ARCHIVED - Letter

Ottawa, February 25, 2014

Our reference: 8740-M59-201316969

BY EMAIL

Mr. John Maksimow
Tariffs Manager, Regulatory Affaires
Manitoba Telecom Services Inc.
iworkstation@mtsallstream.com

Re: TN 747 – Very High-Speed Digital Subscriber Line Data Access Service

Dear Mr. Maksimow

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

Manitoba Telecom Services Inc. is to file its responses to the attached interrogatories with the Commission, serving a copy on all other parties, by 18 March 2014.

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.

Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications Sector

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

Attach. (1)

ATTACHMENT

MTS VDAS 50 Mbps Service and Bonded VDSL Access

1. For the cost category Capital Causal to service for each of the Standard VDSL Access at the 50 Mbps speed profile and the Bonded VDSL Access services:

a. Refer to Attachment 2, Sheet Table 6b – Capital, Table B and Attachment 1, Tables 6.4.5-2 and 6.4.5-3 Capital Causal to Service - Software. Explain the discrepancy between:
i. The PWAC for Table B, Item 1, 50 Mbps Internal Causal to Startup and the PWAC for Capital Causal to Service- Software in Table 6.4.5-3 and;
ii. The PWAC for Table B, Item 2, Pair Bonding Internal Causal to Startup and the PWAC for Capital Causal to Service – Software in Table 6.5.4-2.

b. Refer to Attachment 2, Sheet Table 6b - Capital, Table B1 and Attachment 1, the report on the Economic Evaluation for this service. The company states that the capital causal to service consists of one-time costs associated with process development and billing systems for implementation of the Standard VDSL Access at the 50 Mpbs speed profile and the Bonded VDSL Access.
i. Describe in detail the specific processes that the company is developing for the Standard VDSL Access at the 50 Mpbs speed profile and the Bonded VDSL Access.
ii. How do the processes being developed differ from the processes that were previously developed for implementation of the existing VDSL access service with 32 Mbps speed profile? Describe the existing VDSL access service processes and explain how they are deficient with respect to process support for Standard VDSL Access at the 50 Mbps speed profile and for Bonded VDSL Access. Explain how the processes being developed fit into the existing VDSL access service processes and whether they are new additional processes or processes that augment or replace existing processes.
iii. For each of the 50 Mbps VDSL Service and the Bonded Access Service, identify the specific changes that are being made to the billing system and identify the steps involved in making the billing system changes.
iv. Using Table B1, identify which activities relate to process development and which relate to billing system changes. If an activity on a particular line in the table is for both process development and billing system changes, split the time estimate between the two. Group each process-related activity with the appropriate process identified in question i above.
v. Provide a description of each activity listed in Table B1 including the type of labour.
vi. For each process development and billing system change activity, identify each activity for the Bonded Access service that is common to the VDSL Access service or is an activity that could be done at the same time as a related activity associated with the VDSL Access service.

c. Refer to Attachment 2, Sheet Table 6b – Capital, Table B1 and explain the duplication of activities for the following:
i. Project Management
ii. Product Design, Analysis, CRTC Filing
iii. System Analysis, Design, Development Testing, Implementation
iv. Requirements, process development or Developing Requirements and processes

d. Provide a further breakdown of time estimates for each service of the following activity ‘Product Design, Analysis and CRTC Filing’ into its 3 components including a description of each component activity.

e. MTS has provided project estimates for its process and billing development costs. Since the project is completed as MTS requested an effective date of 31 January 2014, provide the most recent actuals for each of the items and activities listed in Attachment 2, Tab Table 6b – Capital, Table B1.

2. Refer to the Attachment 2, Sheet Table 6a- Expenses, Table B1 – Bonded VDSL Access Service Charge costs:

a. For the following activities provide a more detailed description of the activity and a further breakdown into sub-activities and associated time estimates:
i. Wire ports if available (and what is done if no ports are available?)
ii. Check for minimum speeds
iii. Trouble shoot from cabinet
iv. Obtain spare pairs from Assignment
v. LTO & test spare pairs
vi. Cable Maintenance checks defective ports

b. Provide the source of the occurrence rate estimates.

c. Identify the steps, with a detailed description of each step, that the company carries out to provision its service for each of the following service requests:
i. Request for a 50 Mbps access service requiring a single copper pair;
ii. Request for a 50 Mbps access service requiring bonding of two copper pairs.
Identify which steps for service request ii are common with the steps for service request i.

d. Compare the service charge activities for the Bonded Access Service in Table B1 referenced above and VDSL Access service charge activities (as per MTS Allstream(CRTC)4Jan11-1 Attachment Table 2). Identify each activity for the Bonded Access charge that is common to the VDSL Access service charge or is an activity that could be done at the same time as a related activity associated with the VDSL Access service charge.

3. Provide a detailed configuration diagram for the standard VDSL 50 Mbps Access service and Bonded VDSL Access service including all the main components that are included in the proposed costs for this service.

4. Provide the current retail rates including the service charges for each of MTS’ residential high speed internet rates service offerings with and without bonded access.

5. Refer to Attachment 1, Table 5.2-1:

a. Provide a breakdown of the forecasts for each of Standard VDSL 50 Mbps and Bonded VDSL Access into competitor and company demand.

b. If there is a large discrepancy (more than 20% difference) between the proportions of VDSL 50 Mbps service for retail versus competitor demand that require Bonded VDSL Access, explain with supporting rationale.

6. MTS states that it is introducing an optional Bonded VDSL Access for service requests for:
i. Locations that are beyond the operational range of the facilitating VDAS on a single copper pair or;
ii. When the requested optional speed profile is only available by bonding two copper pairs.

a. Explain under what specific circumstances is the optional speed profile only available by bonding two copper pairs other than for being beyond the operational range of the facility.

Date modified:

2014-02-25