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:

sdesy@actq.qc.ca; gcordeau@maskatel.qc.ca ; jpatry@telcourcelles.qc.ca; telstep@telstep.net; telvic@telvic.net; pallard@cooptel.qc.ca; rroy@telwarwick.qc.ca; j-fmathieu@telupton.qc.ca; alain.duhaime@sogetel.com; paul.frappier@telmilot.com; nantel@tellambton.net; regulatory@bell.aliant.ca; dreynard@kmts.biz; reglementa@telebec.com; Regulatory.Matters@corp.eastlink.ca; Lisa.marogna@cwct.ca; scoffey@dryden.ca; jonathan.holmes@ota.on.ca; m.baron@brktel.on.ca; regulatory@brucetelecom.com; Nicolet@puc.net; regulatory@execuling.com; a.schneider@hay.net; grubb@hurontel.on.ca; pdowns@nexicom.net; sachuter@tcc.on.ca; Roxboro@ontarioeast.net; pwightman@wightman.ca; rbanks@mornington.ca; wagrier@1000island.net; steve@wtccommunications.ca; tracy.cant@ontera.ca; jdowns@nexicomgroup.net; dave.baxter@guadro.net; gosfield@gosfieldtel.com; nfrontenac@kw.igs.net; barb@rideau.net; rob.olenick@tbaytel.com

Interrogatories to the small incumbent local exchange carriers (small ILECs)

Interrogatories to all small ILECs

101. At paragraph 119 of its 26 April 2010 submission, Bell Canada stated 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.

102. At paragraph 54 of their joint submission, the Ontario Telecommunications Association and TBayTel describe the “doughnut effect” as it relates to local competition in the small ILEC operating territories.  The Association des Compagnies de Téléphone du Québec also discusses the doughnut effect at paragraph 22 of its submission.

a) For each exchange in your serving territory, provide the following:

i. Total residence NAS as of 31 December 2009;
ii. The percentage of residence NAS that are in the core (i.e. the centre of the doughnut) and how you define this core;
iii. The percentage of your local and access operating revenues generated by these NAS; and
iv. The percentage of local service subsidy you receive from the National Contribution Fund that is used to offset costs of provisioning these services.

b) For each exchange in your serving territory, provide the following:

i. Total business NAS as of 31 December 2009;
ii. The percentage of business NAS that are in the core and how you define this core if different than a) ii. above; and
iii. The percentage of your local and access operating revenues generated by these NAS.

c) If the Commission was to allow local competition in your serving territory, to what extent is a facilities-based service provider present in the core of each exchange in your serving territory?  Identify:

i. the name(s) of the potential competitor(s); and

ii. the percentage, if readily available, of each of residence and business NAS in the core that could be served by the potential competitor(s).

Refer to Appendix 3 for a list of the small ILECs.

“In addition, SILECs have expanded into adjacent territories as CLECs, internet and broadcasting distribution service providers.  The extent of these investments and expansion belie claims that these companies lack the financial resources to compete effectively in their own markets.”

For each of the years 2007 to 2009, provide your company’s total capital expenditures associated with network infrastructure outside of your incumbent operating territory.  Provide a list of services offered by your company in the territories outside of your incumbent operating territory.

Interrogatory to the Ontario Telecommunications Association

104. At paragraphs 14 to 16 of its submission, the Ontario Telecommunications Association stated the following:

“Depending on the magnitude of market share loss, the SILEC’s ability to continue to provide new services to the whole customer base will be greatly impaired...SILECs will not be able to afford to offer enhanced services in rural areas, rural rates might have to increase to guarantee revenue and recover cost... [T]hose outside [the cable company footprint] will not benefit and may see service levels drop and prices increase.”

Indicate, with supporting evidence, whether the predicted outcome described above reflects the current situation in the three SILEC territories where local competition has already been implemented, namely the serving territories of NorthernTel Limited Partnership, People’s Tel Limited Partnership and TBayTel.

Appendix 3

Small ILECs
(listed by association / company which made a submission in this proceeding)

Association des Compagnies de Téléphone du Québec

Téléphone Guèvremont inc.
La Compagnie de Téléphone de Lambton inc.
Le Téléphone de St-Éphrem inc.
La Compagnie de Téléphone de St-Victor
CoopTel
La Cie de Téléphone de Courcelles inc.
La Compagnie de Téléphone de Warwick
La Compagnie de Téléphone Upton inc.
Sogetel inc.
Téléphone Milot inc.

Bell Aliant Regional Communications, Limited Partnership

KMTS
NorthernTel, Limited Partnership

Bragg Communications Inc.

Amtelecom Limited Partnership
People's Tel Limited Partnership

CityWest Telephone Corporation

Dryden Municipal Telephone System

Ontario Telecommunications Association

Brooke Telecom Co-operative Limited
Bruce Telecom
Cochrane Telecom Services
Execulink Telecom Inc.
Gosfield North Communications Co-operative Limited
Hay Communications Co-operative Limited
Huron Telecommunications Co-operative Limited
The Lansdowne Rural Telephone Company Limited
Mornington Communications Co-operative Limited
Nexicom Telecommunications Inc.
Nexicom Telephones Inc.
North Frontenac Telephone Corporation Limited
North Renfrew Telephone Company Limited
Ontera
Quadro Communications Co-operative Inc.
Roxborough Telephone Company Limited
Tuckersmith Communications Co-operative Limited
Westport Telephone Company Limited
Wightman Telecom Limited

TBayTel

Dryden Municipal Telephone System did not make a submission in this proceeding.

Date modified:

2010-05-20