ARCHIVED -  Letter

Ottawa, 27 June 2013

Our reference: 8740-T66-201212216

BY EMAIL

Mr. Ted Woodhead
Vice President, Telecom Policy & Regulatory Affairs
TELUS Communications Company
regulatory.affairs@telus.com

Re: TN 445 – Wholesale Internet ADSL Service – 50 Mbps Residential Service

Dear Mr. Woodhead:

In order to determine the final rates for this service the Commission requires more information.

TCC is to file its responses to the attached interrogatories with the Commission, serving a copy on all other parties, by 11 July 2013. These responses are to be received, and not merely sent, by this date.

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.

Yours sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications

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

Attachments (3): Distribution List, Interrogatories, Tables 1 and 2

Distribution List:

pkgdonovan2@gmail.com; regulatory@vianet.ca; lefebvre@rogers.com; constantly@rogers.com; lainwired@gmail.com; jim-johnston@cogeco.ca; tracy.cant@ontera.ca; linda_maljan@gov.nt.ca; kevanst.john@gmail.com; Regulatory@sjrb.ca; tom.copeland@caip.ca ; Lisajackson@globalive.com; vince.valentini@tdsecurities.com; crtcubb@douville.org; douglas216@shaw.ca; cataylor@cyberus.ca; jkolyn@ikano.com; angusoliver320@gmail.com; bcampbell@skywaywest.com; martina.emard@lethbridgecollege.ca; babramson@mccarthy.ca; regulatory@cnoc.ca; bell.regulatory@bell.ca ; regulatory@bell.aliant.ca; Keith.stevens@execulink.com; jcarter@surenet.net; mike.manvell@switchworks.com; ghariton@sympatico.ca; ctacit@tacitlaw.com; crtcmail@gmail.com; scott@beamdog.com; mmallani@yahoo.ca; d.olafson@shaw.ca; wally@ciaccess.com; jared.mcateer@istockphoto.com; thepga@gmail.com; dirkalgera@gmail.com; tfarrelly@bryston.ca; al@purepages.ca; rubenstein.mark@gmail.com; jamiea@storm.ca; glenrfarrell@gmail.com; dr.wilson@wilson-research.ca; jacqueslee917@gmail.com; catherine.middleton@ryerson.ca; apilon@acninc.com; deschec@ircm.qc.ca; jebouchard@phdvideo.com; ian_fraser@nomorecrtcspam.ca; scottandkai@rogers.com; dmckeown@viewcom.ca; peterdasilva@yahoo.ca; abriggs@cogeco.ca; rwadsworth@sandvine.com; document.control@sasktel.com; sidneirohr@hotmail.com; ivan@vibrantprints.ca; jae@c-art.com; rem00126@hotmail.com; cmich@rogers.com; tzaritsa1000@hotmail.com; chad.cunningham@cwct.ca; renaonlinenow@gmail.com; tisrael@cippic.ca; jfleger@jflegerlaw.com; andyb@teksavvy.com; samsonmi@tlb.sympatico.ca; andre.labrie@mcccf.gouv.qc.ca; regulatory@primustel.ca; amanevich@heenan.ca; brian@colenet.ca; Regulatory.Matters@corp.eastlink.ca; adena.dinn@calliougroup.com; anlakenews@gmail.com; regulatory@bcba.ca; satkepa@rogers.com; lukejwohlgemut@hotmail.com; Smartyjones@sympatico.ca; ricka@zing-net.ca; kirsten.embree@fmc-law.com; hemond@consommateur.qc.ca; grayden@graydenlaing.com; john.temprile@vivosonic.com; broxx@shaw.ca; syscool77@hotmail.com; duarte@aetoronto.ca; eric.leclerc@iaah.ca; jroots@cad.ca; jonathan.holmes@ota.on.ca; mike@mikeaudet.com; mena_samuel@hotmail.com; iworkstation@mtsallstream.com; dennis@iplink.net; rob.olenick@tbaytel.com; shannonbgroves@yahoo.com; t_wardman@hotmail.com; jfmezei@vaxination.ca; scott@zip.ca; ml.auer@sympatico.ca; cbachalo@juniper.net; mdrobac@netflix.com; andrewoca@gmail.com; hannon@rogers.com; hijbji@gmail.com; blackwell@giganomics.ca; erik.waddell@ic.gc.ca; david.watt@rci.rogers.com; regulatory.affairs@telus.com; Andreea.Todoran@ic.gc.ca; cjprudham@barrettxplore.com; regulatory@teksavvy.com; crtc@mhgoldberg.com; piac@piac.ca; telecom.regulatory@cogeco.com; regaffairs@quebecor.com; regulatory@distributel.ca; regulatory@teksavvy.com; munly@worldbroadbandfoundation.org; henault_claude@hotmail.com

Attachment 1

Wholesale Internet ADSL Service – 50 Mbps Residential Service

1. Refer to Telus(CRTC)8Mar12-2 Attachment 1b and Table 5 of Appendix B filed in support of TN 445, specifically the Outside Plant and Access loop costs. Telus noted that an additional copper loop is required to provide bonded service.

a. Provide a detailed configuration diagram that describes how bonding of copper is implemented, identifying the resources type of equipment.

b. Provide the calculation of the Access loop costs that the company based on the average of the Alberta and British Columbia Decision CRTC 2001-238 loop rates with supporting data and rationale.

c. Provide data and calculations showing how the Access Loop Unit Cost (IFC) in Attachment 1b and the Outside Plant Capital Causal to Demand PWAC in Table 5 were calculated.

d. Provide your point of view on excluding the additional copper costs to provide bonded service and charging for it separately as a dry loop charge in view of the fact that some end-users may need one or more additional loops.

2. Refer to Telus(CRTC)8Mar13-1, and Telus(CRTC)8Mar13-2;

a. Provide a revised cost study and proposed rates (including Table 5 – Detailed Summary of Causal Costs) for the 50 Mbps residential wholesale Internet ADSL service that includes all Commission determinations in Telecom Decision CRTC 2011-703 and Telecom Decision CRTC 2013-73 namely,

i. A ten year study period, the historical usage growth rate per month for the first year and 20 percent per year for the remaining years of the study period,
ii. An annual capital unit cost change of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment cost.

iii. Standard equipment lives: e.g. DSLAM (6 years), BRAS/Aggregation (8 years) and ATM PVC (8 years).

b. Complete Tables 1 and 2 in the Attachment 2, including manufacturer’s equipment name, model number for the major components of the BRAS/Aggregation configuration.

c. Show the calculations required to derive the IFCs for the BRAS/Aggregation devices in Table 2 using the information provided in Table 1 for the BRAS/Aggregation devices.

d. Provide the value used for the oversubscription ratio and the supporting rationale for its derivation.

e. Provide the equivalent usage per kbps per end-user based on your oversubscription ratio.

3. For the above scenario in question 2:

a. Provide a breakdown of the Advertising and Sales Management Expenses Causal to Demand into the major sub-activities; and

b. For each major sub-activity of Advertising and Sales Management Expenses Causal to Demand, provide the associated costing methodology and assumptions; and

c. For any major sub-activity of Advertising and Sales Management Expenses Causal to Demand that is developed based on explicit time estimates, provide time estimates in time increments of no more than 15 minutes and labour unit cost values; further provide associated vintages and sources of information; and

d. For any major sub-activity of Advertising and Sales Management Expenses Causal to Demand that is developed based on unit costs or factors, provide the values specifying the vintage of the data. Further explain, if and how retrospective PIFs and EIFs were applied to restate each unit cost from the vintage year to the year 2012, with supporting rationale.

4. In response to interrogatory Telus(CRTC)4Feb11-110, dated 11 March 2011, TCC stated that it plans to standardize a newer Aggregation device which could handle more bandwidth in preparation to converge more services in TCC’s edge network.

a. Provide a description of this new Aggregation device and BRAS growth technology, including manufacturer, model and capacity. The BRAS growth technology is defined here as the BRAS model that the company is using in its new installations and/or for replacement.

b. If TCC has not incorporated this new Aggregation device and BRAS growth technology in its cost studies filed in support of TN 445, explain why not.

c. Provide a revised cost study and proposed rates (including Table 5 – Detailed Summary of Causal Costs) for the 50 Mbps residential wholesale Internet ADSL service including this new Aggregation device and the BRAS growth technology that includes all Commission determinations in Telecom Decision CRTC 2011-703 and Telecom Decision CRTC 2013-73 namely,

i. A ten year study period, the historical usage growth rate per month for the first year and 20 percent per year for the remaining years of the study period,

ii. An annual capital unit cost change of minus 5 percent for access-driven equipment and minus 10 percent for usage-driven equipment cost.

iii. Standard equipment lives: e.g. DSLAM (6 years), BRAS/Aggregation (8 years) and ATM PVC (8 years).

d. Complete Tables 1 and 2 in Attachment 2 for the new Aggregation device and BRAS growth technology for the 50 Mbps residential service.

Date modified:

2013-06-27