ARCHIVED - Letter

Ottawa, 11 August 2011

Our reference: 8663-W36-200910225

BY EMAIL

Mr. Tom Sullivan
Vice President & General Manager
Wightman Telecom Ltd.
100 Elora Street N., Box 70
Clifford, Ontario  N0G 1M0
tsullivan@wightman.ca

RE: Wightman’s local competition implementation plan for EastLink

Dear Sir:

The Commission has received a local competition implementation plan from Wightman Telecom Ltd. (Wightman), dated 25 July 2011, in response to a request by Bragg Communications Inc., carrying on business as EastLink (EastLink).

In a process letter dated 5 May 2011, Commission staff required Wightman to file any required tariffs in conjunction with filing its local competition implementation plan.  Those tariff notices were not filed with the company’s implementation plan.  Wightman is to file those tariff notices, with justification for the proposed rates, when it submits its responses to the attached request for information.

Wightman is requested to file with the Commission, by 1 September 2011, its responses to the request for information set out in the attachment to this letter.

The comment process set out in Commission staff’s letter dated 29 July 2011 is hereby amended as follows:

1) EastLink and any interested person may file an intervention, serving that intervention on Wightman, by 8 September 2011; and

2) Wightman may file a reply by 15 September 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
Telecommunications

cc: Nathalie MacDonald, EastLink,
Laurie Ventura, CRTC, 819-997-4589, laurie.ventura@crtc.gc.ca
Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca

Request for information – Implementation plan for local competition

1) In its local competition implementation plan (the plan), Wightman proposes to file tariffs related to local network interconnection (LNI) based on EastLink’s LNI requirements.

a) Provide a list of all specific tariffed services requested/required to implement LNI for EastLink, along with the following information: 

i) A description of each service;

ii) whether it is a new or existing tariffed service;

iii) a description of the required tariff revisions, if any; and

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

b) Further to the list provided in a) above, include all other tariffed services required to implement local competition and LNP for the competitor, such as services related to Access to 9-1-1, Inside wiring, Transiting, and Common Channel Signalling #7.

2) Refer to page 2 of the plan, where Wightman indicates that in exchanges subject to EastLink’s request for local competition, the company would migrate its customers to a new Meta Switch platform.  Provide, for each of these exchanges, a timeline detailing the major tasks and activities that the company would need to perform for the proposed migration.

3) Refer to page 2 of the plan, where Wightman indicates that, for costing purposes, it has used a very conservative upgrade cost rather than the cost the company would incur in migrating its customers to the new Meta Switch platform.  Explain how Wightman estimated the upgrade cost, providing the methodology, assumptions, and detailed calculations used to derive this cost.

4) With reference to the line item “Membership Neustar” under ongoing expenses in Attachment 1 to the plan, clarify whether

a) “Membership Neustar” means that Wightman is a shareholder in the Canadian Local Number Portability Consortium (CLNPC); and

b) the costs included in the Attachment 1 result from Wightman’s agreement with the CLNPC.  Further, indicate if these are additional costs that are paid over and above any membership costs associated with the CLNPC.

5) With reference to the line item  “CSG (Salaries)” in Attachment 1  to the plan, provide the following details:

a) Identify the type of personnel required to operate the CSG (for example – clerical employee, professional employee); and

b) indicate if the CSG function would be performed by a dedicated employee or employees.

i) If so, provide the number of dedicated employee(s), by type of personnel.

ii) If not, identify the number of personnel, by type, who would be assigned to CSG activities, and indicate the percentage of time each person would be assigned to CSG activities during their work week.  Further, explain how Wightman would maintain confidentiality of its competitor’s customer information within its organization under this type of arrangement.

6) With reference to the line item “Equipment and Installation (P.O.I.)” in Attachment 1, provide the following details:

a) Confirm if the start-up costs included under this line are associated with the fibre interconnection facilities referenced in page 2 of the plan under “Exchanges and local network interconnection regions (LIR),” and page 5 of the plan under “Interconnection trunks and services.”

i) If so, provide a breakdown of the costs related to this item by “fibre,” “electronics,” and “installation,” providing all the detailed calculations and assumptions used to estimate each of these components.

ii) If not, explain what these costs represent and provide a breakdown of costs by “equipment” and “installation,” including the detailed calculations and assumptions used to estimate these costs.

b) If the company confirms in its response to a) that start-up costs included under this item are associated with the fibre interconnection facilities, provide revised costs for this item, assuming that copper interconnection is used.  The response should provide a breakdown of copper interconnection costs by “copper facility,” “installation,” and “other” (if applicable), including the methodology, assumptions, and detailed calculations used to estimate these costs.  Further, provide a revised Table 2, assuming that copper interconnection is provided.

7) With reference to the line item “Equipment (CSG)” in Attachment 1, provide the following details:

a) Describe what additional equipment would be required to perform the CSG function associated with EastLink’s request.

b) Provide a breakdown, by major component, of the costs associated with this item.  The response should provide the methodology, assumptions, and detailed calculations used to estimate each of the components, identifying the vintage of the data for each cost item.

8) With reference to the start-up costs in Attachment 1,

a) Describe the functionality and activities associated with each of the following:

i) Personnel Training

ii) Modifications to internal systems

b) Provide a breakdown, by major component, of the costs for the items identified in (a) above.  The response should provide the methodology, assumptions, and detailed calculations used to derive the costs for each major component, identifying the vintage of the data for each cost item.

9) With reference to the ongoing costs in Attachment 1,

a) Describe the functionality and activities associated with each of the following:

i) CSG (accommodation)

ii) Maintenance

b) Provide a breakdown, by major component, of the costs for the items identified in (a) above.  The response should provide the methodology, assumptions, and detailed calculations used to derive the costs for each major component, identifying the vintage of the data for each cost item.

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

11) Provide a detailed description of the methodology, assumptions, and relevant supporting data the company used to develop its market share loss projections for both its residential and business subscribers, in the areas of its territory that are covered by an application for local competition and LNP.

Date modified:

2011-08-11