ARCHIVED - Letter
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Ottawa, 10 September 2009
File No.: 8740-B2-200908569
Mr. Denis E. Henry
Regulatory and Government Affairs
Bell Aliant Regional Communications, Limited Partnership
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
Mr. David Palmer
Director - Regulatory Affairs
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
Re: Bell Aliant Tariff Notice 269 and Bell Canada Tariff Notice 7205 – Proposed unbundled local loop rate increases
This letter sets out supplemental interrogatories to address the Bell Aliant Regional Communications, Limited Partnership’s and Bell Canada’s (collectively, the Bell companies) request that the Commission make the current unbundled loop rates interim immediately with the final rates to be applied retroactively to that date in light of the significant difference between the Bell companies’ proposed unbundled loop costs and those upon which the existing unbundled loop rates are based. Bell companies’ responses to the attached interrogatories are to be filed with the Commission and served on the parties listed on the distribution list by 17 September 2009.
In light of the above, the deadlines set out in the letter dated 12 August 2009, are extended as follows:
Parties may file comments on the Bell companies’ responses as they related to making the current unbundled loop rates interim by 23 September 2009. Reply comments from the Bell companies are to be filed by 30 September 2009.
Responses to interrogatories, comments and reply comments are to be filed with the Commission and served on all parties.
Documents to be filed and served in accordance with the above process are to be received, not merely sent, by the dates indicated. Copies of the documents should also be sent to firstname.lastname@example.org
Original signed by Mario Bertrand
Competition, Costing & Tariffs
cc: Yvan Davidson, email@example.com ; Thomas Hui, firstname.lastname@example.org
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1. For each company, for each band, provide the number of inward and outward unbundled loops for each of the following:
a) Actuals for each of the years 2006 to 2008.
b) Forecast for each of the years 2009 to 2013.
2. In response to The Companies(CRTC)12Aug09-2 d) and e) i), the Bell companies stated that they will continue to place distribution cable in growth areas and will continue to incur incremental cost:
a) With respect to the actual inward unbundled loops provided in response to 1 a) above, provide the Bell companies’ best estimate of the percentage of inward unbundled loops that are associated with growth areas. Further comment on the extent to which unbundled loops that have been provisioned in growth areas were provisioned using voice remotes where there is no copper feeder cable.
b) With respect to the forecast inward unbundled loops provided in response to 1 b) above, provide the Bell companies’ best estimate on the percentage of inward unbundled loops that are associated with growth areas. Further comment on the extent to which unbundled loops that will be provisioned in growth areas would be provisioned using voice remotes where there is no copper feeder cable.
c) Confirm that the Bell companies would be unable to provision unbundled loops to CLECs in those areas where there is no copper feeder cable.
3. In response to The Companies(CRTC)12Aug09-2 d) and e) ii), the Bell companies indicated that there are high growth routes where provision relief is likely to be required:
a) Provide the Bell companies’ definition of high growth routes and the criteria used by the Bell companies to identify these high growth routes.
b) For routes that are not considered to be high growth routes, explain with rationale whether provision relief would be expected.
c) For each company, provide the estimated copper cable capital expenditure associated with the in-service base assumed at the start of the study period.
d) Explain whether the Bell companies have assumed the same installed first cost per unbundled loop for both high growth routes and routes that are not considered to be high growth routes. If so, explain why, in light of the response to part b) above.
4. In response to The Companies(CRTC)12Aug09-2 d) and e) i), the Bell companies indicated that “[w]hile for distribution plant there is no planned relief, and so no cost of advancement, the capacity cost method approximates the explicit unit cost for distribution plant”.
Provide supporting rationale why, in the Bell companies’ view, it would be appropriate to use explicit unit cost (using cost new for estimating cost of existing distribution cables) to estimate the prospective incremental costs associate.
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