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Telecom - Commission letter adressed to Philippe Gauvin (Bell Canada)

Ottawa, 28 October 2021

Our reference:  8740-B20-202106096, 8740-O31-202106129, 8740-N51-20210611 8740-N51-202106111, 8740-D3-202106104

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 10
160 Elgin St. Ottawa, ON K2P 2C4
bell.regulatory@bell.ca

Re: Bell Canada Tariff Notice 967 - Introduction of National Services Tariff Item 796, Central Office Located Customer Provided Equipment

Ontera Tariff Notice 151, NorthernTel Tariff Notice 409, DMTS Tariff Notice 84 - Withdrawal of Central Office Located Customer Provided Equipment

Philippe Gauvin:

On 3 September 2021, the Commission received an application from Bell Canada, under Tariff Notice (TN) 967 in which the company proposed to introduce Item 796 – Central Office Located Customer Provided Equipment (CPE) to its National Services Tariff (NST).

The company also proposed to migrate the existing equivalent terms for three of Bell Canada’s small incumbent local exchange carriers to Item 796; namely, DMTS and Ontera, both divisions of Bell Canada, and NorthernTel Limited Partnership (NorthernTel), as follows, for which there are currently no customers.

  1. DMTS General Tariff 25370 Section 1000 (TN 84);
  2. NorthernTel General Tariff CRTC 25510 Item N1000.4 (TN 409); and
  3. Ontera General Tariff CRTC 25520 Item 1020.2 (TN 151).

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require parties to file information or documents where needed.

Bell Canada is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 12 November 2021.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the relevant information qualifies for designation as confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

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. The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover page” located on this web page. 

A copy of this letter and all subsequent replies will be added to the public record of this proceeding.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca

Attach. (1)

Request for Information

Bell Canada is proposing to introduce item 796, Central Office Located Customer Provided Equipment (CPE), to its National services Tariff, 7400. Central Office Located CPE is a custom arrangement that provides Central Office floor space and power for interconnection with eligible services. According to the company, this Special Facility Tariff (SFT) will be available in the operating territories of Bell Canada and its affiliates.

Bell Canada noted that the proposed rates for this item are identical to the Commission-approved rates for mandated wholesale co-location services and reflect the historical differences in co-location rates between the various regulated entities.  Given these historical differences, the company proposed three rate tables; specifically, one each for:

  1. Bell Canada in Ontario and Quebec and operating as Bell Aliant in Atlantic Canada and Bell MTS in Manitoba;
  2. Bell Affiliates in the incumbent serving territories of DMTS; KMTS; Groupe Maskatel Québec LP (Maskatel); NorthernTel including its division, Ontera; and Télébec société en commandite (Télébec); and
  3. Northwestel in the incumbent serving territory of Northwestel Inc.

Bell further noted that it proposed to use the highest approved mandated co-location rate for each rate element, stating that adopting rates for each grouping that are equal to or greater than the Commission approved rate for the mandated co-location service in each territory for each grouping ensures that the Phase II costs for each serving territory are recovered, consistent with the Commission's price floor test for retail services.

Under separate cover, Bell Canada proposed to withdraw the Central Office CPE SFTs for NorthernTel (TN 409), Ontera (TN 151) and DMTS (TN 84), and replace these SFTs with new NST item 796.

  1. A special facilities or special assembly tariff (SFT) is generally a customer specific tariff that involves service features or technology that differ from those covered by the general tariff.
    1. Explain with supporting rationale how this SFT involves service features or technology that are not currently available in the companies’ tariffs. Further, if the SFT does not involve unavailable features or technology, explain why it is appropriate to file the proposed service as an SFT rather than relying on the existing tariffs.
    2. Indicate who the customer is for this SFT. If Bell Canada has not developed this SFT for any customer at this time, explain, with supporting rationale, why it is necessary to introduce a new SFT item for a service in the absence of demand for such a new tariff item across the company’s operating territories and withdraw the services offered by DMTS, NorthernTel, and Ontera .
  2. In reference to the Bell Canada rate table identified above, in the Attachment to the application, Bell Canada has proposed that rate element charges for Central Office CPE in most cases reflect the highest available rate across the applicable companies.
    1. Given that these services are otherwise considered wholesale services (conditional mandated non-essential) subject to specific pricing requirements; explain, with supporting rationale why this rating approach should be considered appropriate.
    2. If any of the rate elements in the Bell Canada rate table are to be updated, how will the revised rates be developed to adhere to specific pricing requirements for wholesale services.
  3. In reference to the Bell Affiliate rate identified above, in the Attachment to the application, Bell Canada has proposed to reflect the rates applicable in the serving territories of NothernTel and DMTS for Télébec and Maskatel, which are currently lower than those rates.
    1. Given that these services would be available at lower rates in the companies’ existing tariff, explain, with supporting rationale, why it is reasonable to include higher rates for the operating territories of Télébec and Maskatel in the new proposed SFT.
    2. If any of the rate elements in the Bell Affiliates rate table are to be updated how will the revised rates be developed to adhere to specific pricing requirements for wholesale services.
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