ARCHIVED - Letter
This page has been archived on the Web
Information identified as archived on the Web is for reference, research or recordkeeping purposes. Archived Decisions, Notices and Orders (DNOs) remain in effect except to the extent they are amended or reversed by the Commission, a court, or the government. The text of archived information has not been altered or updated after the date of archiving. Changes to DNOs are published as “dashes” to the original DNO number. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, you can request alternate formats by contacting us.
Ottawa, 21 August 2009
File No: 8740-N51-200715344
BY E-MAIL
Mr. Michel Gilbert
Corporate Director - Regulatory
NorthernTel Limited Partnership
25 Paget Street, Box 4000
New Liskeard, Ontario P0J 1P0
Dear Mr. Gilbert:
Re: Tariff Notice 244 – Local Network Interconnection and Component Unbundling
NorthernTel is requested to file its responses to the annexed questions by 28 August 2009.
Sincerely yours,
Original signed by
Suzanne Bédard
Senior Manager, Tariffs
Telecommunications
Annex (1)
cc: Martin Brazeau, CRTC, martin.brazeau@crtc.gc.ca
Dem Magmanlac, CRTC, dem.magmanlac@crtc.gc.ca
Annex
Tariff Notice 244 – Interrogatories
In the above-referenced tariff notice, NorthernTel has proposed, among other matters, rates for Type A unbundled local loops (ULL) that have been previously approved for Télébec:
1. In bands E and F, the company collects subsidies for providing residential Primary Exchange Service (PES). Commission staff notes that NorthernTel's proposed ULL rates for bands E and F reflect Télébec's costs, which are higher than the loop costs used the calculation of the company's subsidies for residential PES in Bands E and F:
a. Comment on the appropriateness of using the company's proposed ULL rates for bands E and F, in light of the above-referenced concern. The company's response should address the issue as to why approval of its proposed ULL rates for bands E and F would not be in violation of subsection 27(2) of the Telecommunications Act; and
b. Comment on the appropriateness of adopting the following rates for the company's ULL service, which rates are based on the weighted average loop rates of the large Incumbent Local Exchange Carriers (ILECS): $42.82 for bands E and of $30.76 for band F.
2.a. Comment on the appropriateness of using the company's proposed ULL rate for band C, considering the differences in the cost structures of Northern Tel and Télébec, i.e., average loop length, density, and other cost factors;
b. If NorthernTel wishes to adopt the ULL rate of another company for band C, provide the company's justification, considering the differences in the cost structures of Northern Tel and of that company, i.e., average loop length, density, and other cost factors; and
c. Comment on the appropriateness of adopting a ULL rate of $17.18 for band C which is based on the weighted average loop rates of the large ILECs. Commission staff notes that doing so would provide a more simplified and consistent approach for the derivation of the ULL costs and rates for all the bands in the company's territory.
a. Tariff Notice 244 – Interrogatory
|
Type A loops |
||||
|
Rates adjusted for Decisions 2001-238-1 and 2, 2001-848, 2002-12 and 2003-70 |
||||
|
|
|
|
|
|
|
|
(Loop cost + 15%) |
Band C |
Band E |
Band F |
|
Bell Canada |
$14.44 |
$25.82 |
$26.39 |
|
|
IslandTel (P.E.I.) |
$11.91 |
$27.62 |
$29.13 |
|
|
MTT (Nova Scotia) |
$13.75 |
$24.56 |
$23.22 |
|
|
MTS (MTS Allstream) |
$16.13 |
$40.86 |
$24.68 |
|
|
NBTEL (New Brunswick) |
$13.51 |
$23.06 |
$15.12 |
|
|
NEWTEL (Newfoundland & Labrador) |
$16.14 |
$24.48 |
$25.30 |
|
|
TCI (Alberta) |
$16.07 |
$27.05 |
$22.37 |
|
|
TCBC (British Columbia) |
$19.33 |
$46.03 |
$35.77 |
|
|
SaskTel |
$22.21 |
$43.89 |
$36.99 |
|
|
Weighted Average Loop Rates |
|
|
|
|
|
|
|
Band C |
Band E |
Band F |
|
a) |
large ILECs loop rate |
$14.70 |
$36.65 |
$26.33 |
|
b) |
large ILECs loop cost (loop rate less 15% mark-up) [a / 1.15] |
$12.78 |
$31.87 |
$22.89 |
|
|
||||
|
c) |
Subsidy related margin (large ILECs loop cost + 7.5%) |
$0.96 |
$2.39 |
$1.72 |
|
|
||||
|
d) |
Sub-total [b + c] |
$13.74 |
$34.26 |
$24.61 |
|
|
||||
|
e) |
Mark-up (large ILECs loop cost + 25%) [d * 0.25] |
$3.44 |
$8.56 |
$6.15 |
|
small ILECs loop rate [d + e] |
$17.18 |
$42.82 |
$30.76 |
|
|
note 1. |
NAS count taken from PN 2000-27 proceeding that led to Decision 2001-238 |
|||
|
note 2. |
Band D and Band F NAS count taken from the proceeding to Decision 2001-238 |
|||
- Date modified: