ARCHIVED - Letter

Ottawa, 26 July 2010

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

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. Mirko Bibic
Senior Vice-President – Regulatory and Government Affairs
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Dear Sirs:

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

Bell Aliant Regional Communications, Limited Partnership and Bell Canada (collectively, the Bell companies) are requested to respond to the interrogatories provided in the attachment, consistent with the process established in the Commission letter dated 23 June 2010. The Bell companies are to provide a version of the responses for the public record abridged in a manner consistent with the level of disclosure to be set out in the Commission staff letter dated 30 July 2010.

A copy of each interrogatory response must be served on all interested parties by 12 August 2010. The responses must be received, not merely sent, by this date. Copies of the documents should also be sent to thomas.hui@crtc.gc.ca.

Yours sincerely,

Original signed by

Lynne Fancy
Director General
Competition, Costing and Tariffs
Telecommunications

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

Encl.: Attachment

Attachment

Unbundled Loop Monthly Rates

1. In the response to The Companies(CRTC)28May10-6 TNs 269 & 7205, the Bell companies re-estimated their 2009 cost submission monthly cost per loop based on the re-calculated copper cable unit cost per meter.

Provide revised Tables 6 in Attachments 2 and 3 of the response to The Companies(CRTC)28May10-2 TNs 269 & 7205 using the re-calculated copper cable unit cost per meter.

2. In response to The Companies(CRTC)28May10-7 b) TNs 269 & 7205, the Bell companies indicated that:

 the "Order Fulfillment - Perform CO Framework - Data & New Services" cost is included in the Outward Order Expenses for CLEC Loops;
 this cost is associated with the transfer of equipment within the same or another Central Office (CO), including removing or re-running CO cross-connections related to data and new services; and
 due to the absence of appropriate order volume drivers associated with CLEC Loops, this cost was included as on Outward Order expense for CLEC Loops.

a) Confirm that re-running CO cross-connections for data and new services are activities that relate to establishing service. Identify, if any, other activities included in „‟Order Fulfillment – Perform CO Framework – Data & New Services‟‟ that relate to establishing service.

b) If the Bell companies have identified any activities that relate to establishing service in response to part a) above, provide estimates of the unit costs associated with these activities and provide revised Tables 6 in Appendices 1 and 2 of Attachment 1 to the 2009 cost submission excluding these costs

Unbundled Loop Service Order Charges

3. In response to The Companies(CRTC)23Dec09-20, the Bell companies indicated that to estimate the truck roll time required to fulfill a loop order, the Bell companies extracted from the Employee Coaching Record (ECR) tool, the average time recorded to perform this activity by Bell Canada and Bell Aliant-Central region technicians for the months of August, September and October 2008 for each of ILEC and CLEC loop orders. Further, in response to The Companies(CRTC)23Dec09-27, the Bell companies stated that the purpose of the ECR tool is to track the efficiency and productivity of the field technicians.

a) For each of Bell Canada and Bell Aliant-Central territory, provide a list of the locations included in the ECR extract noted above.

b) Provide an estimate of the productive time in hours per technician that is recorded in ECR on a daily basis and this productive time as a percentage of the technician‟s total time (paid hours per day).

4. In part b) of the response to The Companies(CRTC)28May10-15, the Bell companies submitted “the average truck roll time included for ILEC orders does not include the time required for other activities, such as installing DSL service. Technician time spent on installing a voice line is recorded by the technician against the order number for that voice line. Time spent installing DSL or any other non-voice service would be recorded against the other order number for that other service”. Further, in parts c) and d) of the response, the Companies provided revised Visiting Customer Premises activity time estimates and costs based on an ECR extract for the months of August, September and October 2009.

a) Identify the other non-voice services referred to above that could be recorded against another order number by the technician.

b) Explain if and how the time associated with additional work at customer premises for NID is recorded by the technician as part of either the voice service or another non-voice service, specifying which service, with supporting rationale. Confirm that this NID work time is excluded from the total time estimate associated with the ECR voice service order and if so, identify and quantify the adjustments the Bell companies made to exclude these costs; if these adjustments were not made, identify and quantify the adjustments that would be needed to exclude these costs from the total time estimate associated with the ECR voice service order.

c) In the event that a customer order requests both voice and high speed internet services and that this request causes a customer premises visit:

i. Identify the separate activities that would be assigned to each of the voice and high speed Internet service orders; further, for each activity that is common to both services orders (e.g., travel time, drop installation time) explain how the time for the common activity is assigned to each service, with supporting rationale; confirm that this separation of time by service would be recorded as such in ECR.

ii. Indicate whether the approach described in response to i) above would also be used for jobs where voice service and non-voice services other than high speed Internet are being provided. If not, describe the method that would be used to record and assign the travel time in these cases. If travel time is not split between the voice service and non-voice service, provide rationale as to why the time is wholly assigned to the voice service.

d) In the event that a customer order requires a customer premises visit, provide the expected occurrence rate for the following types of orders:

i. Order for voice service only

ii. Order for both voice and high speed Internet services

iii. Order for voice and non-voice services

e) From the ECR extract noted above, provide the average time estimate for the technician‟s time associated with each of the following types of orders:

i. Residence voice

ii. Business voice

iii. Residence high speed Internet

iv. Business high speed Internet

v. Other (specify)

5. Refer to the response to The Companies(CRTC)28May10-11.

a) Confirm that the time associated with the creation of a directory listing for Residence or Business customers was included in the ILEC Order Issuance activity time estimate; further, confirm that this activity is retail in nature; if so, provide a revised time estimate that excludes this sub-activity.

b) In response to part d) of the above-noted interrogatory, the Bell companies submitted “No other adjustments were made to the time estimates to exclude any sub-activities that are retail in nature.” Using the format of Tables 3-6 in The Companies (CRTC)23Dec09-20, for each of ILEC residence and business retail customers, provide revised unit cost estimates for the order issuance activity that reflect the Commission determinations regarding the removal of retail-related costs in paragraph 30 of Interim approval for revised unbundled loop service order charges, Decision CRTC 2001-694, 16 November 2001.

c) In response to part e) iii) of the above-noted interrogatory, the Bell companies indicated that one order would be issued for a request for three loops of one CLEC end-customer at the same location. Given that the order issuance activities for the CLEC are classified as “per loop“, explain whether the Bell companies would carry out three order issuance activities; if not, comment on the reasonableness of including the order issuance activity in the per loop service charge instead of the per order service charge.

6. In response to The Companies(CRTC)23Dec09-21, the Bell companies submitted that the CLEC percentage of customer premise visits requiring additional work was tracked from March 2007 to April 2008 while the ILEC percentage of customer premise visits requiring additional work was estimated by Bell Canada Field Services‟ SMEs. Provide an explanation as to why the Bell Canada Field Services‟ SME estimate of the frequency of ILEC Residence customer premise visits requiring additional NID work is significantly different from that for CLECs.

7. Refer to part c) i) in the response to The Companies(CRTC)28May10-19 and to Tables 3 to 6 in the response to The Companies(CRTC)23Dec09-20.

a) Confirm that the ILEC 2009 unit costs for Jumper Wire Work in the CO for the Bell companies‟ retail customers are significantly different from the ILEC 2001 unit costs provided for the Perform Distribution Framework activities in Tables 5 and 7 of Attachment 2 in the response to The Companies(CRTC)26Jan01-1. Provide detailed explanations to justify these changes to the unit costs (and associated time estimates) for this activity.

b) In the above-noted response the Bell companies submitted that the average time to perform the CLEC jumper wire work activity is longer than that of the ILEC jumper wire work activity due to the additional step of the CO technician contacting the CLEC provider to confirm that the work has been completed. Identify the activities involved in this additional step and provide detailed explanations to justify the estimated additional time required for these activities.

8. In the response to The Companies(CRTC)28May10-12, the Bell companies indicated that the time estimates and occurrence rates used in the 2009 cost submission for the CLEC Answering Inquiries-General activity are identical to those provided in Table 2 of the response to The Companies(CRTC)26Jan01-7.

a) In Tables 1 and 2 of Attachment 3 of The Companies(CRTC)26Jan01-1, the Bell companies identified Pre-Order Information and Query to Order activities as CLEC sub-functionalities for the Receive Inquiries activity, along with the associated time estimates, unit costs and occurrence rates. Provide the most recent update of the Receive Inquiries unit costs consistent with the Bell Canada data provided in the above-noted Tables 1 and 2, if available.

b) Confirm that the 2009 SME time estimates, unit costs and occurrence rates for the CLEC Answer Inquiries – General activity are significantly different from the time estimates, unit costs and occurrence rates associated with Bell Canada‟s 2001 data as provided in Tables 1 and 2 of Attachment 3 of The Companies(CRTC)26Jan01-1. Provide detailed explanations to justify the changes to the unit costs, associated time estimates and occurrence rates between the 2009 Bell Canada Field Services SME estimates and the above-noted 2001 Bell Canada data or the revised data as provided in response to part a) above.

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; 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; regulatory@teksavvy.com

Date modified:

2010-07-26