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Ottawa, 26 July 2011

O/Ref.: 8663-C41-200813800


To: Attached Distribution List

Dear Madam or Sir:

Re: Local competition in small ILEC territories

The Commission has received local competition implementation plans from CoopTel, Téléphone Guèvremont inc., la Compagnie de téléphone de Lambton Inc., Sogetel inc., le Téléphone de St-Éphrem inc., la Compagnie de téléphone de St-Victor, Téléphone Milot Inc., and la Compagnie de téléphone Upton Inc. (collectively, the small incumbent local exchange carriers or ILECs), dated 9 June 2011, in response to requests for local competition in their territories made by TELUS Communications Company (TCC) and Cogeco Cable Inc. (Cogeco).

In a process letter dated 5 May 2011, Commission staff required the small ILECs to file any required tariffs in conjunction with filing their local competition implementation plans.  Those tariffs were not filed with the implementation plans.  The small ILECs are to provide those tariffs, with justification for their proposed rates, when they submit their responses to the attached request for information.

The small ILECs are requested to file with the Commission, by 16 August 2011, their responses to the request for information set out in the attachment to this letter.

The process set out in the Commission staff letter dated 14 June 2011 is amended as follows:

TCC and Cogeco may file comments regarding the small ILECs’ responses to the attached request for information by 23 August 2011; and

The small ILECs may file final replies by 30 August 2011.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager, Tariffs

cc: Laurie Ventura, CRTC, 819-997-4589,
Danny Moreau, CRTC, 819-953-5672,

Liste de distribution
Louise Bégin, Téléphone Milot inc.,
Louise Bégin, Sogetel inc.,
Pierre Allard, CoopTel,
Jean-François Mathieu, La Compagnie de Téléphone Upton Inc.,
Guy Cordeau, Téléphone Guèvremont inc.,
Raymonde Lapierre, La Compagnie de Téléphone de Lambton Inc.,
Michel  Couture, Téléphone de St-Éphrem inc.,
Jean  Bélanger, La Compagnie de téléphone de Saint-Victor,
Serge Désy, Association des Compagnies de Téléphone du Québec,
Roger Choquette, Consultant and Authorized Representative,>
Ted Woodhead, TCC,
Michel Messier, Cogeco,


Request for information – Implementation plan for local competition and local number portability

1) In reference to the salary and accommodation expenditures for the carrier services group (CSG) function , identify the type of resource person required to operate the CSG (for example – clerical employee, professional employee) and provide all the costs related to the employment of this resource person (such as annual salary, benefits).

(a) Is the CSG function this person’s only responsibility? If not, what other duties will the person perform in the company?

(i) Could this raise questions about the maintenance of confidentiality?

(ii) Provide the number of hours per month the person will spend on the CSG function – that is, on interconnection and subscriber transfer activities.

(b) If the Commission did not require the small ILEC to establish a special CSG function, but allowed it to incorporate this function into its day-to-day operations, indicate the impact on the costs for providing this function and on the company’s ability to maintain confidentiality.  

2) In reference to start-up and recurring consulting costs, provide the following details:

(a) Name of the consulting firm;

(b) Nature of the consulting – describe the primary activities for which the consulting firm will be responsible; and 

(c) An estimate of the number of start-up and recurring hours for each primary activity, with supporting rationale.

3) Provide the necessary details for calculating the recurring and start-up costs for access to the local number portability (LNP) database, including the company’s hypotheses, with supporting rationale. 

4) Provide a breakdown of start-up and recurring costs under the heading “Other Costs” for the implementation of local competition and LNP, with supporting rationale.

5) In reference to LNP query costs, provide the following details:

(a) Unit cost of each query; and

(b) Expected number of queries per month, with supporting rationale.

6) Provide a list of all tariffed services required to implement local competition and LNP for the competitor, along with the following information:

(a) A description of the service;

(b) Whether it is a new or existing tariffed service;

(c) A description of the required tariff revisions, if any; and

(d) The proposed service implementation date.

7) Make reference to the initial implementation plan for local competition and LNP submitted by the company on 5 November 2008, and the revised plan submitted on 9 June 2011. Make a comparison of the start-up and recurring costs provided in these plans for each item, and provide a justification for all differences of more than 5%, with supporting rationale; show all the changes in your hypotheses. 

8) Start from the hypothesis that the Commission will allow the company to de-average its local home and business tariffs. Discuss the impact this could have on the company’s plan for the recovery of local competition and LNP costs.

9) Provide a detailed description of the methodology used by the company to develop its market share loss projections (for example, trends and totals after five years) for both its residential and business subscribers, in the areas of its territory that are covered by an application for local competition and LNP.  Provide all studies and relevant data, with supporting rationale; outline your hypotheses.

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