ARCHIVED - Letter

Ottawa, May 20, 2010

Our File: 8663-C12-201000653  

BY E-MAIL

To:  Distribution List

Re:  Obligation to serve and other matters, Telecom Notice of Consultation CRTC 2010-43: Commission interrogatories

Pursuant to the procedures set out in Telecom Notice of Consultation CRTC 2010-43, attached are the Commission interrogatories associated with this proceeding.

Responses to these interrogatories are to be filed with the Commission, and served on all parties to this proceeding, by 15 June 2010.   Responses are to be received, and not merely sent, by this date.

Appendix 1 contains the distribution list.

Appendix 2 contains the interrogatories and to whom they are addressed.

Yours sincerely,

Original signed by:

John Macri
Director
Telecommunications Policy

As amended by Telecom Notice of Consultation CRTC 2010-43-2.

Appendix 1

Distribution List:

regulatory@bell.alliant.ca; bell.regulatory@bell.ca; iworkstation@mtsallstream.com; regulatory.affairs.@telus.com; reglementa@telebec.com; document.control@sasktel.sk.ca; regulatoryaffairs@nwtel.ca

Appendix 2

Interrogatories to the following incumbent local exchange carriers (ILECs):

• Bell Aliant Regional Communications, Limited Partnership (Bell Aliant), Télébec, Société en Commandite (Télébec), NorthernTel, Limited Partnership (NorthernTel), and KMTS, (collectively, the Bell Aliant Companies);
• Bell Canada;
• MTS Allstream Inc. (MTS Allstream);
• Northwestel Inc. (Northwestel);
• Saskatchewan Telecommunications (SaskTel); and
• TELUS Communications Company (TELUS).

Interrogatories to Bell Aliant, Bell Canada, MTS Allstream, SaskTel, Télébec and TELUS

101. Provide the total number of subscribers in the company’s serving territory who only subscribe to wireline residential primary exchange service (PES), i.e. residential PES customers who do not subscribe to the company’s Internet, wireless, television, optional or toll service plans.  Indicate the percentage that these subscribers represent in relation to the total number of the company’s wireline residential PES subscribers.  This information should be provided by i) province, ii) forborne local exchanges (taken as a whole) and iii) non-forborne local exchanges (taken as a whole).

102. Provide an estimate of the total number of Held Orders for the company, as of 30 April 2010, due to shortages of facilities for customers who have requested wireline residential PES.  This information should be provided by i) province, ii) forborne local exchanges (taken as a whole) and iii) non-forborne local exchanges (taken as a whole), for each of the following intervals:

a) Held Orders of 90 days or less;

b) Held Orders of greater than 90 days but less than 1 year; and

c) Held Orders of 1 year or more.

103. For each of Bands E, F and G,  provide, as applicable, the number of residence NAS in service provided by your company in forborne exchanges as of 31 December 2009 in each of the following ILEC territories:

a) Bell Aliant NL;

b) Bell Aliant NS;

c) Bell Aliant NB;

d) Bell Aliant PEI;

e) Bell Aliant Central (Ontario and Quebec);

f) Bell Canada;

g) MTS;

h) SaskTel;

i) Telus AB;

j) Telus BC;

k) Telus PQ; and

l) Télébec.

Interrogatories to Bell Aliant, MTS Allstream, SaskTel, Télébec and TELUS

104. Refer to Bell Canada’s 26 April 2010 submission, Appendix 4, Tables 3, 4 and 5.  Indicate, by province and for each forborne residential local exchange within the company’s serving territory, the company’s stand-alone wireline residential PES rate (including all standard mandatory charges, such as touch-tone, network access charges 911 and message relay).

Interrogatories to Bell Aliant, MTS Allstream, Northwestel, SaskTel, Télébec and TELUS

105. At paragraph 119 of its 26 April 2010 submission, Bell Canada states that the current $5 implicit target subsidy from optional local services is clearly too low.  Bell Canada then provides an analysis of the current margins for optional local services, toll services and network access charges (NACs) in HCSAs in its serving territory.  Bell Canada’s analysis suggests that a combined implicit target subsidy from optional local services, toll services and the NAC is more than $15 per month per residential NAS.

a) Provide an estimate for your company of the contribution / margin from optional local services, toll services and any NAC in HCSAs.  Provide a detailed description of the methodology used in the development of these estimates, including all assumptions and relevant data.   The description should include, but not be limited to, how revenues associated with bundled services and how any cost components used in the analysis were estimated.  Provide the revenues used in the derivation of the margins.

b) Comment, with supporting rationale, on whether the implicit target contribution should also include margins associated with other services offered by the company that utilise the local loop, such as DSL and IPTV services.

Interrogatory to Bell Aliant, Bell Canada, MTS Allstream, Télébec and TELUS

106. At paragraph 96 of its 26 April 2010 submission, SaskTel proposes that the Commission “… re-visit the definition of HCSAs and classify only those locations not within municipal boundaries (or Base Rate Areas, in SaskTel’s case) as high cost, regardless of the location of the serving central office.”

Does your company in the operation of its business use a geographic classification similar or equivalent to SaskTel’s Base Rate Area?  If so, provide a detailed description of that geographic classification, including the parameters (e.g., loop lengths, municipal boundaries, etc) and any associated thresholds used in its definition.

Interrogatories to the Bell Aliant Companies

107. At paragraph 152 of their submission, the Bell Aliant Companies stated that “… in the case of SILECs with less than 20,000 NAS, only wireless to wireless portability (intramodal) would be mandated at the SILECs expense and SILECs could also implement the porting-out process only if SILECs elected to do so.”  The Bell Aliant Companies further submitted that if a wireless service provider (WSP) specifically requests wireline to wireless number portability (intermodal) of a small ILEC that has fewer than 20,000 NAS, the Commission should determine on a case-by-case basis if intermodal number portability should be implemented in that small ILEC’s territory, and how the small ILEC’s costs of implementation should be shared between the small ILEC and the WSP.

a) If the implementation of number portability by the small ILECs was made mandatory, explain why the implementation of the porting-out process would be at the small ILEC’s discretion.

b) For a small ILEC with fewer than 20,000 NAS where a WSP requests only intramodal portability, explain why the implementation should be at the small ILEC’s expense.

c) For a small ILEC with fewer than 20,000 NAS where a WSP requests intermodal portability, indicate, with supporting rationale, how the costs of implementing intermodal portability should be apportioned between the small ILEC and the WSP.

d) For a small ILEC with fewer than 20,000 NAS where a WSP requests both intramodal and intermodal portability, is it your proposal that the costs of implementation could be shared between the small ILEC and the WSP?  If so, indicate, with supporting rationale, how those costs should be apportioned between the small ILEC and the WSP.  If not, explain why not.

108. At paragraph 143 of their submission, the Bell Aliant Companies stated that the roll-out of competition should be enabled in all small ILEC operating territories. At paragraph 144, the Bell Aliant Companies stated that specific arrangements to accommodate new entrants should be cognizant of the expense, and should balance this against the benefits. The Bell Aliant Companies further submitted that local competition should continue to be implemented in small ILEC territories on a request-driven basis.

Indicate, with supporting rationale, which service provider(s) should incur the costs of implementing local competition in small ILEC operating territories.  If the costs are to be shared, indicate with supporting rationale, how those costs should be apportioned between relevant service providers.  Further, indicate with supporting rationale, how those costs could be reasonably recovered.

109. At paragraph 148 of their submission, the Bell Aliant Companies commented that local number portability (LNP) should not be mandated for small ILECs with fewer than 20,000 NAS unless specifically requested by a CLEC. The Bell Aliant Companies further submitted that if a CLEC made a request for LNP, then the small ILEC should include it in its implementation plan and the Commission could make a determination on the need for LNP implementation as well as on the apportionment of costs between the small ILEC and the CLEC if LNP was deemed necessary.

Indicate, with supporting rationale, how the costs of implementing LNP should be apportioned between the small ILEC and the CLEC in territories served by a small ILEC that has fewer than 20,000 NAS.

Interrogatories to Bell Canada

110. In Figure 3 of its 26 April 2010 submission, Bell Canada provides estimates of “Margins Associated with Optional Local Services, the Network Access Charge and Toll for 2009”.

a) Provide a detailed description of the methodology used in the development of these estimates, including all assumptions and relevant data.  The description should include, but not be limited to, how revenues associated with bundled services were estimated and how any cost components used in the analysis were estimated.

b) For each cell in Figure 3, provide the revenues used in the derivation of the margins.

c) Comment, with supporting rationale, on whether the implicit target contribution should also include margins associated with other services offered by the company that utilise the local loop, such as DSL and IPTV services.

111. At paragraph 203 of its submission, Bell Canada states the following:

“For SILECs with fewer than 20,000 NAS only wireless-to-wireless porting should be mandated, unless the wireless service provider (WSP) makes a specific request.  If a WSP specifically requests WNP, the Commission could rule on a case-by-case basis if such WNP should be implemented in the SILEC's territory, and how the SILEC's cost of implementing such WNP would be shared between the SILEC and the WSP.”

a) For small ILECs with fewer than 20,000 NAS where a WSP requests only wireless to wireless portability, is it your proposal that the costs of implementation could be shared between the small ILEC and the WSP?  If so, indicate, with supporting rationale, how those costs should be apportioned between the small ILEC and the WSP.  If not, explain why not.

b) Indicate, with supporting rationale, how the costs of implementing WNP should be apportioned between the small ILEC and the WSP in territories served by a small ILEC that has fewer than 20,000 NAS.

c) For small ILECs with fewer than 20,000 NAS where a WSP requests wireline to wireless portability, is it your proposal that the costs of implementation could be shared between the small ILEC and the WSP? If so, indicate, with supporting rationale, how those costs should be apportioned between the small ILEC and the WSP.  If not, explain why not.

112. At paragraph 195 of its submission, Bell Canada stated that the Commission should continue to adapt the large ILEC local competition framework to small ILEC needs in recognition of their smaller size and more limited resources.  At paragraph 196, Bell Canada stated that local competition should continue to be implemented in small ILEC territories on a request-driven basis.

Indicate, with supporting rationale, which service provider(s) should incur the costs of implementing local competition in small ILEC operating territories.  If the costs are to be shared, indicate with supporting rationale, how those costs should be apportioned between relevant service providers.  Further, indicate with supporting rationale, how those costs could be reasonably recovered.

113. At paragraph 199 of its submission, Bell Canada stated that for small ILECs with fewer than 20,000 NAS, local competition should be implemented without local number portability (LNP), unless a CLEC specifically request LNP.  Bell Canada further submitted that if a CLEC specifically request LNP of a small ILEC that has fewer than 20,000 NAS, the small ILEC would include in its local competition implementation plan the costs that it would incur to implement LNP; then, the CRTC could rule on a case-by-case basis if LNP should be implemented in that small ILEC’s territory, and how the small ILEC’s cost of implementing LNP would be shared between the small ILEC and the CLEC.

Indicate, with rationale, how the costs of implementing LNP should be apportioned between the small ILEC and the CLEC in territories served by a small ILEC that has fewer than 20,000 NAS.

Interrogatory to MTS Allstream

114. In paragraph 78 of its 26 April 2010 submission, MTS states the following:  

“...[A]ssuming that a currently relevant BBSO definition would entail download speeds of between 3 to 4 Mbps, the total uneconomic cost of expanding such a BBSO to currently unserved or underserved areas (subject to the reasonable restrictions in the Terms of Service) could be in the range of between $9 billion to $15 billion over a period of ten years.”

Provide a full description of how the range of $9 billion to $15 billion was developed, including the methodologies, assumptions (e.g., technologies, service providers, costs and revenues) and external references. 

Interrogatories to SaskTel

115. At paragraph 96 of its 26 April 2010 submission, SaskTel proposes that the Commission “…re-visit the definition of HCSAs and classify only those locations not within municipal boundaries (or Base Rate Areas, in SaskTel’s case) as high cost, regardless of the location of the serving central office.”

a) Provide a detailed description of SaskTel’s “Base Rate Area”, including a list of the parameters (e.g., loop lengths, municipal boundaries, etc) and any associated thresholds used in its definition

b) Provide a detailed comparison of Base Rate Areas with “municipal boundaries” in SaskTel’s territory, including a description of how Base Rate Areas reflect changes over time in municipal boundaries.  Identify and quantify, in terms of residence lines as of 31 December 2009, all situations in which a Base Rate Area currently differs from a “municipal boundary”.

Provide a detailed description of how SaskTel’s proposal to use Base Rate Areas and municipal boundaries for the purposes of contribution fund would work.  For example, would areas outside a base rate area or municipal boundary be classified into bands?  If so, how?

116. At paragraph 93 of its 26 April 2010 submission, SaskTel states that “…the inaccuracies in the contribution regime remove any incentive, for those who are not obliged to do so, to serve these truly high cost NAS and may lead to competitive inequities and regulatory gaming.”

a) Define “regulatory gaming” in the context of the national contribution fund. 

b) Provide a list of all instances, with complete descriptions, of such regulatory gaming that have taken place in SaskTel’s high cost areas.

Date modified:

2010-05-20