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Telecom - Commission Letter addressed to Robert Olenick (Tbaytel)

Ottawa, 14 January 2022

Our reference: 8740-T8-202107531

BY EMAIL

Robert Olenick
Regulatory Analyst
Tbaytel
1046 Lithium Drive
Thunder Bay ON  P7B 6G3
rob.olenick@tbaytel.com

Subject: Tbaytel - Introduction of Next Generation 9-1-1 (NG9-1-1) Service – Requests for Information

Dear Robert Olenick,

The Commission received Tbaytel’s submissions dated 1 November 2021 in support of its tariff application filed under Tariff Notice 174, further to the direction provided under Telecom Decision 2021-199Footnote1, requesting approval for proposed changes to Tbaytel’s General Tariff CRTC 25570 to introduce Item 10.0 - Next Generation 9-1-1 (NG9-1-1) Service. By way of Telecom Decision 2021-199, the Commission directed all NG9-1-1 network providers to file proposed Wholesale and Retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, and functionalities.

Commission staff have reviewed Tbaytel’s supporting information and documentation filed in response to Telecom Decision 2021-199. Commission staff requests additional supporting information from the Applicant associated with the proposed tariffs.

In that respect, Commission staff requests that Tbaytel provide its response to the attached requests for information no later than 31 January 2022. Where a document is to be filed or served by a specific date, the submission must actually be 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 “Broadcasting and Telecom Cover Page” or the “Broadcasting Cover Page” located on the Commission’s website. There, you will also find information on the submission of applications to the Commission “Filing Broadcasting and Canadian Program Certification documents with the CRTC: Privacy and Security.”

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

As set out in section 39 of the Telecommunications ActFootnote2 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote3, 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 designated information is 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.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.:  Stais Armstrong, CRTC, 819-997-9253, stacey.armstrong@crtc.gc.ca;
Daniel Cardozo, CRTC, 819-962-5720, daniel.cardozo@crtc.gc.ca

Attach. (1) Request for Information (RFI) Questions

Requests for Information (RFI)

For all questions that follow, please refer to the appendices filed in relation to Tariff Notice 174, containing costing information filed in support of Tbaytel’s proposed NG9-1-1 service rate.

  1. Provide a definition of all acronyms used in the submission.
  2. Verify that the wireless demand has been driven by NPA/NXX, as opposed to billing address, in the current submission.
  3. If the demand is driven by billing address, provide a new tariff rate proposal (including all inputs, costs, and demands), with wireless demand based on the NPA/NXX approach.
  4. Refer to paragraph 11 of the cover letter to Tbaytel’s tariff application, dated 1 November 2021, and the appendices entitled “Tbaytel TN#174 NG9-1-1 Page 2 -NPW 001” and “Tbaytel TN#174 NG9-1-1 Page 3 - Details 001” respectively:
    1. Specify if all cost items are reflective of the Net Present Value (NPV) of the NG9-1-1 all-carrier demand. If so, provide the discount rate used and the methodology used to estimate it.
    2. If the costs are not reflective of the NPV of the NG9-1-1 all-carrier demand, restate the costs to reflect the NPV, providing the detailed calculations, methodology, vintage of costs, source of costs, discount rate, and the methodology used to estimate it.
  5. Refer to the appendix titled “Tbaytel TN#174 NG9-1-1 Page 3 - Details 001”, line items “Project Delay Costs”, “Design Development Fee”, “Circuits- NRC”, “Circuits- MRC”, and “Wireless Costs”.
    1. Present the appropriate proportion of the respective costs within the below cost categories:
      1. One-time Expenses Causal to Demand
      2. Ongoing Expenses Causal to Demand
      3. One-time Expenses Causal to Service
      4. Ongoing Expenses Causal to Service
      5. One-time Capital Causal to Demand
      6. Ongoing Capital Causal to Demand
      7. One-time Capital Causal to Service
      8. Ongoing Capital Causal to Service
    2. Explain how the above costs provided are calculated, driving each cost to the respective year of the study period, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
    3. Provide a description of the functions and costs included within the cost item “Project Delay Costs”.
    4. Provide a description of the functions and costs included within the cost item “Design Development Fee”.
    5. Refer to the line items “Circuits- NRC” and “Circuits- MRC”:
      1. Provide a description of the cost item(s) included in the “Circuits - NRC” costs.
      2. Provide a description of the cost item(s) included in the “Circuits - MRC” costs.
      3. State whether transport to the point of interconnection (POI) was considered in the calculation of estimated capital costs and if so, provide an explanation of how this is reflected in the costs.
    6. Provide a description of the functions and costs included within the cost item “Wireless Costs”.
    7. For any service provisioning agreements, identify and provide the applicable service driven costs and demand driven costs, as feasible, driving each cost to the respective year of the study period, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions. Further, provide explanations as to the details and descriptions of any service provisioning agreements.
  6. Refer to the appendix entitled “Tbaytel TN#174 NG9-1-1 Page 2 - NPW 001”:
    1. Provide all assumptions used to determine the demand forecast for both Wireless and Wireline NG9-1-1 services.
  7. Refer to the requirements set forth in paragraph 145 of Telecom Regulatory Policy CRTC 2017-182Footnote4 concerning call routing to the appropriate public safety answering point (PSAP) vis-à-vis the submissions filed in support of the proposed NG9-1-1 tariff.
    1. Does the cost study provided include costs for handling emergency calls without routing information? If so, indicate how these costs are reflected in the cost estimate. If not, explain why the company does not need this component.
    2.  State whether causal costs incurred subsequent to the issuance of Telecom Regulatory Policy 2017-182 but prior to 1 March 2022 (i.e., the cost study start date) have been included at the beginning of the cost study in 2022 dollars. If not, explain if these costs have been included and how they have been calculated.
  8. If the responses to any of the questions above have altered the company’s submission in any way, provide a revised cost study and model for the period 1 March 2022 to 1 March 2027 that incorporates the responses to the requested information, where applicable, for both wireline-only and wireline and wireless services combined.
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