Telecom Commission Letter Addressed to Philippe Gauvin (Bell Canada) and Christopher Hickey (Canadian Network Operators Consortium Inc)

Ottawa, 26 April 2017

Our reference: 8662-B2-201612391

BY EMAIL

Mr. Philippe Gauvin
Senior Legal Counsel
Bell Canada
160 Elgin Street, floor 19
Ottawa, ON  K2P 2C4
bell.regulatory@bell.ca

Mr. Christopher Hickey
Director of Industry Affairs
Canadian Network Operators Consortium Inc.
107-85 Curlew Drive
Toronto, ON  M3A 2P8
regulatory@cnoc.ca

RE: Review and Vary and Stay Telecom Decision CRTC 2016-379, follow-up to Telecom Regulatory Policy 2015-326 – Implementation of a disaggregated wholesale high-speed access service, including over fibre-to-the premises access facilities

Dear Sirs:

On 2 December 2016, Bell Canada filed the above noted application and subsequently filed a revised version of the application on 9 December 2016 (revised application). Comments were received from the Canadian Network Operators Consortium Inc. (CNOC), Public Interest Advocacy Centre, British Columbia Broadband Association, Telus Communication Company, Vaxination Informatique and Zayo Canada Inc.

In order to assist in the analysis of the application, Bell Canada and CNOC are to provide responses to the attached requests for information (RFIs) by 19 May 2017. Parties may file comments limited to the new information provided in response to the RFIs by 5 June 2017 and Bell Canada may file reply comments by 12 June 2017.

Responses to RFIs and comments are to be served on all parties to this application by the specified dates. Copies of the document should also be sent to nat.natraj@crtc.gc.ca
Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunications Sector

c.c.: Distribution list


DISTRIBUTION LIST
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ATTACHMENT

Request for information from Bell Canada

Refer of the company’s 9 December 2016 revised application titled “Review and Vary and Stay Telecom Decision CRTC 2016-379, follow-up to Telecom Regulatory Policy 2015-326 – Implementation of a disaggregated wholesale high-speed access service, including over fibre-to-the premises access facilities”.

  1. Refer to paragraph 20 where the company stated:

    “Our estimates posit start up co-location costs in most instances to be between $8,356 and $24,943 and monthly operating costs of between $505 and $1050, depending on the equipment required.”

    1. Provide a detailed description of how each of the co-location cost range values for start-up ($8,356 and $24,943) and monthly operating costs ($505 and $1050) were established.
    2. For 1) each range value noted above and 2) for each instance of co-location used to establish the range values, provide the following:
      1. the co-location type;
      2. a breakdown of each of the start-up and monthly costs into the components identified in the company’s co-location tariff CRTC 7516 Item 110 4.e). Further identify each of the costs associated with installing the IC cable that are referenced in the company’s co-location tariff Item 110.4 d);
      3. if any of the components referenced in paragraph 18 of CNOC’s intervention dated 23 January 2017 were not included in the start up costs namely: 1) project management fees, 2) space preparation and 3) charges associated with the installation of IC cable, explain with supporting rationale why they did not apply;
      4. if there are additional charges other than those specified above that apply to co-locate, indicate each additional charge that applies and provide the rate and a brief description of associated activities and explain how the rate was estimated.
  2. Refer to paragraph 18 where the company stated:

    “We compiled all co-locations established from 2009 to present, which are on a variety of interconnection types, to determine an average of costs. While there are a variety of considerations, it should be noted that the median cost was $54,179, with numbers as low as $12,767, far below the hundreds of thousands alleged by Allstream.”

    1. Explain if the above costs (median and low) include both start-up and monthly costs. If yes, provide a breakdown between start-up and monthly costs. If not, and these are start-up costs, provide the monthly costs.
    2. For 1) the median cost co-location ($54,179), 2) the low cost co-location ($12,767) and 3) each of the remaining co-locations included in the company’s compilation of co-locations established from 2009 to the present, provide the following:
      1. the co-location type;
      2. a breakdown of start-up and monthly costs into the components identified in the company’s co-location tariffs CRTC 7516 Item 110 4.e). Further identify all the costs associated with installing the IC cable that are included as referenced in the company’s co-location tariffs Item 110.4 d);
      3. if any of the components referenced in paragraph 18 of CNOC’s submission dated 23 January 2017 were not included in the start up costs namely: 1) project management fees, 2) space preparation and 3) charges associated with the installation of IC cable, explain with supporting rationale why they did not apply;
      4. If there are additional other charges than those specified above that apply to co-locate, indicate each additional charge that applies and provide the rate and a brief description of associated activities and explain how the rate was estimated.
    3. Were co-location requests from CNOC members included in the compiled list of co-locations established from 2009 to the present? If yes, provide details of each of the co-location types requested and the associated co-location charges.

Request for information from CNOC

Refer to CNOC’s 23 January 2017 intervention in the proceeding dealing with Bell Canada’s Part 1 application titled “Review and Vary and Stay Telecom Decision CRTC 2016-379, follow-up to Telecom Regulatory Policy 2015-326 – Implementation of a disaggregated wholesale high-speed access service, including over fibre-to-the premises access facilities”.

  1. Refer to paragraph 17 where CNOC stated:

    “CNOC members noted that as an absolute minimum, Co-location costs approximately $20,000 in combined “project management fees” and “space preparation” costs.”

    1. If co-location quotes from Bell Canada to CNOC members or charges for existing co-locations were reviewed to obtain the above estimate, provide the following for each quote or existing co-location reviewed;
      1. the co-location type,
      2. the total start-up cost and total monthly cost,
      3. a breakdown of start-up and monthly costs into the components identified in Bell Canada’s co-location tariff CRTC 7516 Item 110 4.e).
    2. If co-location quotes from Bell Canada to CNOC members or charges for existing co-locations were not reviewed to obtain the above estimate, explain how the above costs were obtained.
  2. Refer to paragraph 17 where CNOC stated that:

    “Such estimates do not even include the substantial cost of bringing in fibre from the manhole to the CO transmission equipment” (estimated to be around $10,000)Footnote1 . “However, in the vast majority of cases, entry costs associated with any of the co-locationFootnote2 options can exceed $50,000 and sometimes reach over $100,000, with perpetual monthly recurring costs ranging between $1,000 and $2,500 to cover floor space expenses and power within the CO.”

    1. If co-location quotes from Bell Canada to CNOC members or charges for existing co-locations were reviewed to obtain the above estimates, provide the following for each quote or existing co-location reviewed;
      1. the co-location type,
      2. the total start-up cost and total monthly cost,
      3. a breakdown of start-up and monthly costs into the components identified in Bell Canada’s co-location tariff CRTC 7516 Item 110 4.e).
    2. If co-location quotes from Bell Canada to CNOC members or charges for existing co-locations were not reviewed to obtain the above estimate, explain how the above costs were obtained.
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