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Ottawa, 15 September 2010

Our Reference: 8638-C12-201014620

BY E-MAIL

To Distribution List:

Re: Wholesale high-speed access services proceeding, Telecom Regulatory Policy CRTC 2010-632, 30 August 2010 - Request to file proposed tariffs for TPIA services with supporting Phase II cost studies

In Wholesale high-speed access services proceeding, Telecom Regulatory Policy
CRTC 2010-632, 30 August 2010 (Regulatory Policy 2010-632), the Commission directed cable carriers[1] to file within 90 days of the date of the decision, proposed tariffs that include proposed configurations and rates, with supporting Phase II cost studies, for TPIA services that aggregate traffic for the competitors’ end-customers as set out in section B (a) of this decision.

In order to expedite the rate review and approval process, the cable carriers are requested to provide responses to the attached interrogatories along with their respective Phase II cost studies.

Phase II cost studies and responses to the interrogatories are to be filed in accordance with the process outlined in Regulatory Policy 2010-632 and are to be received, not merely sent, by the dates indicated.

Yours sincerely,

Original signed by

Mohammed Omar for/Yvan Davidson
Senior Manager, Competitor Services and Costing

cc: Mohammed Omar, mohammed.omar@crtc.gc.ca
Interested parties to Regulatory Policy 2010-632

ENCL.: Distribution List

DISTRIBUTION LIST

Cogeco Cable Canada Inc.: telecom.regulatory@cogeco.com
Rogers Cable Communications Inc.: ken.engelhart@rci.rogers.com
Shaw Communications Inc. : Regulatory@sjrb.ca
Videotron Ltd.: regaffairs@quebecor.com

List of Interested Parties

Northwestel Inc.: regulatoryaffairs@nwtel.ca
Bell Canada:  bell.regulatory@bell.ca
Télébec: reglementa@telebec.com
Saskatchewan Telecommunications: document.control@sasktel.sk.ca
MTS Allstream Inc.: iworkstation@mtsallstream.com
Bell Aliant Regional Communications:  regulatory@bell.aliant.ca
Eastlink Cable Systems: Regulatory.Matters@corp.eastlink.ca
Cybersurf Corp. : marcel.mercia@cybersurf.com
Quebec Coalition of Internet Service Providers (QCISP): reglementation@xittel.net
Distributel Communications Limited: regulatory@distributel.ca
OneConnect Services Inc.: lisagoetz@globalive.com
Primus Telecommunications Canada Inc.: regulatory@primustel.ca
TELUS Communications: regulatory.affairs@telus.com
Mark H. Goldberg & Associates Inc.: crtc@mhgoldberg.com
Ripnet Ltd.: eric@rothschildco.com
The Internet Centre Inc.: gfletcher@incentre.net
Nucleus Inc.:berzins@nucleus.com
McCarthy, Tetreault, Barrister & Solicitors: babramson@mccarthy.ca
Execulink Telecom Inc.: regulatory@execulink.com
Christian S. Tacit: ctacit@tacitlaw.com
AGBriggs Consulting Inc.: abriggs@cogeco.ca
Next Dimension Communications Corporation: slavalevin@ethnicchannels.com
Les.Net (1996) Inc. : crtc@les.net
LCB Consulting. Inc.: LBC_Consulting@live.ca
Ministère de la Culture et des Communications: andre.labrie@mcccf.gouv.qc.ca
Open Source Solutions: bob.Allen@abccomm.com
TIA Telecommunications: ghariton@sympatico.ca
Wall Communications Inc.: lefebvre@rogers.com
Fraser Milner Casgrain: kirsten.embree@fmc-law.com
Bruce   Buchanan : bruce@brucebuchanan.net
Ontario Telecommunications Association: jonathan.holmes@ota.on.ca
Christopher Taylor: cataylor@cyberus.ca
ABC Communications: chris.allen@abccomm.com
Kathleen   Turnsek: regulatory@vianet.ca
The Consumer Groups: piac@piac.ca
Canadian Association of Internet Providers: tom.copeland@caip.ca
Union des consommateurs: hemond@consommateur.qc.ca
Giganomics Consulting Inc.: blackwell@giganomics.ca
James H Pratt Consulting Inc.: jhpratt@msn.com
EGATE Networks Inc.: crtc@paul.ca
Peace Region Internet Society: pris@pris.ca
Lemay-Yates Associates Inc.: regulatory@lya.com
TekSavvy Solutions Inc. : regulatory@teksavvy.com
View Communications Inc.: dmckeown@viewcom.ca
TBayTel : David.Wilkie@tbaytel.com
Fibernetics Corporation: regulatory@fibernetics.ca
Vaxination Informatique : jfmezei@vaxination.ca
Electronic Box Inc.:  jp@electronicbox.net
TBayTel: stephen.scofich@tbaytel.com
British Columbia Broadband Association (BCBA): regulatory@bcba.ca
Liam Buckley: crtcmail@gmail.com
Province of British Columbia: telecom@gov.bc.ca

Attachment

Interrogatories for Cable Carriers

101. Provide an electronic copy of the economic evaluation model along with the associated model documentation.  Also, provide a brief description of all input data variables used in the costing analysis along with their respective values. Further provide any changes in modelling methodology and assumptions from those used in the cost studies submitted in the proceeding leading to Decision 2006-77, with supporting rationale. The response should further provide a discussion of any changes to the financial parameters, including income tax and the newly introduced harmonized sales tax in certain provinces, with supporting rationale.

102. For each proposed TPIA matching speed service:

a) Provide the schematic diagram(s) showing the service configuration(s) and identifying the resources by type of equipment required to provide service; and

b) For each type of equipment identified in response to part a) above, indicate whether the equipment is dedicated to the TPIA service (i.e., used only by this service and not shared with any other services) or shared with other company services (i.e., cable television, video-on-demand, PPV, telephony internet, etc.).

103. With respect to the development costs associated with aggregation of traffic for the TPIA’s end-customers as set out in section B (a) of Regulatory Policy 2010-632:

a) Identify, with supporting rationale, all the associated developmental activities and resources;

b) Provide a detailed breakdown of the development costs into its major components;

c) For each major component identified in response to part a) above provide (i) a brief description and (ii) the methodology and assumptions used to develop the cost estimate; and

d) Identify, with supporting rationale, the proposed revised points of interconnection, specifying each location.

104. For each proposed TPIA matching speed service, for each of All Carrier and TPIA end-user only demand:

a) Provide the annual forecast of the in-service demand including the methodology and assumptions used to estimate the in-service demand
(e.g. market size, demand growth, cable carrier market share, competitor market share) over the study period; and

b) Provide the most current actual in-service demand specifying the vintage of the data.

105. For each proposed TPIA matching speed, for each of the major resource components identified in response to 102) a) above, provide the following:

a) Unit cost (i.e. Installed First Cost) specifying the vintage of the data;

b) Explanations regarding the application of retrospective productivity improvement factors (PIFs) and capital increase factors (CIFs) to restate each unit cost from the vintage year to the year 2010, with supporting rationale;

c) Average working fill factor, if any, and life estimate; if these values are different from those assumed in the cost studies submitted in the proceeding leading to Decision 2006-77, provide supporting rationale; and

d) PWAC value.

106. For each of the major resource components that are shared by TPIA and other service(s) as identified in response to 102) b) above:

a) Provide any changes in the assumed proportions of the equipment costs that have been attributed to TPIA compared to those determined in Decision 2006-77; further if any changes, explain how the proposed proportion of the equipment costs that have been attributed to TPIA has been identified and quantified.

b) Place on the public record any proposed revised proportion of the equipment costs that have been attributed to TPIA, consistent with the level of disclosure determined in the proceeding leading to Decision 2006-77.

107. With reference to the estimation of the capital cost estimates that are causal to traffic demand:

a) Explain if and how peak period usage and/or monthly average traffic volumes per end-user have been used to estimate the costs of the resources / equipment identified in response to interrogatory 102) a) above.  If peak period usage is not taken into consideration, explain why not.

b) For each proposed TPIA matching speed service:

i. Provide the per end-user monthly average traffic volumes and peak period traffic levels in the first year of the cost study that were assumed for the purpose of determining the traffic related costs along with the supporting assumptions (e.g. traffic studies) and rationale.  The response should identify the type and vintage of information
(e.g. if sample used, identify sample size, date of sample, locations selected, etc.), explain how they were estimated and specify the peak period; and

ii. Describe the changes in assumptions made to estimate per end-user monthly average traffic volumes and peak period traffic levels for the subsequent years of the cost study.

iii. Provide the per end-user monthly average traffic volumes and peak period traffic levels that are currently used for provisioning purposes.

108. Refer to Cogeco(CRTC)07April06-13, Rogers(CRTC)7April06-13, Shaw(CRTC)7April2006-12, Videotron(CRTC)07April2006-13, as applicable to each cable carrier, in the proceeding leading to Decision 2006-77.  For each proposed TPIA matching speed service, for each expense line item identified in the above interrogatories, as applicable to each cable carrier:

a) Provide any changes in costing methodology and assumptions from those used in the cost studies submitted in the proceeding leading to Decision 2006-77.

b) Provide a breakdown of the expense estimate into the major sub-activities.

c) For any major sub-activity of the expense item that is developed based on explicit time estimates, provide the time estimate and labour unit cost values; further provide the associated vintages and the source of information.

d) For any major sub-activity of the expense item that is developed based on unit costs or cost factors, provide unit costs or cost factors specifying the vintage of the data.  Further explain if and how retrospective PIFs and expense increase factors (EIFs) were applied, if any, to restate each unit cost from the vintage year to the year 2010, with supporting rationale.

e) For any expense item that is common to TPIA and the company’s retail high speed Internet Service, provide a comparison of the estimate of the per end-user unit cost associated with the company’s expenses to provide its own high speed Internet Service and to provide the TPIA Service.

f) Provide the methodology and assumptions used to determine the revenue percent charges, if any included.

109. With respect to the proposed calculation of Income Taxes and Terminal Value in the TPIA matching speed service cost studies, provide any changes in costing methodology and assumptions from those used in the cost studies submitted in the proceeding leading to Decision 2006-77, with supporting rationale.  

[1] In this letter, the term “cable carriers” refers to Cogeco Cable Canada Inc., Rogers Cable Communications Inc., Shaw Communications Inc., and Videotron Ltd.

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