ARCHIVED - Telecom Commission Letter Addressed to Dallas Yeulett (Northwestel Inc.)

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Ottawa, 12 August 2015

Our reference:  8740-N1-201501023


Mr. Dallas Yeulett
Senior Manager, Regulatory Compliance
Northwestel Inc.
P.O. Box 2727
Whitehorse, Yukon Y1A 4Y4

Re: Northwestel Tariff Notice (TN) 923 – Request for further information

The purpose of this letter is to establish additional process in the context of Northwestel Inc. (Northwestel)’s Tariff Notice (TN) 923 concerning its Wholesale connect service for 150 Mbps and 200 Mbps circuits in Type A and Breakout communities.

On 23 April 2015 Commission staff, by letter, requested that Northwestel file certain cost information and disclose such information in accordance with Telecom Regulatory Policy 2012-592 (TRP 2012-592).Footnote 1  Northwestel responded to this request on 25 May 2015.  The Canadian Network Operator’s Consortium (CNOC) filed comments on this information on 26 June 2015, to which Northwestel replied on 10 July 2015. 

Based on the record of this proceeding and Commission staff’s preliminary analysis, further information is required in order to make a proper determination on whether the proposed rates are just and reasonable. For example, it is noted that the study period relied upon in this application may not be appropriate on the basis that the study pertains to services that are being offered as of February 2015 and forward. Also, the vintage data (2007 and 2011) used in the study might not be representative of the current costs (2015).

Accordingly, Commission staff requests that Northwestel provide responses to the attached interrogatories by 15 September 2015.

Interested parties may file comments on the materials filed by Northwestel by 30 September 2015 and Northwestel may file reply comments by 16 October 2015.
Northwestel may designate information as confidential in accordance with sections 38 and 39 of the Telecommunications Act and sections 30 – 34 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure.  However, the company is to disclose the information filed in accordance with TPR 2012-592.

All documents filed with the Commission in response to this letter should also be served on all other parties by the required dates. Where a document is to be filed or served by a specific date, the document must be actually received, nor merely sent, by that date.

Please ensure that copies of all documents are also sent by email to Nat Natraj, Senior Analyst at at the time they are filed with the Commission.


Original signed by

Lyne Renaud
Director, Competitor Service and Costing Implementation
Telecommunications Sector
c.c.:  B.Natraj (Nat Natraj) CRTC, 819-953-5081,
William Sandiford, CNOC,
Dean Proctor, SSI,

Attach. (1)

  1. Provide a revised study reportFootnote 2 and detailed cost informationFootnote 3 for the Wholesale Connect service for each of 150 and 200 Mbps circuits for each of Type A and Breakout communities incorporating the following assumptions:
    1. Study period from 2015 to 2019
    2. All capital and expense unit costs are to be be based on current (i.e. 2015) vintage data. If current vintage data is not used:
      1. explain why not, and
      2. clearly identify all the unit costs that do not use current vintage data and specify the vintage of the data used and provide supporting rationale that demonstrate it is the most appropriate and reasonable value to use. Also, provide the retrospective CIF(s) and PIF(s) used to restate the data to 2015.
    1. Apply annual cost decrease factor  of -5% to the usage-driven capital costs within the switching category as indicated in paragraph 23 of the company’s reply comments on TN 923 dated 10 July 2015.
  1. Using the format of the Tables in the study report provided in response to 1 above, and the assumptions indicated in parts  a), b) and c) above, provide revised costs and rates for each of the150 and 200 Mbps speeds for each of the Type A and Breakout communities with only the following change in assumption:

    Assume supplier identified maximum capacity of the switching equipment is 10,000 MbpsFootnote 4

  2. Refer to  the company’s 10 July 2015 submission CRTC(NWTEL_TN 923) _Disclosure of Cost Information, Attachment 3_Table 6b, Item A1

    1. Explain with supporting rationale why the “IFC PER MBPS PER ROUTE KM” is an appropriate driver for electronics costs as indicated in the column headed “Unit Cost per capacity driver”.
    2. Explain with supporting rationale why the fiber electronics costs components included in “Fiber route estimate # 1- Electronics only(breakout route) as provided in NWT(CRTC)19Oct12-07 Att 1c Estimate 1” (Estimate 1) is appropriate for  each of the breakout community’s locationsFootnote 5 .The response should address how difference in the number of hops or types of equipment used, which could impact costs, would be captured.
    3. Further provide a configuration diagram indicating the location of the hops for each of the breakout communities and Estimate #1.

  3. Disclose the above information in accordance with TRP 2012-592


Footnote 1

Confidentiality of information used to establish wholesale service rates, Telecom Regulatory Policy CRTC 2012-592, 26 October 2012.

Return to footnote 1


Footnote 2

Using the format of the company’s 25 May 2015 submission, as amended in its 10 July 2015 submission.

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Footnote 3

In accordance with the Commission staff letter dated 23 April 2015 titled “Northwestel’s Tariff Notice (TN) 923 - Filling and disclosure of cost information.” To be provided in Excel spreadsheet format.

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Footnote 4

instead of the supplier identified maximum capacity of 8143 Mbps used in the study as indicated in Attachment 3_Table 6b of the company’s 10 July 2015 response.

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Footnote 5

High level Alberta and Fort St. John BC as indicated in the section A1of Table 6b “Breakout communities weighted average transport (Layer 1) IFC per Mbps-Electronic.”

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