ARCHIVED - Letter

Ottawa, 23 December 2009

Our Reference: 8740-B2-200908569
                     8740-B54-200908543

BY E-MAIL

Mr. Denis E. Henry
Vice-President
Regulatory and Government Affairs
Bell Aliant Regional Communications, Limited Partnership
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca

Mr. David Palmer
Director - Regulatory Affairs
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Re: Bell Aliant Tariff Notice 269 and Bell Canada Tariff Notice 7205 – Proposed unbundled local loop rate increases

Dear Sirs:

Pursuant to Bell Aliant Regional Communications, Limited Partnership and Bell Canada – Revised rates for unbundled loop wholesale service, Telecom Order CRTC 2009-775, 14 December 2009, the following letter sets out the process to complete the review of Tariff Notices 269 and 7205 filed by Bell Aliant Regional Communications, Limited Partnership (Bell Aliant) and Bell Canada (collectively, the Bell companies), dated 2 June 2009.

The record developed to date is made part of the record of this tariff application review.

Responses to the attached interrogatories are to be filed with the Commission and served on all interested parties by 3 February 2010.

Requests by interested parties for public disclosure of information for which confidentiality has been claimed, setting out in each case the reasons for disclosure, must be filed with the Commission and served on the Bell companies by 10 February 2010.

Written responses to requests for public disclosure must be filed with the Commission and served on the interested party or parties making the request by 17 February 2010.
Determinations will be issued regarding requests for public disclosure as soon as possible. Any information to be provided pursuant to such determinations must be filed with the Commission and served on all interested parties by 3 March 2010.

The Commission and the parties may address interrogatories to the Bell companies regarding their submissions, cost studies and interrogatory responses. Any such interrogatories must be filed with the Commission and served on the Bell companies by 12 March 2010.

Responses to interrogatories are to be filed with the Commission and served on all parties by 6 April 2010.

Requests by parties for further responses to their interrogatories, specifying in each case why a further response is both relevant and necessary, and requests for public disclosure of information for which confidentiality has been claimed, setting out in each case the reasons for disclosure, must be filed with the Commission and served on the Bell companies by 13 April 2010.

Written responses to requests for further responses to interrogatories and for public disclosure must be filed with the Commission and served on the party or parties making the request by 19 April 2010. The Commission may address further interrogatories to the Bell companies by the same date.

Determinations will be issued regarding requests for further information and public disclosure as soon as possible. Any information to be provided pursuant to such determinations must be filed with the Commission and served on all interested parties by 4 May 2010. Responses to the Commission's further interrogatories are to be filed with the Commission and served on all interested parties by the same date.

All parties may file written comments with the Commission on any matter within the scope of this tariff application review, serving copies on all other parties, by 20 May 2010.

The Bell companies may file reply comments with the Commission, serving copies on all other parties, by 28 May 2010.

The Commission expects to finalize the unbundled loop rates 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. Copies of the documents should also be sent to thomas.hui@crtc.gc.ca

Parties may file their submissions electronically or on paper. Submissions longer than five pages should include a summary.

Electronic submissions should be in HTML format. As an alternative, those making submissions may use Microsoft Word for text and Microsoft Excel for spreadsheets.

Each paragraph of all submissions should be numbered. In addition, the line ***End of document*** should be entered following the last paragraph. This will help the Commission verify that the document has not been damaged during electronic transmission.

Yours sincerely,

Original signed by

Paul Godin
Director General
Competition, Costing and Tariffs
Telecommunications

cc: Yvan Davidson, yvan.davidson@crtc.gc.ca
Thomas Hui, thomas.hui@crtc.gc.ca

Attach (2)

Distribution List

bell.regulatory@bell.ca ; regulatoryaffairs@nwtel.ca; regulatory.affairs@telus.com; reglementa@telebec.com; document.control@sasktel.sk.ca; iworkstation@mtsallstream.com; regulatory@bell.aliant.ca; pdowns@nexicom.net; telstep@telstep.net; a.schneider@hay.net; alain.duhaime@sogetel.com; nantel@tellambton.net; j-fmathieu@telupton.qc.ca; gcordeau@maskatel.qc.ca; jpatry@telcourcelles.qc.ca; nfrontenac@kw.igs.net; sachuter@tcc.on.ca; tracy.cant@ontera.ca; rroy@telwarwick.qc.ca; pwightman@wightman.ca; telvic@telvic.net; dreynard@kmts.biz; scoffey@dryden.ca; paul.frappier@telmilot.com; m.baron@brktel.on.ca; regulatory@brucetelecom.com; lisa.marogna@citywest.ca; dave.baxter@quadro.net; rob.olenick@tbaytel.com ; roxboro@ontarioeast.net; steve@wtccommunications.ca; rbanks@mornington.ca; wagrier@1000island.net; grubb@hurontel.on.ca; gosfield@gosfieldtel.com; deborah.shaffner@corp.eastlink.ca; regulatory@execulink.com; pllard@cooptel.qc.ca; jonathan.holmes@ota.on.ca; michel.messier@cogeco.com ; andrew@isptelecom.net; JohnP@mountaincable.on.ca; regaffairs@quebecor.com; documents@accesscomm.ca; ataylor@personainc.ca; Regulatory.Matters@corp.eastlink.ca; jboutros@globility.ca ; regulatory@distributel.ca; regulatory@telnetcommunications.com; sbishay@iristel.com; cedric.tardif@derytelecom.ca; ingenierie@axion.ca; tim@cabletv.ca; regulatory@vianet.ca; bazilewichr@westmancom.com; dmckeown@viewcom.ca; Regulatory@sjrb.ca; regulatory.aff@fidomobile.ca; rmccaffrey@seaside.ns.ca; reglementation@xittel.net ; lisagoetz@globalive.com; regulatory@primustel.ca; rwi_gr@rci.rogers.com; ctacit@tacitlaw.com; Alexander.Adeyinka@rci.rogers.com

Attachment 1

Unbundled Loop Monthly Rates

1. In the response to The Companies(CRTC)10Sep09-4 TN 269 & 7205, the Bell companies stated that the distribution network is provisioned for ultimate demand and by design, there is no planned relief for distribution plant. For each company, explain whether or not the copper feeder network is also provisioned for ultimate demand. If not, explain why not.

2. In the response to The Companies(CRTC)10Sep09-4 TN 269 & 7205, the Bell companies submitted that using cost new for existing distribution cable is a practical way of recognizing the value of the plant:

a) For each company, for each band, provide the copper distribution and feeder cable capital cash flows associated with the in-service demand assumed at the start of the 2009 cost study submitted by the Bell companies on 2 June 2009 filed in support of TNs 269 and 7205 (the 2009 cost submission).

b) With respect to the copper cable capital cash flows provided in the response to part a) above, for each company, for each band, provide the following breakdown:

i. Copper feeder aerial cable;

ii. Copper feeder buried cable;

iii. Copper feeder underground cable ;

iv. Copper distribution aerial cable;

v. Copper distribution buried cable;

vi. Copper distribution building cable; and

vii. Copper distribution underground cable.

c) For each company, provide the copper cable Net Book Value (NBV) at the end of 2008 for each of the copper cable asset accounts (i.e. copper aerial, buried, underground and building cable) excluding the drop wire-related asset accounts. The response should provide the methodology and assumptions used to derive each company’s NBV.

d) For each company, for each of the copper cable asset accounts excluding the drop wire-related asset accounts, provide the current average age and average remaining life, specifying the vintage of the data.

e) With respect to the copper cable NBVs by asset account provided in response to part c) above, for each company, for each band, provide the following breakdown:

i. Copper feeder aerial cable;

ii. Copper feeder buried cable;

iii. Copper feeder underground cable;

iv. Copper distribution aerial cable;

v. Copper distribution buried cable;

vi. Copper distribution building cable; and

vii. Copper distribution underground cable.

If the above breakdown of the feeder/distribution NBV by band is not readily available, for each of copper aerial, buried, underground, and building cable, provide a breakdown of copper cable plant NBVs into feeder and distribution and by band, by apportioning the copper cable NBVs provided in response to part c) above using the respective Integrated Mapping, Accounting and Provisioning (IMAP) copper cable pair-meter information or an alternative approach, specifying the methodology and assumptions used.

f) For each company, for each band, provide revised Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission assuming the following change in assumption: the copper cable capital cash flows associated with the in-service demand at the start of the 2009 cost study are replaced by the respective NBV estimates based on the response to part e) above. The response should provide the methodology and assumptions used.

g) Given that the Bell companies’ copper cable plant is provisioned for ultimate demand, and that as a result, there is no planned relief for these facilities and no cost of advancement, provide the Bell companies’ views on the use of the NBV approach to recognize the value of existing copper cable plant rather than the capacity costing approach.

h) Provide the Bell companies’ views on other valuation approaches (e.g. opportunity costing approach, unrecovered capital cost) that can be used to estimate the value of existing plant, and discuss whether any such alternative approach would be appropriate to assess the value of existing copper cable plant that is provisioned for ultimate demand.

3. In paragraphs 52 to 54 of Attachment A to the 2009 cost submission, the Bell companies indicated that the loop rates established in Decision 2001-238 were based on copper loop make-up characteristics obtained from a sample of loops in 1981 while the loop costs in the 2009 cost submission were based on the copper cable loop make-up extracted from Bell Canada’s IMAP database:

a) Provide a detailed description of the IMAP database including the purpose of the database, the information collected in the database, the database update process, the frequency of updates and the latest vintage of the database.

b) For each company, provide a detailed description of the IMAP data extraction process and of the loop make-up information extracted from the IMAP database for use in the 2009 cost submission.

c) For each company, confirm that the loop make-up information used in the 2009 cost submission was based on a census of the 2004 IMAP database. If not, provide a detailed description of the sample size and how the sample was taken and provide an assessment of the accuracy of the chosen sample, with supporting rationale.

d) If in response to part c) above, the Bell companies confirm that the 2009 cost submissions were based on a census of the 2004 IMAP database, for each company, provide an assessment of the accuracy of using the 2004 census to represent the loop make-up in bands A, B and C over the study period, given that in these bands significant demand migration has occurred since 2004.

4. In Tables 4, 5, and 6 of Attachment A to the 2009 cost submission, the Bell companies provided their copper cable make-ups on a combined Bell Canada and Bell Aliant – Central territory basis. Separately, for each of Bell Canada and Bell Aliant - Central:

a) Provide (i) the average cable sizes – loops, (ii) the average construction mix – 1981 sample, and (iii) the average construction mix – 2004 IMAP census, in the format of Tables 4, 5 and 6.

b) With respect to the Table 6 information provided in response to part a) above, provide the methodology and assumptions used to estimate the proportions of distribution cable versus feeder cable. The response should explain if and how this methodology takes into consideration the roll-out of Integrated Digital Loop Carrier (IDLC)/remote systems, with supporting rationale.

5. Refer to the loop lengths provided in Table 3 of Appendix 4 of Attachment 1 to the 2009 cost submission:

a) Provide the data source and vintage of loop lengths used in the cost submission leading to Decision 2001-238 (the 2000 cost submission) as well as those used in the 2009 cost submission.

b) On page 10 of Attachment 1 to the 2009 cost submission, the Bell companies submitted that loop lengths were estimated using the “Terminal Method”. Confirm that the methodology used in estimating the loop lengths in the 2009 cost submission is the same as the methodology used in the 2000 cost submission. If not, provide a detailed description of the changes in methodology used to estimate the loop lengths, and explain why a different methodology is used; further, the response should discuss the merits of the new proposed approach relative to the previous approach and the potential differences in the average loop length measures stemming from the new proposed approach.

c) For each company, for each of bands E, F and G, provide and justify the differences in the average loop lengths used between the 2000 cost submission and the 2009 cost submission.

d) For each company, for each band, in the format of Table 6 in Appendix 1 of Attachment 1 to the 2009 cost submission, provide the impacts on the cost per loop per month due to the differences in loop lengths used in the 2000 and 2009 cost submissions.

e) Explain why Bell Aliant has not filed revised costs and rates for band G in light of the significant change in the average loop length. Further provide revised cost estimates for Bell Aliant – Central band G based on the average loop length provided in Table 3.

6. In Table 7 of Attachment A to the 2009 cost submission, the Bell companies provided the per band percent change in copper cable unit costs between the years 1999 and 2009:

a) For each company, for each band, for each copper feeder and distribution construction type, for each copper cable size and gauge under each construction type, provide the1999 and 2009 per meter per pair copper cable unit costs. Further, for each of these 1999 and 2009 copper cable unit costs, provide the breakdown of the unit costs into (i) supplier price, (ii) installation labour, (iii) other material, (iv) Ontario Provincial Sales Tax, (v) other (specify). The response should further provide a description of the major cost components included in each of parts (ii), (iii), and (v) above.

b) For each company, for each band, identify all of the Expertech Network Installations Inc. price elements and provide the associated Expertech prices used in the development of the 1999 and 2009 copper cable unit costs.

c) For each company, for each band, for each copper feeder and distribution construction type, provide a detailed list of copper cable sizes and gauges that were considered growth cables in 1999 but that are no longer considered growth cables in 2009, explaining why certain cable gauges are no longer considered growth, with supporting rationale. The response should include a discussion on whether the decision to purchase or not to purchase certain copper gauges is related to the provisioning of broadband enabled loops.

d) Provide an explanation and a detailed numerical example on how the per band copper cable unit costs are applied to the IMAP copper cable information to estimate the per band copper cable capital cash flows in the 2009 cost submission, with supporting rationale.

7. In paragraph 62 of Attachment A to the 2009 cost submission, the Bell companies described the methodology used to develop the 2009 per band copper cable unit costs. For each company, provide a detailed description of the methodology used to develop the 2009 per band copper cable unit costs, with supporting rationale. The response should further include the following:

a) The per band costing inputs and values that are developed by the company’s subject matter experts, the vintages of these values, the rationale for such inputs and values, and a detailed explanation on how each of these costing inputs is used to develop the 2009 copper cable unit costs.

b) For each band, for each distribution construction type, the sample size, the sampling method, the source and vintage of the data, and an assessment of the statistical accuracy of the sample with respect to the samples of installation jobs chosen to develop the per band copper cable unit costs.

c) Of the major cost components identified in response to question 6 a) above, a list of components for which the associated costs do not vary with the length of the copper cable and a detailed description of the methodology used to unitize these costs on a per meter per pair basis, including the average length of cables used to unitize these cable costs.

d) A detailed numerical example to illustrate the 2009 methodology to develop Bell Canada’s 200 pair 24 gauge copper distribution aerial cable unit cost in band B, and Bell Aliant’s 200 pair 24 gauge copper distribution aerial cable unit cost in band F.

e) Supporting rationale for the differences in copper cable unit costs across bands, including a detailed list of costing inputs and values that differ across bands.

8. Provide the source and vintage of the data used to develop the information provided in Tables 8-9, and Tables 10 to 15 in Attachment A to the 2009 cost submission.

9. In paragraph 31 of Attachment 1 to the 2009 cost submission, the Bell companies indicated that the drop wire costs were calculated by taking into account the fact that not all loops require a drop wire. For each company:

a) Provide a detailed description of the methodology used to estimate the drop wire costs per unbundled loop used in the 2009 cost submission, with supporting rationale. The response should include detailed costing assumptions, costing input values, vintages of the costing input values and should outline the changes in methodologies compared to the 2000 cost submission.

b) Provide the drop wire costs per loop per month used in the 2000 and 2009 cost submissions.

10. For each company, for each band, provide a breakdown of the per loop per month Capital Causal to Demand - Outside Plant Equipment included in Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission into the following:

a) Copper feeder aerial cable capital cost

b) Copper feeder buried cable capital cost

c) Copper feeder underground cable capital cost

d) Copper distribution aerial cable capital cost

e) Copper distribution buried cable capital cost

f) Copper distribution building cable capital cost

g) Copper distribution underground cable capital cost

h) Drop wire capital cost

11. In paragraph 31 of Attachment 1 to the 2009 cost submission, the Bell companies assumed that for a certain percentage of cases, the line card used in the AnyMedia Access System (AMAS) remotes is a combination card capable of providing voice and Asymmetric Digital Subscriber Line (ADSL) service and for a certain percentage of cases, the line card used in the AMAS remotes is a voice only card:

a) Provide the installed first cost for each of the voice only card and the combination card.

b) Confirm that the costs of the combination cards are included in the costs of unbundled loops. If yes, explain why the costs of unbundled loops include costs of cards capable of providing both voice and ADSL services instead of including costs of cards capable of providing voice service only.

c) For each company, for each band, provide revised Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission assuming that all line cards used in the AMAS remotes are voice only cards.

12. In the response to The Companies(CRTC)10Sep09-2 TN 269 & 7250, the Bell companies used data from Canadian Mortgage and Housing Corporation (CMHC) as an indicator for growth in unbundled loops:

a) For each company, for each band, and for each of years 2005 to 2010, provide (i) the number of new dwelling unit completions and (ii) the new dwelling unit completions as a percentage of total existing dwelling units.

b) Comment on the appropriateness of using these percentages to estimate the percentage of the inward unbundled loops that are associated with growth areas.

c) Further provide the Bell companies’ best estimate of the proportion of unbundled loops in growth areas that will be provisioned on voice remotes where there is no parallel copper feeder cable.

13. In paragraph 197 of Telecom Decision CRTC 2003-45 (Decision 2003-45), the Commission concluded that it is appropriate to require all Local Exchange Carriers (LECs) that have responsibility and control of copper in-building wire in an Multi-dwelling Unit (MDU) to permit other LECs to connect to and use the in-building wire at no charge and that the LECs that make use of such facilities are responsible for their maintenance. In the proceeding leading to Decision 2003-45, Bell Canada et al. indicated that it had largely recovered their initial investment in in-building wire and that the costs of repair and maintenance of copper in-building wire were minimal.

Confirm that the copper building cable is part of the copper in-building wire. If so, further confirm that the percentage estimates in Table 6 of Attachment A to the 2009 cost submission under Distribution - % Bldg are associated with the copper building cable, and provide supporting rationale for the inclusion of copper building cable costs in the costing of unbundled loops in view of Decision 2003-45.

14. In paragraph 24 of Attachment 1 to the 2009 cost submission, Bell Aliant indicated that Bell Canada’s loop expenses were used as a proxy for its Central Region loop expenses. Explain, with supporting rationale, why Bell Aliant - Central’s per loop per month expenses in Table 6 of Appendix 2 of Attachment 1 to the 2009 cost submission are different from Bell Canada’s per loop per month expenses in Tables 6 of Appendix 1 of Attachment 1 to the 2009 cost submission for comparable bands.

15. For each company, identify the labour unit costs (LUCs) and operating expense (OE) unit costs used in the 2009 cost submission and provide the associated vintages. Confirm that no more than 2 years of expense increase factors (EIFs) and productivity improvement factors (PIFs) have been applied to restate the LUCs and OE unit costs to 2009. If not, provide supporting rationale for applying more than 2 years of EIFs and PIFs.

16. For each company:

a) For each of the capital-related maintenance expenses and the service assurance expenses, provide a detailed description of the methodology used to estimate these expenses, with supporting rationale.

b) For each of the capital-related maintenance expenses and the service assurance expenses, provide a list and description of costing inputs used to estimate these expenses, including the OE input values and their vintages.

c) For each band, provide the breakdown of the maintenance expense per loop per month into:

i. Capital-related maintenance;

ii. Service assurance; and

iii. Other (specify).

d) Provide the 2008 total actual maintenance expenses associated with

i. Unbundled loops;

ii. primary exchange service (PES); and

iii. high speed internet service (ADSL).

17. For each company:

a) Relative to the total unbundled loops provided to the company’s retail end-users, provide the most recent actual percentage (specifying the vintage) of unbundled loops provided to the company’s retail end-users that:

i. Subscribe to the company’s PES, but not to the company’s ADSL service;

ii. Subscribe to both the company’s PES and ADSL services;

iii. Subscribe to the company’s ADSL service, but not to the company’s PES.

b) For each company, provide a detailed description, with supporting rationale, of the methodology used to estimate the unbundled loop service assurance expenses such that it excludes those expenses associated with the company’s retail PES and ADSL services. The response should identify, with supporting assumptions, how the company assigns the service assurance activities and expenses between (i) unbundled loop service, (ii) retail PES, and (iii) retail ADSL service.

18. For each company, for each band:

a) For each of (i) loops that are provisioned to the company’s retail end-users (company unbundled loops) and (ii) loops that are provisioned to the competitors’ end-users (competitor unbundled loops), provide the cost per loop per month in the format of Table 6 in Appendix 1 of Attachment 1 to the 2009 cost submission.

b) Identify the differences in costing assumptions, inputs and values between those used in the costing of company unbundled loops and those used in the costing of competitor unbundled loops, with supporting rationale for any differences.

19. In the proceeding leading to Decision 2001-238, the Bell companies identified the use of a “hairpin solution” to provide unbundled loops within a wire centre serving area for end-users served by an IDLC/remote system:

a) Provide a configuration diagram for the hairpin solution.

b) Explain where the use of the hairpin solution is possible within a wire centre serving area for end-users served by an IDLC/remote system, and explain why the Bell companies are not including the use of the hairpin solution to provide unbundled loops to competitor’s end-users in their 2009 cost submission.

c) For each company, for each band, provide revised Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission assuming the use of the hairpin solution to provision unbundled loops to competitors within a wire centre serving area for end-users served by an IDLC/remote system.

d) For each company, for each band, provide revised Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission assuming that Central Office Terminals are deployed to provision unbundled loops to competitors within a wire center serving area for end-users served by AMAS remotes.

e) Identify and provide a detailed description of other ways to provide unbundled loops to competitors within a wire centre serving area for end-users served by an IDLC/remote system.

 

Service Charges

 

20. Refer to Tables 3 a – 3 h of Appendix 3 of Attachment 1 to the 2009 cost submission:

a) For each company, for each of business and residence, provide the breakdown of the per order service provisioning cost by completing Table 1 of Attachment 2 and the breakdown of the per loop provisioning cost by completing Table 2 of Attachment 2. The response should explain how the composite ILEC and CLEC weightings used to calculate the all-carriers costs are developed, including the assumptions and data sources.

b) For each of the service charge costs per order and per loop, for each of ILEC and CLEC, provide with supporting rationale, a mapping of the activities identified in response to The Companies(CRTC)26Jan01-8 to those identified in paragraph 39 of Attachment 1 to the 2009 cost submission, identifying each additional activity that is included in the 2009 cost submission.

c) For each company, for each of business and residence, for each of ILEC and CLEC, provide the breakdown of the service provisioning cost by completing Tables 3, 4, 5, and 6 of Attachment 2. The response should further provide the following:

i. A description of each major activity identified in the tables including other activities specified by the company. The description of the major activities should include a discussion of the significant sub-activities. If a major activity or sub-activity is common to both the per order and the per loop service provisioning costs, (e.g., order issuance, as indicated in paragraph 39 of Attachment 1 to the 2009 cost submission), the Bell companies are to provide a detailed description of the activities that are included in each of the per order and the per loop costs and the reason for the inclusion in both the per order and per loop costs;

ii. Confirmation that each activity included in either the cost per loop or cost per order is consistent with the determinations of Decision CRTC 2001-694. If not consistent with that decision, provide the reasons for any deviation from that decision, with supporting rationale;

iii. If an activity is outsourced to a third party, a description of the approach taken to estimate the total unit cost, with supporting rationale;

iv. The Bell companies are to provide the methodology used to derive the time estimates along with supporting assumptions and data sources used. If the time estimates were based on a sample, the Bell companies are to provide details on the sample size and an assessment of the accuracy of the sample; and

v. If unit costs based on the non-LUC approach are also used, the Bell companies are to provide a detailed description of the methodology used to develop the unit costs along with all the assumptions and supporting rationale.

21. With reference to paragraph 79 in Attachment A to the 2009 cost submission, the Bell companies provided the percentages of residence and business loop orders requiring a customer premises visit and the customer premises visits requiring additional work.

a) For each company, for each of residence and business, for each of ILEC and CLEC, provide (i) the assumed percentage of loop orders requiring a customer premises visit and (ii) the assumed percentage of the time those customer premises visits require additional work.

b) With respect to the percentages provided in response to a) above, provide the methodology used to derive the percentages along with supporting assumptions, data sources and vintage of the data used. If the percentages were based on a sample, provide details on the sample size and an assessment of the accuracy of the sample.

22. For each of the per loop and per order service provisioning costs, provide a detailed description, with supporting rationale, of the methodology used to estimate the loop service provisioning expenses such that it excludes those expenses associated with the company’s retail PES and ADSL services. The response should identify, with supporting assumptions, how the company assigns the service provisioning activities and expenses between (i) unbundled loop service, (ii) retail PES, and (iii) retail ADSL service.

23. Refer to paragraph 79 in Attachment A to the 2009 cost submission where the Bell companies indicate that additional work is required on the customer facing side of the Network Interface Device (NID) in order to complete the connection:

a) For each of business and residence, provide a detailed description of the additional activities required on the customer facing side of the NID and identify when and how often such activities are required.

b) Explain why it is appropriate to include the costs associated with the additional activities required on the customer facing side of the NID in the 2009 cost study.

24. Refer to paragraph 35 in Attachment 1 to the 2009 cost submission where the Bell companies stated that the per loop service charges for residence and business are the same for both Bell Canada and Bell Aliant - Central region. For each of residence and business, provide an explanation with supporting rationale as to why the per loop service charges would be expected to be the same for both companies. Further, indicate for which company the analysis was undertaken to estimate the costs associated with the per loop service charge.

25. Refer to paragraph 78 in Attachment A to the 2009 cost submission where the Bell companies indicated that customer premises visits are required under certain circumstances such as a new line connection, second line connection, or NID replacement. In the event that a customer premises visit is required solely to replace a NID, explain why any costs associated with NID replacements should be included in service provisioning costs rather than maintenance expenses. For each company, of the occurrence rates provided in Tables 3 to 6 of the response to question 20 c) above, provide the percentage of premises visits that are required for NID replacement only.

 

26. Refer to paragraph 78 in Attachment A to the 2009 cost submission where the companies stated that the per order costs reflect the fact that field visits are now more prevalent, due to the practice of cable companies cutting Bell Canada service entrance wire when migrating a telephony customer (cable cutting practice):

a) For each company, of the occurrence rates provided in Tables 3 to 6 of the response to question 20 c) above, provide the percentage of customer premises visits that are due to the above-noted cable cutting practice.

b) For each company, explain if and how the company’s occurrence rates have been adjusted to reflect the forward looking view of customer premises visits due to the above-noted cable cutting practice in light of the recent individual company initiatives to address this issue.

27. Refer to paragraph 80 in Attachment A to the 2009 cost submission where the companies indicated that they were able to derive company-specific time estimates for visits to the customer premises for Bell Canada and Bell Aliant-Central region from Bell Canada’s Employee Coaching Report (ECR) tool:

a) Provide a detailed description of the ECR tool including (i) the purpose of the tool, (ii) the information collected, (iii) the update process, (iv) the frequency of the update, and (v) the current vintage of the data.

b) For each company, explain how the information is used to derive company-specific time estimates for visits to the customer premises, with supporting rationale.

c) For each company, for each of business and residence, for each of ILEC and CLEC, provide the time estimate associated with only the truck roll. The response should provide the methodology and assumptions, data sources and vintage used to develop this estimate.

28. Refer to paragraph 81 in Attachment A to the 2009 cost submission where the companies stated that there has been an increase in the amount of time it takes to perform jumper wire work in the CO in order to give customers the choice of having voice services from one service provider and ADSL services from another. Justify why this increase should be attributed to unbundled loop service provisioning costs. Further, for each company, of the time estimates associated with the line item titled “Jumper Wire Work in the CO” provided in Tables 3 to 6 of the response to question 20 c) above, provide an estimate of the increase in the amount of time that relates to the above-noted jumper wire activity.

29. Refer to paragraph 81 in Attachment A to the 2009 cost submission where the companies indicated that the per loop service order costs for a CLEC loop are higher than for an ILEC loop due to the requirements for circuit design and additional time associated with contacting the CLEC. For each company, for each of business and residence, indicate why circuit designs are required for CLEC loops and not for ILEC loops, with supporting rationale.

30. Refer to paragraph 81 in Attachment A to the 2009 cost submission where the companies stated that the per loop service costs are different than the costs filed in The Companies(CRTC)26Jan01-7 TN6488 due to, among other reasons, different weights of CLEC loops in the 2009 cost study. For each company, for each of residence and business, provide a comparison of the CLEC loop weights used between these two cost studies to determine the per loop service costs, with explanations for significant differences.

 

Date modified:

2009-12-23