ARCHIVED - Letter
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Our reference: 8740-M59-201404912
BY EMAIL
Mr. John Maksimow
Tariffs Manager, Regulatory Affairs
MTS Inc.
P.O. Box 6666, MP19C
333 Main Street
Winnipeg, MB R3C 3V6
iworkstation@mtsallstream.com
RE: MTS Tariff Notice 758 – Accelerated Installation Service
Dear Sir:
On 28 May 2014, the Commission received an application from MTS Inc. (MTS), under Tariff Notice 758, in which the company proposed to introduce Accelerated Installation Service (AIS).
Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.
MTS Inc. is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 27 June 2014.
Consequently, this application, along with any associated subsequent revisions, will not be approved on an interim basis on the 15th calendar day following receipt. However, the Commission intends to dispose of this application, along with any associated subsequent revisions, within 45 business days of receipt of the filing.
Sincerely,
Original signed by
Michel Murray
Director, Regulatory Implementation
Telecommunications Sector
c.c.: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca
Attach. (1)
Request for information- Refer to Attachment 1 ‒Report on the Economic Evaluation for the Introduction of Accelerated Installation Service. In subsection 6.4.1, Expenses Causal to the Service, paragraph 20, under “Other,”
- MTS has included costs associated with the development of the Phase II cost study and filing package.
Commission staff notes that in Review of certain Phase II costing issues, Telecom Decision 2008-14, Appendix 1 ‒ Expense Exclusions From Regulatory Economic Studies, paragraph 12, the Commission listed the following expenses that were to be excluded from regulatory economic studies:
- MTS has included costs associated with planning meetings and delivering training to personnel. Explain, with supporting rationale, why these costs are causal to the AIS service. In addition, provide the Present Worth of Annualized Costs (PWAC) for each of these components.
In light of that determination, provide a revised Table 6.4.5-2 –Summary of Phase II Cost Impacts for Costs Causal to Service for Accelerated Installation Service Per Request, excluding from the “Other” category the costs associated with developing the Phase II cost study and filing package.Expenses associated with activities regarding services subject to the regulatory jurisdiction of the Commission ... such as developing regulatory strategy, monitoring government/regulator views, interpreting decisions, co-ordinating responses to decisions and public notices, preparation and presentation of material to support the company's position in regulatory filings and proceedings, preparation of responses to interrogatories, training and preparation of witnesses as well as participation in legislative and policy processes are not to be included in economic studies.
- MTS has included costs associated with the development of the Phase II cost study and filing package.
- In subsection 6.4.2, Capital Causal to the Service, paragraph 21, under “Software,” MTS indicated it had included, among other things, c) process development and internal documentation used for training purposes, and d) creation of the customer communication documents.
Explain, with supporting rationale, why these activities fall within the definition of software expenses. In addition, if the company believes that these costs are causal to the AIS service, provide details of activities undertaken and justify why they should be considered software costs. Otherwise, propose an appropriate alternative classification.
- Refer to Appendix 1 of Attachment 1 ‒Table 5.2-1,Year end Demand Estimates Accelerated Installation Service.
Explain, with supporting rationale, why the demand values listed in the rows “1-8 Days Betterment” and “9+ Days Betterment” do not equal the demand figures in the row “Accelerated Installation Service Requests.” Provide revisions to the demand values, if applicable, for each of these categories and revise all applicable associated tables – for example, Tables 6.4.5-1 and 6.4.5-2. Further, revise rates if necessary.
- Date modified: