ARCHIVED - Letter

Ottawa, 11 August 2011

Our reference: 8663-H3-200917503

BY EMAIL

Ms. Angela M. Schneider
General Manager
Hay Communications Co-Operative Limited
P.O. Box 99, 72863 Blind Line
Zurich, Ontario  N0M 2T0
a.schneider@hay.net

RE: Hay Communications’ local competition implementation plan for EastLink

Dear Madam:

The Commission has received a local competition implementation plan from from
Hay Communications Co-operative Limited (Hay), dated 22 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 Hay to file any required tariffs in conjunction with filing its local competition implementation plans.  Those tariff notices were not filed with the company’s implementation plan.  Hay is to file those tariff notices, with justification for the proposed rates, when it submits its responses to the attached request for information.

Hay 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 26 July 2011 is hereby amended as follows:

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

2) Hay 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
Martin Brazeau, CRTC, 819-997-3498, martin.brazeau@crtc.gc.ca

Request for information – Implementation plan for local competition

1) In its local competition implementation plan (the plan), Hay 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 paragraph 11 of the plan, where Hay states that it needs to activate the LNP software feature on its switch.  List the activities associated with activating the LNP software feature.

3) Refer to paragraph 13 of the plan, where Hay states that it is currently a member of the Canadian Local Number Portability Consortium (CLNPC).  Indicate if the company currently pays membership fees to the CLNPC.  Further, explain, with supporting rationale, if the line item “Membership CLNPC” in Attachment 1 corresponds to additional fees that the company would have to pay as a result of implementing local competition and LNP for EastLink.  If not, explain the basis for including incremental cost on the line item “Membership CLNPC.”

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

a) “Membership Neustar” means that Hay is a shareholder in the CLNPC; and

b) the costs included in the Attachment 1 result from Hay’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  “Consulting fees” in Attachment 1 to the plan, for each of (i) start-up costs and (ii) ongoing costs, provide the following details:

a) The name of the consulting firm;

b) a  description of the primary activities for which the consulting firm will be responsible; and

c) an estimate of the hours per week (start-up and recurring, as applicable) associated with each primary activity, with supporting rationale.

6) 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 Hay would maintain confidentiality of its competitor’s customer information within its organization under this type of arrangement.

7) With reference to the line items  “Software (LNP)” and “Software (LNP) – Update” in Attachment 1,

a) Explain what “Software (LNP) – Update” means and provide the major components associated with this line item; and

b) for each of “Software (LNP)” and “Software (LNP) – Update,” provide a cost breakdown by major resource component.  The response should provide the methodology, assumptions, and detailed calculations used to estimate the cost for each major component.

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

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

i) Equipment and installation (P.O.I)

ii) Access to the LNP database

iii) Personnel training

iv) Modifications to internal systems

b) Provide a breakdown, by major component, of the costs for each of 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) Equipment (P.O.I.)

ii) SS7 transit fees

iii) Personnel training

iv) Other expenses

b) Provide a breakdown, by major component, of the costs for each of 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.

Date modified:

2011-08-11