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Ottawa, 25 May 2011

Our reference: 8663-B7-200905052

BY EMAIL

Eric Dobson
President & CEO
Bruce Telecom
Box 80, 3145 Hwy 21 North
Tiverton, Ontario
N0G 2T0
regulatory@brucetelecom.com   

Re: Local competition in small ILEC territories – Implementation plan for Eastlink

Dear Sir:

In a letter dated 20 May 2011, Bragg Communications Inc., carrying on business as Eastlink (Eastlink), informed the Commission and Bruce Telecom that it is still interested in entering Bruce Telecom’s territory as a competitive local exchange carrier (CLEC). Eastlink indicated that it intends to offer local switched services to customers located in the exchanges of Port Elgin and Paisley, Ontario.  This letter was posted on the Commission’s website on 24 May 2011 at the following address:

http://www.crtc.gc.ca/partvii/eng/2009/8663/b7_200905052.htm

As set out in a Commission staff letter dated 5 May 2011, the following process applies:

Where a CLEC or a WSP [wireless service provider] reaffirms its interest in pursuing competition or implementing WNP [wireless number portability] in a small ILEC’s [incumbent local exchange carrier] territory, the small ILEC in question is to file an updated implementation plan with the Commission, serving a copy to the CLEC and/or WSP, no later than 30 days from the date the CLEC’s or WSP’s letter of confirmation of interest is posted on the Commission’s website.  Each small ILEC’s updated implementation plan plan must contain

Based on the above, Bruce Telecom must file its implementation plan and other required information with the Commission, serving a copy to Eastlink, no later than 23 June 2011.

Bruce Telecom is to ensure that its updated implementation plan addresses its proposed arrangements with Eastlink and includes any other requirements needed to implement local competition in its territory.  Commission staff reminds Bruce Telecom that it should begin discussion with Eastlink about its requirements as soon as possible.

Sincerely,

‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manger, Tariffs
Telecommunications

cc: Nathalie MacDonald, Eastlink, regulatory.matters@corp.eastlink.ca
Martin Brazeau, CRTC, (819) 997-3498, martin.brazeau@crtc.gc.ca

Appendix 2

[to 5 May 2011 Commission staff letter]

Small ILECs are to include the following cost and cost recovery elements as part of their implementation plans:

1. The company’s total number of residential and business NAS, as of 1 June 2011.

2. The company’s ownership and affiliate structure, including the total residential and business NAS of all the small ILEC’s affiliates and/or its parent company as of 1 June 2011.

3. A 10-year demand forecast using Table 1 in Appendix 3.

4. The names of the exchanges where local competition, LNP, and/or WNP will be implemented.

5. A list of all tariffs required by competitors, including:

a) a description of the service;

b) whether it is a new or an existing tariffed service;

c) a description of the required tariff changes, as applicable; and

d) he proposed effective date for the service introduction or tariff changes.

Note: proposed tariffs are to be filed with the implementation plan.

6. The following costing information:

a) Using Table 2 in Appendix 3, provide details of the cost cash flows associated with implementing local competition, LNP, and/or WNP in the company’s operating territory.  The cost cash flows are to be broken down into start-up and ongoing costs, and also expressed as present worth of annual costs (PWAC) and annual equivalent cost (AEC), using a 5-year study period.  Small ILECs with over 3,000 total NAS should also include a sensitivity that reflects a 10-year study period.

Further, provide a breakdown of the start-up and ongoing costs into major capital and expense components.  The response should also provide details on the functionality and activities associated with each of the major components, and the associated costing methodology and all assumptions ‒ including the source and vintage of data used, the cost increase factor(s), expense increase factor(s), and productivity increase factor(s) applied in the study period.

b) Further to the information required in 6. a) above, provide

i) the general cost study parameters and assumptions, such as cost of capital, cost of debt, debt equity ratio, tax rate, labour unit cost(s), and the study period used to derive the costs provided in Table 2; and

ii) details as to the schedule for the various elements of your plan.

7. A plan for cost recovery.  As noted above, residential rates may not increase by more than $4 in any one year.  This amount would include any rate increases to recover exogenous adjustments for local competition and/or WNP costs, as well as any rate increases to recover subsidy lost due to the Commission’s determinations in Telecom Regulatory Policy 2011-291.
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