Telecom Commission Letter Addressed to the Distribution List

Ottawa, 27 July 2018

Our references: 8740-B2-201606873, 8740-B2-201703447, 8740-C6-201606831, 8740-E17-201610262, 8740-M59-201606980, 8740-R28-201606808, 8740-S22-201606823, 8740-S9-201606790, 8740-T66-201606815, 8740-V3-201606849

BY EMAIL

Distribution list

RE: Follow-up to Telecom Order CRTC 2016-396 and Telecom Order CRTC 2016-448 – aggregated wholesale high-speed access (HSA) service – Requests for disclosure and additional information

Dear Madams/Sirs:

This letter addresses requests for disclosure of information designated as confidential made in the tariff proceeding for aggregated wholesale high-speed access (HSA) services initiated by Telecom Order CRTC 2016-396 and Telecom Order CRTC 2016-448. This letter also addresses responses to Commission requests for information that were incomplete.

On 8 June 2018, the Canadian Network Operators Consortium Inc. (CNOC) filed requests for disclosure of information for which confidentiality had been claimed and requests for additional information regarding the responses filed by Bell Canada; Bell MTS (formerly MTS Inc.); Bragg Communications Incorporated, operating as Eastlink; Cogeco Communications Inc. on behalf of Cogeco Connexion Inc. (Cogeco); Rogers Communications Canada Inc. (Rogers); Saskatchewan Telecommunications (SaskTel); Shaw Cablesystems G.P. (Shaw); TELUS Communications Company (TCC); and Québecor Média inc. on behalf of its affiliate Videotron (Videotron) to Commission staff requests for information.

On 22 June 2018, Bell Canada, Bell MTS, Eastlink, Cogeco, Rogers, SaskTel, Shaw, TCC, and Videotron responded to the above requests.

Requests for disclosure of information designated as confidential are addressed in light of sections 38 and 39 of the Telecommunications Act (the Act) and sections 30 and following of the CRTC Rules of Practice and Procedure (the Rules of Procedure). In evaluating a request, an assessment is made as to whether the information falls into a category of information that can be designated confidential pursuant to section 39 of the Act. An assessment is then made as to whether there is any specific direct harm likely to result from the disclosure of the information in question and whether any such harm outweighs the public interest in disclosure. In making this evaluation, a number of factors are taken into consideration, including whether information could be reasonably aggregated and the competitive sensitivity of the information itself. The factors considered are discussed in more detail in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, as amended by Broadcasting and Telecom Information Bulletin CRTC 2010-961-1, 26 October 2012.

Commission staff has reviewed the requests filed by CNOC, as well as reply comments and considers that disclosure of certain information, as specified in the Attachment to this letter, is appropriate and in the public interest. Bell Canada, Bell MTS, Eastlink, Cogeco, Rogers, SaskTel, Shaw, TCC, and Videotron have not established the likelihood of specific and direct harm that would outweigh the public interest in the disclosure of the designated information.

Furthermore, Commission staff considers that additional information as specified in the Attachment to this letter is to be submitted.

Having regard to all the considerations set out above, unless otherwise expressly indicated, parties are to file with the Commission all information to be provided pursuant to this letter as set out in the Attachment to this letter by 10 August 2018.

Commission staff continues to examine the aggregated wholesale HSA tariff applications. Parties will be advised as to the next steps in the evaluation process by way of a separate procedural letter, which will set out further process for the proceeding.

Sincerely,

Original signed by

Lyne Renaud

Director, Competitor Services and Costing Implementation
Telecommunications Sector
c.c.:  Abderrahman El Fatihi, CRTC, abderrahman.elfatihi@crtc.gc.ca;
David Mah, CRTC, david.mah@crtc.gc.ca;
Ramin Adim, CRTC, ramin.adim@crtc.gc.ca

Attach. (1)

Distribution List

Lyne Renaud, CRTC, lyne.renaud@crtc.gc.ca
Abderrahman El Fatihi, CRTC, abderrahman.elfatihi@crtc.gc.ca;
David Mah, CRTC, david.mah@crtc.gc.ca;
Ramin Adim, CRTC, ramin.adim@crtc.gc.ca;
Matthew Alexander, CRTC, matthew.alexander@crtc.gc.ca;
Marc Pilon, CRTC, marc.pilon@crtc.gc.ca
Bell Canada:  bell.regulatory@bell.ca;
MTS Inc.: regulatory@mts.ca;
Zayo Canada Inc.: regulatory@zayo.com;
Saskatchewan Telecommunications: document.control@sasktel.com;
TELUS Communications Company: regulatory.affairs@telus.com;
Cogeco Cable Inc.: telecom.regulatory@cogeco.com;
Quebecor Media Inc. (Videotron): regaffairs@quebecor.com;
Rogers Communications Canada Inc.: barry.choi@rci.rogers.com; david.watt@rci.rogers.com;
Nathan Jarret: nathan.jarrett@rci.rogers.com; rwi_gr@rci.rogers.com;
Shaw Cablesystems G.P.: Regulatory@sjrb.ca;
CNOC Regulatory: regulatory@cnoc.ca;
TekSavvy Solutions Inc.: regulatory@teksavvy.com;
Vaxination Informatique: jfmezei@vaxination.ca;
VMedia Inc.: george.burger@vmedia.ca;
Steve Sorochan: steve.sorochan@gov.yk.ca;
Darren Parberry: metisbus@yahoo.ca;
Marcus Schultze: marcus.p.schultze@gmail.com;
Kathleen Turnsek: regulatory@vianet.ca;
Eastlink: Regulatory.Matters@corp.eastlink.ca;
Tacit Law: ctacit@tacitlaw.com;
Distributel Communications Limited: regulatory@distributel.ca;

Disclosure of information designated as confidential

Bell Canada TN 7504

  1. Bell Canada(CRTC)2Mar18-1 Decision 2016-379, part a): Bell Canada is to disclose on the public record from Table 3, Item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.
  2. Bell Canada(CRTC)2Mar18-1 Decision 2016-379, part b): Bell Canada is to disclose on the public record the “CRTC Service-Based Attribution Factor”.
  3. Bell Canada(CRTC)2Mar18-1 Decision 2016-379, part c): Bell Canada is to disclose on the public record the “Proposed Internet Access-Based Attribution Factor”.
  4. Bell Canada (Letter) - Follow-up to Telecom Decision CRTC 2016-379 and Follow-up to Order 2016-396 and Order 2016-448 – Responses to Requests for Information, Paragraph 61: Bell Canada is to disclose on the public record, the cumulative financial impact of the adjustments based on the RFIs the Commission is asking.

Bell MTS TN 778

  1. Bell MTS(CRTC)2Mar18-1 TN 778/A/B, part a): Bell MTS is to disclose on the public record from Table 2, Item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.
  2. Bell MTS(CRTC)2Mar18-1 TN 778/A/B, part b): Bell MTS is to disclose on the public record the “CRTC Service-Based Attribution Factor”.
  3. Bell MTS(CRTC)2Mar18-1 TN 778/A/B, part c): Bell MTS is to disclose on the public record the “Proposed Internet Access-Based Attribution Factor”.

Cogeco TN 52

  1. Cogeco (CRTC)02Mar18 Question 8b) and 8c): Cogeco is to disclose on the public record from Table 1. Item viii the total maximum capacity for the proposed CCAP configuration in Mbps for Cogeco’s proposed CCAP configuration and the CCAP configured with maximum supplier identified capacity.
  2. Cogeco (CRTC)02Mar18 Question 8c): Cogeco is to disclose on the public record the all text in the first sentence in response to Question 8c.
  3. Cogeco (CRTC)02Mar18 Question 10a) ix: Cogeco is to disclose on the public record the Maximum Capacity of the growth technology for IP Core Routers.
  4. Cogeco (CRTC)02Mar18-19 Attachment 1 Updated Table 14: Cogeco is to disclose on the public record from Table 14 - TPIA, Total downstream capacity per fully loaded CMTS/CCAP (Kbps) in column C and column D.
  5. Cogeco (CRTC)02Mar18-19 Attachment 1 Updated Table 14: Cogeco is to disclose on the public record, from Table 14 – TPIA,  available upstream bandwidth per node (Mbps) and available downstream bandwidth per node (Mbps) in column L.

Eastlink TN 37

  1. Bragg(CRTC)2Mar18-6 part a): Eastlink is to disclose on the public record the response to question 6, part a.
  2. Bragg(CRTC)2Mar18-6 part b): Eastlink is to disclose on the public record the response to question 6, part b.
  3. Bragg(CRTC)2Mar18-7part b), Attachment 1 Abridged: Eastlink is to disclose on the public record the value of the DWDM cost factor.
  4. Bragg(CRTC)2Mar18-9 part a): Eastlink is to disclose on the public record the WFF in sixth paragraph following, “the equivalent WFF based on used channels is”, of the response.
  5. Bragg(CRTC)2Mar18-12 part a): Eastlink is to disclose on the public record from Table 2, item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.
  6. Bragg(CRTC)2Mar18-12 part b-c): Eastlink is to disclose on the public record the value of the attribution factor based on the calculation proposed by the Commission staff.

Rogers TN 45

  1. Rogers (CRTC)2Mar18- Proposed Tariff Tables Abridged: Rogers is to disclose on the public record from Table 14 TPIA (A B), Total downstream capacity per fully loaded CMTS/CCAP (Kbps) in column C and column E.
  2. Rogers (CRTC)2Mar18- Proposed Tariff Tables Abridged: Rogersis to disclose on the public record, from Table 14 – TPIA (C D E), available upstream bandwidth per node (Mbps) and available downstream bandwidth per node (Mbps) in column K.
  3. Rogers (CRTC)2Mar18-1 part c): Rogersis to disclose on the public record, the initial working fill factor (WFF) in response to part c.
  4. Rogers (CRTC)2Mar18-9 part a) vii: Rogers is to disclose on the public record the total maximum downstream capacity of the proposed CCAP configuration in Mbps.
  5. Rogers (CRTC)2Mar18-13 part a) iii: Rogers is to disclose on the public record the total capacity of a fully utilized CGW and DGW CRS - 16 slot carrier routing system in Gbps.
  6. Rogers (CRTC)2Mar18-13 part b) iii: Rogers is to disclose on the public record the total supplier identified maximum capacities of a fully utilized CGW and DGW CRS - 16 slot carrier routing system in Gbps.
  7. Rogers (CRTC)2Mar18-14, Attachment 1-Abridged: Rogers is to disclose on the public record the value of the DWDM cost factor.
  8. Rogers (CRTC)2Mar18-15, Attachment 1-Abridged: Rogers is to disclose on the public record the value of the  transport fibre cost factor.
  9. Rogers (CRTC)2Mar18-16, Attachment 1 – Abridged: Rogers is to disclose on the public record the value of the segmentation fibre cost factor.
  10. Rogers (CRTC)2Mar18-17, Attachment 1-Abridged: Rogers is to disclose on the public record the value of the Battery and Power Cost Factor.
  11. Rogers (CRTC)2Mar18-20 part a: Rogers is to disclose on the public record the fully loaded capacity of a CCAP chassis in the sentence following, “Each fully loaded chassis has a capacity of”.
  12. Rogers (CRTC)2Mar18-25 part a): Rogers is to disclose on the public record from Table 2, item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.
  13. Rogers (CRTC)2Mar18-25 part b): Rogers is to disclose on the public record the value of the attribution factor based on the calculation proposed by the Commission staff.
  14. Rogers (CRTC)2Mar18-25 part c): Rogers is to disclose on the public record the value of the Rogers proposed attribution factor for coaxial access facilities.
  15. Rogers (CRTC)2Mar18-25 part c): Rogers is to disclose on the public record the value of the Rogers proposed attribution factor for transport fibre facilities.
  16. Rogers (CRTC)2Mar18-26 part a): Rogers is to disclose on the public record the POI router card capacities used in the aggregated model and the POI router card capacities used in the disaggregated model.
  17. Rogers (CRTC)2Mar18-28 Attachment -Tariff Tables Abridged: Rogers is to disclose on the public record from Table 14 TPIA (A B), Total downstream capacity per fully loaded CMTS/CCAP (Kbps) in column C and column E.
  18. Rogers (CRTC)2Mar18-28 Attachment -Tariff Tables Abridged: Rogers is to disclose on the public record, from Table 14 – TPIA (C D E), available upstream bandwidth per node (Mbps) and available downstream bandwidth per node (Mbps) in column K.

Shaw TN 26

  1. Shaw(CRTC)2Mar18-10 part b): Shaw is to disclose on the public record the value of the DWDM cost factor.
  2. Shaw(CRTC)2Mar18-11 part b): Shaw is to disclose on the public record the value of the segmentation fibre cost factor.
  3. Shaw(CRTC)2Mar18-15 part b): Shaw is to disclose on the public record from Table 2, item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.

TELUS TN 512

  1. TELUS(CRTC)2Mar18-1, part a):TELUS is to disclose on the public record from Table 2, Item f, titled, "% Internet of Total", Average that is based on a straight average of the ratios calculated for each of the years 2017-2022.
  2. TELUS(CRTC)2Mar18-1, part b) and part d): TELUS is to disclose on the public record the “CRTC Service-Based Attribution Factor”.
  3. TELUS(CRTC)Mar2018-2, part c): TELUS is to disclose on the public record from Footnote 11, the percentage of traffic-sensitive costs of the total cost (Base scenario) and the percentage impact on the final rate.

Additional information
Cogeco TN 52

  1. Cogeco (CRTC)02Mar18 Question 6b): Using the format of Appendix 4 - Summary of Revenue and Cost Impact of Cogeco’s baseline cost study, Cogeco is to provide revised proposed rates and cost information using the baseline cost study that includes the costs associated with segmentation fibre and any other usage-sensitive equipment in the traffic driven portion of the cost model.
  2. Cogeco (CRTC)02Mar18 Question 26): Cogeco is to provide (i) an updated baseline cost study (ii) an updated Table 13b, and (iii) the associated revised proposed rates and cost information in the format of Cogeco’s baseline cost study, Appendix 4 - Summary of Revenue and Cost Impact that incorporates the responses identified in question 26, a through l.

Eastlink TN 37

  1. Bragg(CRTC)2Mar18-14:Eastlink is to provide (i) an updated baseline cost study (ii) an updated Table 13b, and (iii) the associated revised proposed rates and cost information in the format of Eastlink’s baseline cost study, tables 1 & 2 that incorporates the responses identified in question 14, a through h.

Rogers TN 45

  1. Rogers (CRTC)02Mar18 Question 7b): Using the format of table 1 of Rogers' baseline cost study, Rogers is to provide revised proposed rates and cost information using the baseline cost study that includes the costs associated with segmentation fibre and any other usage-sensitive equipment in the traffic driven portion of the cost model.
  2. Rogers (CRTC)02Mar18 Question 28): Rogers is to provide (i) an updated baseline cost study (ii) an updated Table 13b, and (iii) the associated revised proposed rates and cost information in the format of table 1 of Rogers' baseline cost study that incorporates the responses identified in question 28, a through m in its response.

Shaw TN 26

  1. Shaw(CRTC)2Mar18-17 part h): Shaw is to provide (i) an updated baseline cost study (ii) an updated Table 13b, and (iii) the associated revised proposed rates and cost information in the format of Shaw’s baseline cost study, tables 1 & 2 that incorporates the responses identified in question 17, a through i.

Videotron TN 52

  1. Québecor Média(CRTC)2mars18-5 groupé partie b): En utilisant le format de l’étude de coûts de référence de Vidéotron (tableau 1), fournir les tarifs proposés modifiés et les renseignements sur les coûts qui comprennent les coûts associés à la fibre de distribution dans la portion liée au trafic du modèle de coûts, ainsi tout autre équipement lié à l’utilisation.
  2. Québecor Média(CRTC)2mars18-21 groupé partie a): Fournir i) une étude de coûts à jour, ii) un tableau 13 b à jour et iii) les tarifs révisés proposés et les renseignements sur les coûts connexes dans le même format que le Tableau 1 de l’étude de coûts de référence de Vidéotron qui comprend les réponses dans la question 21, a) jusqu’au l).
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