ARCHIVED - Letter

Ottawa, 11 August 2011

Our references: 8663-B7-200905052
8620-B7-200905599

BY EMAIL

Ms. Faye Hughes
Regulatory Analyst
Bruce Telecom
Box 80, 3145 Highway 21 North
Tiverton, Ontario  N0G 2T0
regulatory@brucetelecom.com

RE: Bruce Telecom’s local competition and wireless number portability implementation plans

Dear Madam:

The Commission has received from Bruce Telecom  i) a local competition implementation plan in response to a request by Bragg Communications Inc., carrying on business as EastLink (EastLink); and ii)  a wireless number portability (WNP) implementation plan, in response to a request by Rogers Communications, on behalf of Rogers Wireless operating as a wireless service provider (Rogers).  Both plans were dated 22 July 2011.

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

Bruce Telecom 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 letters dated 26 July 2011 is hereby amended as follows:

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

2) Bruce Telecom 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,
Simon-Pierre Olivier, Rogers, rwi_gr@rci.rogers.com  
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 plans for local competition and wireless number portability

1) In its local competition implementation plan, Bruce Telecom 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 17 of the local competition implementation plan, and paragraph 10 of the WNP plan, where Bruce Telecom 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 Appendix 2 corresponds to additional fees that the company would have to pay as a result of implementing local competition and LNP for EastLink and/or WNP for Rogers.  If not, explain the basis for including incremental costs on the line item “Membership CLNPC.”

3) Refer to paragraph 18 of the local competition implementation plan and paragraph 12 in the WNP plan, where Bruce Telecom states that (i) significant modifications are required to migrate existing customers to a different switching platform, and (ii) the cost analysis filed in Appendix 2 is based on migrating ported numbers onto a switch that is LNP/WNP capable.

a) With reference to the cost analysis filed in Appendix 2, indicate under which line item the costs for the two above-noted activities are included.

b) Provide a breakdown, by major component, of the costs (i) to migrate the customers to a different switching platform and (ii) to make its Port Elgin switch ready for LNP/WNP.  The response should provide the methodology, assumptions, and detailed calculations used to derive these costs.

4) Refer to paragraph 19 of the WNP implementation plan, where Bruce Telecom states that Appendix 2 provides costs related to the implementation of local competition and WNP. Using the format in Appendix 2, provide two separate revised Excel spreadsheets – one is to include only the causal costs for the implementation of local competition and LNP for EastLink, and the other is to include only the causal costs for the implementation of WNP for Rogers.  Provide the methodology, assumptions, and detailed calculations to derive the costs associated with WNP.

5) With reference to the line items  “Membership Neustar” under start-up and ongoing costs in Appendix 2to the local competition and WNP plans (collectively, the plans), clarify whether

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

b) The costs included in Appendix 2 result from Bruce Telecom’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.

6) With reference to the line item  “Consulting fees” in Appendix 2 to the plans, 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.

7) With reference to the line item  “CSG (Salaries)” in Appendix 2 to the plans, 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 Bruce Telecom would maintain confidentiality of its competitor’s customer information within its organization under this type of arrangement.

8) With reference to the line items  “Software (LNP)” and “Software (LNP) – Update” in Appendix 2,

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.

9) With reference to the start-up costs in Appendix 2,

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

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

ii) Personnel training

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 of each major component, identifying the vintage of the data for each cost item.

10) With reference to the ongoing costs in Appendix 2,

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

i) Access to the LNP database

ii) SS7 transit fees

iii) Personnel training

iv) Maintenance

v) 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.

11) 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.

12) 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, or WNP.

Date modified:

2011-08-11