ARCHIVED - Telecom Commission Letter Addressed To Suzanne Morin (Bell Aliant) and Philippe Gauvin (Bell Canada)

Ottawa, 1 October 2014

Our reference: 8740-B54-201404863 and 8740-B2-201404871

BY EMAIL

Ms. Suzanne Morin
Bell Aliant Regional Communications, L.P.
160 Elgin Street, 19th floor
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca

Mr. Philippe Gauvin
Bell Canada
160 Elgin Street, 19th floor
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Re:  Bell Aliant Tariff Notice No. 485 and Bell Canada Tariff Notice 7433

Dear Ms. Morin and Mr. Gauvin:

On 27 May 2014, the Commission received an application from Bell Aliant Regional Communications, L.P. and Bell Canada (the Bell companies) associated with Tariff Notices (TN) 485 and 7433, respectively, in which the Bell companies proposed to introduce, in Ontario and Quebec, a new 10 Gigabit Ethernet (GE) Internet Protocol (IP) Asymmetric Digital Subscriber Line (ADSL) Aggregated High-Speed Service Provider Interface (AHSSPI), referred to as 10 GE IP AHSSPI.

In Telecom Order 2014-313, the Commission approved TNs 485 and 7433 on an interim basis.

To help the Commission in its examination of this matter, the Bell companies are requested to provide responses to the attached additional interrogatories, serving copies on all parties, by 28 October 2014.

Parties may file additional written comments with the Commission solely in relation to the responses to the interrogatories serving copies on all interested parties, by 4 November 2014.  The Bell companies may file reply comments with the Commission by 12 November 2014.

The information provided in response to the interrogatories should be disclosed in accordance with the guidelines established in Confidentiality of Information used to establish wholesale service rates – TelecomRegulatory Policy CRTC 2012-592 (TRP 2012-592), dated 26 October 2012.

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 trichur.krishnan@crtc.gc.ca .

Yours sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services & Costing
Telecommunications Sector

c.c.:  CNOC regulatory@cnoc.ca
Doug Thurston, CRTC, 819-997-4579,  doug.thurston@crtc.gc.ca

Attach. (1)

Bell Aliant TN 485 / Bell Canada TN 7433
10GE IP AHHSPI Interrogatories

On 11 August 2014, the Bell companies filed their responses to interrogatories posed by Commission staff by letter dated 18 July 2014. In their responses, the Bell companies identified in ‘The Companies (CRTC) 18Jul14-1 TNs 485/7433’ the time estimates for the development of documents and in ‘The Companies (CRTC) 18Jul14-2 TNs 485/7433’ the time and cost estimates for software modifications for the proposed 10 GE IP AHSSPI wholesale service.

Commission staff needs further information regarding the time and costs estimates related to documents and software modifications for the proposed 10 GE IP AHSSPI wholesale service. Commission staff understands that comparable activities would have been undertaken when the Bell companies introduced its 1 GE IP AHSSPI wholesale service. Hence Commission staff needs to understand whether the cost estimates for the proposed 10 GE IP AHSSPI service provided in the cost study embody the impact, if any, of having the 1G service already available (Interrogatories 1, 2 and 3 below).

1. Refer to the ‘Report on the Economic Evaluation for Tariff Revision of Gateway Access Service (GAS) to introduce 10 GE IP AHSSPI’ service (‘10 GE Economic Study Report’), filed by the Bell companies on 27 May 2014.
   1. Confirm whether the Bell companies currently use 10 GE ports in the network for either their own services or enterprise customers.
   2. Confirm that the 10 GE line card can be shared. If not, explain why not with supporting rationale.
2. Refer to the Bell companies interrogatory responses related to service documents in ‘The Companies (CRTC) 18Jul14-1 TNs 485/7433’ and related to software in ‘The Companies (CRTC) 18Jul14-2 TNs 485/7433’, dated 11 August 2014.

   With respect to the activities associated with each of (i) the service documents and (ii) software identified in the above interrogatory responses, provide responses to the following:

   1. Confirm whether the Bell companies currently have service documents  and  software, related to the provisioning, management and testing of:
      1. 10 GE ports for either, the Bell companies’ own services or its enterprise customers;
      2. 1 GE AHSSPI for independent service providers (including self serve portal).

       If not, explain why not with supporting rationale.

   2. If the response to 2. a. above, indicates that documents and software exist:
      1. Provide a response highlighting the differences between the existing documentations and software and the proposed documents and software associated with 10 GE AHSSPI, with consideration to the activities identified in the above interrogatory responses.
      2. Confirm whether the proposed 10 GE AHSSPI time estimates for the documents and software represent the estimates required to modify the existing documents and software.  If not, explain why not.
3. With reference to the responses provided in questions 1 and 2 above, provide a more detailed breakdown of the tasks identified in the above Bell companies interrogatory responses in support of the proposed Subject Matter Expert (SME) estimates of 1,485 hours for the service documents and 2,018 hours for the software. The breakdown of the activities / tasks should explain the purpose of the task, why it is required and whether the proposed time estimates provided therein acknowledge the existing 1 GE AHSSPI and / or the 10 GE ports services / functionalities.
4. At paragraph 18 of the ‘10 GE Economic Study Report’, the Bell companies stated that the Phase II costs have been adjusted to reflect cost increases and productivity changes within the study period. Further, ‘Table 6c – Capital and Expense Parameters’ of Appendix 2 of the ‘10 GE Economic Study Report’ shows that the proposed economic study was based on a net Capital Cost Increase / Productivity Improvement Factor, within the study period, of minus 5% for the Switching Equipment.

   Provide a revised ‘10 GE Economic Study Report’ (including revised Appendices 1 and 2) and a revised rate for the proposed 10 GE IP AHSSPI wholesale service, under the following scenario:

   1. Remove the cost increases and productivity changes within the study period, which were included in the original study as proposed, so that the rate for the service could be adjusted externally on an annual basis.
   2. Apply a net Capital Cost Increase / Productivity Improvement Factor of minus 10% for the Switching Equipment within the study period, instead of the minus 5% used in the proposed study; and,
   3. No additional changes are made to the proposed economic study.

Date modified:

2014-10-01