan for local competition with Shaw

In a letter dated 1 May 2008, Commission staff agreed with Kenora Municipal Telephone System's ( KMTS) request for an extension to 10 July 2008 to file its implementation plan for facilities-based local competition in its serving territory for Shaw Telecom inc. (Shaw) (the implementation plan).   In its letter, Commission staff requested KMTS to include in its implementation plan, among other things, the causal costs to implement local competition including LNP if appropriate and how those costs will be recovered.

On 10 July 2008, the Commission received KMTS' implementation plan.   The Commission received comments and reply-comments from Shaw and KMTS, respectively.

In paragraph 24 of the implementation plan, KMTS indicated that it will provide the Commission, in the third quarter of 2008, with a final proposal or a complete budgetary assessment with respect to the cost recovery method associated with the implementation of local competition and Local Number Portability (LNP) (the cost recovery proposal).   To date, the Commission has not received KMTS' cost recovery proposal.

Commission staff considers that KMTS has had sufficient time to develop a cost recovery proposal including the related costs.   Commission staff also considers that based on KMTS' commitment, the Commission should already have received KMTS' cost recovery proposal.   Therefore, KMTS is directed to file its cost recovery proposal by 10 November 2008.

• The cost recovery proposal is to include, among other things , at least one proposal to recover the causal costs by way of permanent rate increases to residential and business customers, respectively, through exogenous adjustments to KMTS' rates;
  
  
• Any proposal to recover the causal costs by way of rate increases is to identify the rate increase that would be applicable to specific residential and business services in the First, Second, and Fourth Price Cap baskets, those services that would benefit customers from the introduction of local competition;
  
  
• Recurring and non-recurring causal costs and their associated proposed rate increases are to be identified separately;
  
  
• The different cost recovery scenarios should be based on an allocation of costs amongst services on the basis of retail switched exchange service Network Access Service (NAS) with non-residential NAS weighted by a factor of 1.5;
  
  
• Detailed explanation, calculations and assumptions on how the numbers were derived are required.

KMTS is also requested to provide its responses to the attached questions by 10 November 2008.   With respect to both KMTS' cost recovery proposal and KMTS' responses to the attached questions, interested parties will have until 20 November 2008 to provide comments and KMTS will have until 27 November 2008 to provide reply-comments.

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager, Tariffs
Telecommunications

cc:   Jean Brazeau, Shaw Telecom Inc., regulatory@srjb.ca   
       Martin Brazeau, CRTC, (819) 997-3498, martin.brazeau@crtc.gc.ca

Attachment

Interrogatories related to the implementation plan

1.    In paragraph 40, KMTS indicated that it does have a wireless mobility business, does not offer Wireless Number Portability (WNP) and is eager to see the result of the consultation process initiated by the Commission in Regulatory framework for the implementation of wireless number portability within the serving territories of the small incumbent local exchange carriers , Telecom Public Notice CRTC 2008-11, 19 June 2008.

Confirm whether KMTS is including any WNP related implementation costs in its cost recovery proposal.   If yes, identify separately the costs and the cost recovery proposal related to WNP.

2.    In paragraph 51, KMTS submitted that it has not transferred responsibility for maintenance and repair of existing inside wire and new installations, additions, moves and rearrangements of same to subscribers.   KMTS also submitted that it will transfer ownership of the said wiring prior to 31 October 2009 .

a)   Provide a list of the tariff items that will have to be modified and/or introduced and the specific date by which KMTS expects to file these tariff revisions and/or introduction for approval with the Commission; and

b)   Describe how and when KMTS expects to inform the affected subscribers, in advance, of the said transfer of responsibility.

3.    In paragraph 52, KMTS submitted that is was not prepared to adopt the CRTC Interconnection Steering Committee (CISC) documents related to buildings and wiring until such time it is able to satisfy itself that all of the recommendations can be implemented.

Identify and provide, with rationale, the recommendations that KMTS believes cannot be implemented.

4.    In paragraph 56, KMTS submitted that it is "generally" in agreement with Commission Decisions concerning transiting (local and toll) for sectors served by its DMS-100 switch in Kenora.

Identify the Commission's determinations concerning transiting that KMTS is not in agreement with and provide reasons for the company's views.

5.    In paragraph 60, KMTS submitted that it is "generally" in agreement with the industry concerning the methods in the various Decisions and/or consensus reports pertaining to traffic sharing with Competitive Local Exchange Carriers and Wireless Service Providers.

Identify what aspects of the Decisions and consensus reports KMTS is not in agreement with and provide reasons for the company's views.