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Ottawa, 16 February 2012

Our Ref.:  8662-M59-201104398


Mr. Phillippe Gauvin
Counsel – Regulatory Law & Policy
Bell Canada
160 Elgin Street, Floor 19
Ottawa, Ontario
K2P 2C4

Re:  Interrogatories regarding review and vary application of Telecom Decision CRTC 2011-24Bell Aliant Regional Communications, Limited Partnership and Bell Canada – Monthly recurring rates and service charge rates for unbundled loops in Ontario and Quebec

Dear Mr. Gauvin:

Commission staff request that Bell Aliant Regional Communications, Limited Partnership and Bell Canada (the Bell companies) respond to the attached interrogatories by 23 February 2012.

Commission staff considers that the information to be provided in response to the interrogatories is vital to the assessment of the appropriate revised unbundled loop rates that are the subject of these review and vary applications.

Comments on the Bell companies’ responses to these questions and to the responses to questions filed on 13 February 2012 may be made by 28 February 2012 and the Bell companies may file reply comments by 2 March 2012.

Consistent with the guidelines set out in Broadcasting and Telecom Information Bulletin CRTC 2010-959, copies of comments and interrogatory responses are to be served on parties to the proceeding that led to Telecom Decision 2011-24.

Yours truly,

Original signed by :

Yvan Davidson
Director, Competitor Service and Costing
Telecommunications Directorate



Further interrogatories for the Bell companies on the unbundled loop review and vary applications

1.  a)  In TheCompanies(CRTC)30Sep11-1 D2011-24, the Bell companies provided the cost of removal (COR) factors used in their review and vary application and the updated factors presently used by the companies.  Provide the numerators (i.e., removal expenses) and denominators (i.e., retired Plant in Service) used to calculate these COR factors and indicate the years from which this information was extracted.  Further provide an estimate of the percentage of copper cable removal jobs that were included.

b)  In Attachment 1 to TheCompanies(CRTC)17May11-5 D2011-24, the Bell companies provided monthly equivalent costs (MECs) for removal costs calculated by applying COR factors to copper NBV estimates, copper IFCs and year-end 2008 copper cable PIS estimates.

i)  For each of the removal MECs that are obtained by applying the COR factors to (1) copper IFCs and (2) year-end 2008 copper cable PIS,  provide the calculations used to derive the MECs, identifying any expense or capital increase factors used, with supporting rationale;

ii)  Confirm that the removal MECs estimated based on year-end 2008 copper cable PIS estimates were derived from the application of the COR factors to total year-end PIS (i.e., retired and non-retired PIS) rather than only to retired PIS.  If so, provide revised MECs for removals calculated by applying COR factors to year-end 2008 copper cable PIS estimates for only the retired PIS, identifying the retired PIS values used, with supporting rationale.

2.  In the response to TheCompanies(CRTC)19 Jan12-4 D2011-24, the Bell companies indicated that the individual copper-related maintenance and repair (M&R) factors used in the unbundled loop study were documented in Appendix V, Table 2 of the Companies’ regulatory economic studies manual dated 31 March 2009.  The Bell Companies further provided the aggregate M&R factors by copper cable asset class in Table 1 of this response.

a)  For each of the following individual M&R cost factors identified in Appendix V - Table 2, explain why the associated activities are causal to the maintenance of the unbundled local loop:

i.  Network Management – Switch

ii.  Network Management – Transport

iii.  Network Management – BB/IP

iv.  Network Management – Other – Voice & SNA

v.  Network Management – Specific Customer Networks – IP

vi.  Provisioning – Switch

vii.  Provisioning – Transport

viii.  Provisioning – BB/IP

ix.  Provisioning - Other

x.  Operator Services  Planning

b)  Using the format of Table 1 to TheCompanies(CRTC)19Jan12 -4 D2011-24, provide revised aggregate M&R factors by asset class that exclude the individual M&R cost factors identified in response to part a) above that are not causal to the unbundled loop service.  Further, using the format of Attachment 1 to TheCompanies(CRTC)17May11-5 D2011-24, provide revised maintenance MECs per band for each of Bell Canada and Bell Aliant using the revised aggregate M&R factors.


Distribution:  Parties to Telecom Decision 2011-24
NRTC Communications c/o;

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