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Ottawa, 1 November 2012

Our Files: 8740-B20-201208307


Mr. Denis Henry
Vice-President - Regulatory
Government Affairs and Public Law
Bell Aliant Regional Communications, L.P.
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4

Mr. Philippe Gauvin
Senior Counsel
Regulatory Law and Policy
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario 2P 2C4

Mr. Michel Gilbert
Director – Regulatory Affairs
Télébec, Société en commandite
87 rue Ontario Ouest, 5ème étage
Montréal, Québec H2X 1Y8

Dear Sirs:

RE: Bell Canada Tariff Notice 926 and Télébec, Société en commandite Tariff Notices 452 and 452A

On 11 July 2012, Bell Aliant Regional Communications, Limited Partnership (Bell Aliant); Bell Canada; and Télébec, Société en commandite (Télébec) (collectively, the Bell companies) filed Bell Canada Tariff Notice (TN) 926 and Télébec TN 452. On 27 September 2012, the Bell companies filed Télébec TN 452A.

On 10 August 2012, Bragg Communications Inc., carrying on business as EastLink; Cogeco Cable Inc.; Rogers Communications Partnership; Shaw Communications Inc.; and Quebecor Media Inc. on behalf of its affiliate Videotron G.P. (collectively, the Cable carriers); and MTS Inc. and Allstream Inc. (collectively, MTS Allstream) filed comments.

Commission staff has reviewed the information on the record and determined that additional information is required to properly assess the applications. Accordingly, the Bell companies are requested to provide by 22 November 2012, responses to the questions set out in the Attachment, serving copies on all parties.

Other parties may file comments on the responses filed by the Bell companies’ responses by 6 December 2012, serving copies on all parties. The Bell companies may file reply comments by 17 December 2012, serving copies on all parties.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Yours sincerely,

Original signed by

Mario Bertrand
Director Dispute Resolution & Decisions

c.c.: EastLink :
Cogeco Cable Inc. :
Quebecor Media Inc. :
Rogers Communications Partnership :
Shaw Communications Inc. :
MTS Allstream :


  1. Provide a copy of the contract with the third party contractor that conducted the census in Bell Aliant’s operating territory in Atlantic Canada.
  2. Confirm that the third party contractor is at arm’s length from the Bell companies.
  3. With respect to future censuses in all the remaining regions of the Bell companies operating territories, are the Bell companies considering notifying the Licensees of the intention to conduct a pole audit and to provide Licensees with an opportunity to participate in the census?
  4. In paragraph 9 of the 11 July 2012 application, the Bell companies state “the count attributes included, but were not limited to, location, height, distance between poles, pole type as well as presence of third party attachers”.
    1. Provide a complete list of all attributes accounted for in the census,
    2. Explain how each of these attributes was required to establish the number of the Bell companies’ service poles with attachments for billing purposes, and
    3. If only a portion of the attributes were used to establish the number of service poles, explain why the total amount of third party costs for all attributes are included in the calculation of the one-time service charge for the census of the service poles
  5. Confirm that the census was conducted only with respect to types of poles (e.g., main poles, anchor poles, end poles and overhead guy poles) and not any other support structure. If not, clarify with details all the structures on which the census was conducted.
  6. Describe the method of the census used to distinguish service poles from other poles such as main poles, anchor poles, end poles and overhead guy poles.
  7. Provide a description of how ownership of each of the service poles was established e.g., whether owned by the Bell companies, hydro utility / cable company, or a retail customer.
  8. Indicate whether any service poles not owned by the Bell companies e.g. whether jointly owned, owned by hydro utility / cable company, or a retail customer, were included in the formula to determine the one-time service charge per Licensee.
  9. Provide the assumptions, if any, that were made to determine the one-time service charge per Licensee.
  10. Provide a description of how the Licensee associated with each drop wire attachment was identified.
  11. With reference to the formula in paragraph 7 of the 11 July 2012 application, confirm that the total sum of all Licensees' service pole counts in the denominator is the sum of all attachers including the Bell companies as noted in paragraph 10 of the 11 July 2012 application.
  12. With reference to the hypothetical example in paragraph 8 of the 11 July 2012 application, confirm whether the “service poles the licensees are attached to”, i.e., 5000, would reflect a count of two for the same pole, if two licensees were attached to that pole.
  13. In paragraph 5 of its 10 August 2012 comments, MTS Allstream states “Bell et al’s census is not causal to attachers that have identified their use of service poles and are paying the tariffed rate for those poles. Therefore, they should not be responsible for covering Bell et al’s costs of conducting those censuses.” Explain why attachments identified by Licensees prior to the performance of the census should bear the cost of the census.
  14. In paragraph 48 of the Cable carriers 10 August 2012 comments, the Cable carriers referred to the proportionate allocation method applied by the Commission in Review of the large incumbent local exchange carriers’ support structure service rates, Telecom Decision CRTC 2010-900, 2 December 2010, as amended by Telecom Decision 2010-900-1, and set out a table illustrating the impact of the proportionate allocation method in determining the Licensees share of the audit costs. Provide the Bell companies’ views on the Cable carriers’ allocation method.
  15. In paragraph 11 of the 11 July 2012 application, the Bell companies state “Licensees will be provided with the location of the service poles to which they have been found to be attached in order to verify, should they choose to do so, the validity of the charges.” If Licensees submit requests for the location of service poles, what information will be provided to the Licensees? Provide an example. In what time frame will the information be provided to the Licensees?
  16. Provide the definition of service poles the Bell companies used with respect to: (a) the census, (b) the invoices that were issued to the Licensees after the census and (c) the proposed tariffs revisions for the above-noted tariff notices.
  17. For each of the Atlantic Provinces, provide a summary of the census, showing for each province the census cost; and separately the number of main poles, anchor poles, end poles, overhead guy poles and service poles, i.e., poles on which the only Licensee attachment is a subscriber drop wire, and any other structure that was part of the census. Further, by province provide separately the total number of service poles on which Licensees have attached subscriber drop wires and on which the Bell companies have attachments.
  18. Explain in detail how the census conducted in the Newfoundland differed from the census conducted in the other three Atlantic Provinces.
  19. In paragraph 13 of the 11 July 2012 application, the Bell companies stated that they proposed to include in their tariffs a list of areas where a census has been conducted and the cost of the census per service pole. Paragraph 13 also contains the wording “(unless the Companies’ have negotiated a specific rate for a specific area with a Licensee in which case the negotiated rate will apply)”. Confirm whether the wording in the parenthesis in paragraph 13 refers to the negotiated agreements set out in Bell Canada Item 901.4(o) and Télébec Tariff Général Chapitre 10.3.4(15). If not, clarify.
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