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Ottawa, May 14, 2013

Our references: 8740-T66-201306712 - 8740-B2-201306027 - 8740-B54-201306019 - 8740-A53-201305988 - 8661-C12-201303487

BY EMAIL

To: Interested Parties to Telecom Notice of Consultation 2013-80

RE: Telecom Notice of Consultation CRTC 2013-80 - Review of outstanding wholesale high-speed access service issues related to interface rates, optional upstream speed rates, and modem certification requirements rate – Interface - Interrogatories and comments

Dear Madam, Sir:

The Commission requires more information to complete its assessment of the costs that were submitted in support of the proposed interface rates by Bell Canada, Bell Aliant Regional Communications, Limited Parternerhip (collectively the Bell companies) and Telus Communications Company (TCC). The Commission staff is therefore submitting interrogatories.

Responses to the interrogatories are to be filed with the Commission and served on all interested parties by 28 May 2013.

All parties may file additional written comments with the Commission solely in relation to the responses to the interrogatories serving copies on all other parties, by 4 June 2013. Reply comments from the Bell companies and TCC may be filed by 11 June 2013.

In Confidentiality of information used to establish wholesale service rates - Telecom Regulatory Policy CRTC 2012-592 (TRP 2012-592), dated 26 October 2012, the Commission established disclosure guidelines for cost information filed in support of wholesale services. Therefore, the companies are to also disclose, on the public record, all time estimates for activities identified in the interrogatory responses.


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. Copies of the documents should also be sent to marc.pilon@crtc.gc.ca.

Commission staff notes that on 7 May 2013, it also received a request from Primus to establish a further procedure in the form of an interrogatory round that would allow parties to pose interrogatories to Bell companies and TCC, associated deficiency and disclosure requests, and subsequent comment filings and reply comment filings. Also, the Canadian Network Operators Consortium Inc. (CNOC) in a letter dated 2 May 2013, requested that some new information be provided on the public record.

Commission staff is of the view that it addresses the issues raised by both Primus and CNOC in the attached interrogatories. Therefore Commission staff does not believe that further process other than the one defined above is necessary at this time.

Yours sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications Directorate

Interested Parties to Telecom Notice of Consultation 2013-80

michelle.dupuis@telus.com; regaffairs@quebecor.com; document.control@sasktel.com; david.watt@rci.rogers.com; Regulatory@sjrb.ca; Bianca.Sgambetterra@Cogeco.com; suzanne.giroux@mtsallstream.com; beverley.wells@bell.ca;ocrosby@scs.carleton.ca; GreyBeatle111@hotmail.com; regulatory@cnoc.ca; document.control@sasktel.com; bell.regulatory@bell.ca; Regulatory@sjrb.ca; resa1983@hotmail.com; brian.riquelme@hotmail.com; iworkstation@allstream.com; regulatory@primustel.ca; ted.woodhead@telus.com; jfmezei@vaxination.ca

c. c.: Marc Pilon, CRTC (819)997-4535, marc.pilon@crtc.gc.ca

Attach. (2)

Attachment 1

Interface – Interrogatories

Bell Canada and Bell Aliant operating in Ontario and Quebec - TN BA440-BC7386

1. Provide the detailed IP AHSSPI service configuration diagrams, identifying the resources type of equipment for each of the possible scenarios:
a. Scenario 1a: Digital Subscriber Line Service Provider (DSLSP) is served by an AHSSPI port that is on an IP Edge Switch in the serving central Office
b. Scenario 1b: DSLSP is served by an AHSSPI port that is on an Ethernet Switch in the same central office as the IP Edge Router
c. Scenario 2: The DSLSP is served by an AHSSPI port on an Ethernet Switch in a central Office that is not equipped with an IP Edge Router and requires multiple Ethernet Switches (Metro Ethernet) to carry traffic from the DSLSP’s Ethernet Switch to the edge of the IP Core.

2. Refer to Expenses Causal to Demand - Maintenance expenses: For each of the IP AHSSPI 100 Mbps and 1000 Mbps services:
a. Provide a breakdown of maintenance into the following sub-activities: Help desk, ongoing maintenance and repair activities. For each, provide the specific corporate average maintenance and repair factors that were used to estimate the above and associated monthly cost and cost driver value (such as plant in service).
b. For the costs associated with providing support to DSLSPs, provide a description of the sub-activities, the associated labour unit costs, time estimates in no more than 15 minute increments, occurrence rates and associated monthly costs.
c. Provide the sources of data for time estimates and occurrence rates.

3. Refer to Expenses Causal to Demand - Service Provisioning:
a. Provide a breakdown of Service Provisioning into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates, and occurrence rates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.

4. Refer to Expenses Causal to Demand - Advertising & Sales Management, Billing:
a. Provide a breakdown of Advertising Sales Management into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates with supporting rationale.
b. Provide a breakdown of billing costs sub-activities into increments of no more than 15 minutes including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates with supporting rationale.
c. Provide the sources of data for time estimates and occurrence rates.

5. Refer to Capital Causal to Demand - Switching equipment
a. Complete the table in Attachment 2 by configuration (i.e. Scenario 1a. AHSSPI on IP Edge Router, Scenario 1b. AHSSPI on Ethernet Switch at central office with IP Edge router, Scenario 2. central office is not equipped with an IP Edge Router) for all major equipment components (including the IP Edge Router, Ethernet switching equipment and other)
b. Further indicate whether retrospective pifs and cifs were applied to restate the costs provided in response to a) above from the respective vintage year to the year 2013 with supporting rationale. If yes, provide the pifs and cifs. If not, explain why not.

6. Refer to Capital Causal to Demand - Outside Plant
a. Provide the corporate average unit cost of the fibre, the average fibre length with sources of data, vintage and calculations to estimate the total costs of Outside Plant with supporting rationale.

7. Refer to Capital Causal to Demand – Switching – Ethernet
a. Provide the calculations for estimating the Metro Ethernet Switching costs when the DSLSP is not served by a Bell central Office with an IP Edge router, with supporting rationale and data.
b. Indicate the number of switches in the Metro Network assumed, to carry the traffic from the DSLSP’s Ethernet Switch to the edge of the IP Core, in the calculation of the costs with supporting rationale and data.

8. Telecom Notice 2013-80 directed the Bell companies and TCC to provide a revised cost study using a 10 year study period using the pricing rules in effect for the interface services of MTS Inc. and Sasktel as set out in TRP 2011-703, mainly using a 10 year study period, and applying annual capital unit cost changes of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment over the study period. Indicate if the above annual unit cost changes were applied in the 10 year study that was submitted on 12 April 2013 in support of the IP AHSSPI service. If not provide a revised study using the above annual capital unit cost changes.

9. In reference to the two AHSSPI configurations shown in the diagram of the 29 April 2013 Bell companies’ reply comments;
a. Provide the number and proportion of the AHSSPI interfaces by speed at central offices equipped with an IP Edge Router (i.e. Scenarios 1a and 1b). Provide the current percentage, actual and forecasts of the number of central offices with and without IP Edge routers over the study period. Indicate whether the company plans to add more IP Edge routers to currently un-served central offices and whether this was taken into account in estimating the proportion of the IP AHSSPI interfaces that are not served by IP Edge Routers in calculating the final costs.
b. Identify the central offices that are equipped with IP Edge Routers.
c. Indicate if the DSLSPs have the choice of selecting the central offices for their AHSSPI and if the DSLSPs are made aware that their AHSSPI is connected to a central office with or without an IP edge router.
d. Indicate whether the companies plan to migrate all DSLSPs from the legacy AHSSPI service to the IP AHSSPI service over the study period. If yes provide a forecast.
e. Provide revised Tables 3, 5a, 5b and 5c, for each of the scenarios 1a, 1b and 2, using a 10 year study period and applying annual capital unit cost changes of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment over the study period.
f. Provide the number and percentage of DSLSPs and end-users for each of Scenarios 1a, 1b and 2.

10. Refer to your demand forecast estimates for IP AHSSPI.
a. Explain with supporting rationale how the forecasts of the number of IP AHSSPIs were derived. The answer should provide data and assumptions and should explain how the impacts of end-user growth, per end-user usage growth and other factors were incorporated

11. Refer to the IP AHSSPI Service Charge – Expenses causal to demand - Service Provisioning
a. Provide a breakdown of Service Provisioning into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates.

12. Refer to the expenses causal to service: For each of the on-going product management and one-time billing costs for implementing the rate change:
a. Provide a detailed breakdown of the sub-activities in increments of no more than 15 minutes including a description, monthly costs, labour unit costs, associated time estimates and occurrence rates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.


Bell Aliant Atlantic Region TNN AA449

1. Provide the detailed IP AHSSPI service configuration diagrams, identifying the resources by type of equipment for each of the possible scenarios:
a. Scenario 1a: DSLSP is served by an AHSSPI port that is on a tunnel switch.
b. Scenario 1b. DSLSP is served by an AHSSPI port that is on an Ethernet Switch in the service central office equipped with a tunnel switch.
c. Scenario 2. DSLSP is served by an AHSSPI port at a central office that is not equipped with a tunnel switch.

2. Refer to Expenses Causal to Demand - Service Provisioning Expenses:
a. Provide a breakdown of Service Provisioning into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.

3. Refer to Expenses Causal to Demand - Advertising & Sales Management, Billing:
a. Provide a breakdown of Advertising Sales Management into sub-activities of no more than 15 minute increments including a description of the sub-activity, labour unit costs and associated time estimates and occurrence rates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.

4. Refer to Expenses Causal to Demand - Other Expenses :
a. Provide a breakdown of Service Assurance, into increments of no more than 15 minutes including a description of each sub-activity, monthly costs, labour unit costs and associated time estimates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.

5. Refer to Capital Causal to Demand - Transmission equipment
a. Complete the table in Attachment 2 by configuration (i.e. Scenario 1a. AHSSPI at central Office with tunnel switch, Scenario 1b. AHSSPI at central Office with tunnel switch on Ethernet Switch, Scenario 2. Central office is not equipped with tunnel switch), for all major equipment such as the SONET transmission equipment, Ethernet switch equipment and other types of equipment.
b. Further indicate whether retrospective pifs and cifs were applied to restate the costs provided in response to a) above from the respective vintage year to the year 2013 with supporting rationale. If yes, provide the pifs and cifs,. If not, explain why not.

6. Refer to the Expenses Causal to Demand – Service Provisioning for the Service Charge:
a. Provide a breakdown of Service Provisioning into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates.
b. Provide sources of data for time estimates and occurrence rates.

7. Telecom Notice 2013-80 directed the Bell companies and TCC to provide a revised cost study using a 10 year study period using the pricing rules in effect for the interface services of MTS Inc. and Sasktel as set out in TRP 2011-703, mainly using a 10 year study period, and applying annual capital unit cost changes of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment over the study period. Indicate if the above annual unit cost changes were applied in the 10 year study that was submitted on 12 April 2013 in support of the NNI service. If not provide a revised study using the above annual capital unit cost changes.

8. In reference to the two AHSSPI configurations shown in the diagram of the 29 April 2013 Bell companies’ reply comments;
a. Provide the number and proportion of the AHSSPI interfaces that will be served by a central Office with a tunnel switch (Scenarios 1a and 1b).
b. Provide the current percentage, actual and forecasts of the number of central offices with and without a tunnel switch over the study period. Indicate whether the company plans to add more tunnel switches to currently un-served central offices and if this was taken into account in estimating the proportion of the AHSSPI interfaces that are not served by tunnel switches in calculating the final costs.
c. Identify the central offices that are equipped with tunnel switches.
d. Indicate if the DSLSPs have the choice of selecting the central office for their AHSSPI and if the DSLSPs are made aware that their AHSSPI is connected to a central office with or without a tunnel switch.
e. Indicate whether the company plans to migrate all DSLSPs from the legacy AHSSPI service to the AHSSPI service over the study period. If yes provide a forecast.
f. Provide revised Tables 3, 5a, 5b and 5c, for each of the scenarios 1a, 1b and using a 10 year study period and annual unit capital cost changes of minus 5 percent for access-driven components and minus 10 percent for transport-driven components.
g. Provide the percentage and number of DSLSPs and end-users for each of the Scenarios 1a, 1b and 2.

9. Refer to the expenses causal to service: For each of the Billing and Other Expenses costs for implementing the rate change:
a. Provide a detailed breakdown of the sub-activities in increments of no more than 15 minutes including a description, monthly costs, labour unit costs, associated time estimates and occurrence rates with supporting rationale.
b. Provide the sources of data for time estimates and occurrence rates.

10. Refer to your demand forecasts for the ADSL AHSSPI ports:
a. Explain with supporting rationale how the forecast of the number of AHSSPIs were derived. The answer should provide data and assumptions and should explain how the impacts of end-user growth, per end-user usage growth and other factors were incorporated.


Telus Communications Company (TCC)

1. For each of the ADSL Internet NNI 100 Mbps and 1000 Mbps services:
a. Provide the schematic diagrams showing for each service configuration, identifying the resources by type of equipment required to provide the service with a description of each.

2. Provide a revised cost study using a 10 year study period using the pricing rules in effect for the interface services of MTS Inc. and Sasktel as set out in TRP 2011-703, mainly using a 10 year study period, and applying annual capital unit cost changes of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment over the study period. Indicate if the above annual unit cost changes were applied in the 5 year study that was submitted on 12 April 2013 in support of the NNI service.

3. Refer to Expenses Causal to Demand - Maintenance:
a. Identify and provide a description of each major sub-activity.
b. For each major sub-activity identified in a. above, where costs are developed on explicit time estimates, provide the time estimates in increments of no more than 15 minutes, occurrence rates (percent of time activity is required), and labour unit costs used to estimate the cost associate with the sub-activity along with supporting assumptions, sources and vintage of data.
c. For each major sub-activity identified in a. above where costs are developed based on unit costs/factors, provide a detailed description of the methodology used by the company to develop the unit costs or factors along with supporting assumptions, data values used in the calculations, sources and vintage of the data. The response should include how the unit costs/factors are used to estimate the maintenance expenses associated with each major sub-activity.

4. Refer to Capital Causal to Demand -Switching equipment
a. Complete the table in Attachment 2 for each NNI service configuration for all major equipment components such as the NNI and Ethernet switching equipment or other.
b. Further indicate whether retrospective pifs and cifs were applied to restate the costs provided in response to a) above from the respective vintage year to the year 2013 with supporting rationale. If yes, provide the pifs and cifs. If not, explain why not.

5. Refer to Capital Causal to Demand - Transmission equipment
a. Complete the table in Attachment 2 for each NNI service configuration for all major equipment components such as the NNI and Ethernet switching equipment or other.
b. Further indicate whether retrospective pifs and cifs were applied to restate the costs provided in response to a) above from the respective vintage year to the year 2013 with supporting rationale. If yes, provide the pifs and cifs. If not, explain why not.

6. Refer to your demand forecast estimates for the NNI.
a. Explain with supporting how the forecast of the number of NNIs were derived. The answer should provide data and assumptions and should explain how the impacts of end-user growth, per end-user usage growth and other factors were incorporated.

7. Refer to the Expenses Causal to Demand - Service Charge:
a. Provide a breakdown of Service Provisioning into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates.
b. Provide a breakdown of Advertising & Sales Management into sub-activities of no more than 15 minute increments including a description of the sub-activity, monthly costs, labour unit costs, associated time estimates and occurrence rates.
c. Provide the sources of data for time estimates and occurrence rates.

8. In Tariff Notice 457, TCC proposed new Interface rates under Tariff CRTC 21462 Item 226.3 b. Existing customers are currently charged under Tariff CRTC 21462 Item 217.3 with capacities of an OC-3, OC-12, 100 Mbps and 1000 Mbps.
a. Does TCC plan to migrate all of its customers to Tariff Item 226.3 b.?

9. Refer to paragraph 9 and the associated diagram and table, of the 29 April 2013 Bell companies’ reply comments where the Bell companies identified different service configurations for their AHSSPIs. Indicate whether TCC utilizes more than one service configuration. If so,
a. Provide the number and proportion of the NNIs that will be served by each service configuration for each service configuration. Indicate whether the company plans to change the configuration of its central offices and if this was taken into account in calculating the final costs for the NNI service.
b. Identify the TCC central offices that are equipped with each service configuration.
c. Indicate if the DSLSPs have the choice of selecting the TCC central offices for their NNI and if the DSLSPs are made aware of the type of NNI service configuration.
d. Provide revised Tables 1, 2, 3 and 5 for a 10 year study with annual cost changes of -5% for the access portion and -10% for the usage-driven component for each of the NNI service configurations.

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