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Mr. Philippe Gauvin
Senior Counsel, Regulatory Law & Policy
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
Re: Outstanding Rating Issues of Tariff Notice 7372 from Bell Canada
Dear Mr. Gauvin:
Bell Canada filed Tariff Notice (TN) 7372 to propose revisions to its Access Services Tariffs, Item 110 – Co-locations Arrangements for Interconnecting Canadians Carriers and Digital Line Service Subscriber (DSLSPs) to introduce a 1000 Mbps interconnecting carrier to interconnecting carrier (IC-to-IC) cross-interconnection link.
To assist the Commission in disposing of this application, Bell Canada is required to provide responses to the attached interrogatories which are to be filed with the Commission by 14 June 2013.
All parties may file written comments to the Commission by 21 June 2013. Bell Canada may file reply comments by 28 June 2013.
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 firstname.lastname@example.org.
Each paragraph of all submissions should be numbered. In addition, the line ***End of document*** should be entered following the last paragraph. This will help the Commission.
Original signed by
Director, Competitor Services and Costing
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Bell Canada – Tariff Notice 7372
Introduction of IC-to-IC cross-interconnecting link at 1000 Mbps
1. Consistent with the format of the company’s report filed on 6 December 2012 in support of Tariff Notice 7372, provide a revised economic evaluation and propose a revised monthly charge assuming the following:
i) 10 year study period starting January 2013
ii) Negative capital increase factor (CIF) of 10% applicable to switching equipment over the study period
iii) Exchange rate of Canadian dollar at parity with US dollar (100%).
iv) Maintenance expenses at 10% of the plants in service
v) Exclude any affiliate company’s mark-up associated with third-party service provider for software development, if applicable
2. Consistent with the format of the company’s report filed on 6 December 2012 in support of Tariff Notice 7372, provide a revised economic evaluation and a revised monthly charge assuming the following:
i) 10 year study period starting January 2013
ii) Exclude all costs related to monitoring traffic
iii) Exclude any affiliate company’s mark-up associated with third-party service provider for software development, if applicable.
3. Refer to the response Bell Canada(CRTC)22Jan13-3 TN BC7372, filed on 1 February 2013, where the company provided the installed first costs (IFC) per port by major component of the switching equipment, provide a revised table that indicates the name of the manufacturer, the model / part number and the IFC for each component (e.g. main chassis, cabinet, power supply, switch fabrics, line card, software, etc.).
4. Refer to the response Bell Canada(CRTC)22Jan13-4 TN BC7372 filed on 1 February 2013, where the company provided the description and breakdown of expenses causal to demand associated with service provisioning.
a) Provide a step-by-step calculation in Excel format to explain how inward and outward service provisioning costs were calculated using the information provided in attachment to Bell Canada(CRTC)22Jan13-4 TN BC 7372.
b) Provide the on-going inward and outward cash flows for each year of the study period and the associated present worth of annual costs PWACs.
5. Refer to Telecom Decision CRTC 2012-209, dated 5 April 2012 - Bell Aliant Regional Communication, Limited Partnership and Bell Canada – Application to review and vary Telecom Decision 2011-355 pertaining to the co-location rule. In paragraph 31, the Commission decided that upon receiving a request from a co-located competitor for interconnection links to connect to another co-located competitor, an ILEC may require one or both co-located competitors to demonstrate (emphasize added) that they are adhering to the co-location rule.
Also, refer to Bell Canada’s Access Services Tariff for interconnecting with carriers and other service providers, CRTC 7516 Item 110 Co-location arrangements for interconnecting Canadians Carriers and digital Subscriber Line Service Providers (DSLSP), section 3 (a), Terms and Conditions – General. In that section it stated that, in co-locating the transmission equipment in the Company premises, the Inter-connecting Carrier (IC) shall ensure that the primary purpose of co-location is to interconnect with the Company facilities. The Company reserves the right to require the IC to demonstrate (emphasize added) that the capacity dedicated to interconnection with the Company facilities is greater that dedicated to IC-to-IC cross-connection.
a) In view of the above, explain why the approach implied for DS-1 and DS-3 IC-to-IC links cannot be implemented for IC-to-IC link at 1000 Mbps (i.e. without having to monitor the traffic between co-locators) with supporting rationale.
b) Explain with supporting rationale how currently co-locators demonstrate compliance to co-location rule in DS-1 and DS-3 IC-to-IC links environment.
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