Telecom - Commission Letter addressed to the Distribution List

Ottawa, 14 January 2022

Multiple references

BY EMAIL

Distribution List

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

The Commission received submissions from the small incumbent local exchange carriers (SILEC) referenced in Appendix 1 (Applicants), which are members of the Independent Telecommunications Providers Association (ITPA), in support of their respective tariff applications further to the direction provided under Telecom Decision 2021-199 ^Footnote1 , requesting approval for proposed changes to their national services tariffs to introduce 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, or functionalities.

Commission staff have reviewed the applications and all supporting information and documentation filed in response to Telecom Decision 2021-199 by the Applicants. Commission staff requests additional supporting information from the Applicants in relation to the proposed tariffs.

In that respect, Commission staff requests that each of the Applicants individually submit their respective responses to the attached requests for information (RFIs) 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 Act ^Footnote2 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961 ^Footnote3 , 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;
Jonathan Holmes, ITPA, jonathan.holmes@itpa.ca

Attach. (2)
1. Distribution List
2. Request for Information (RFI) Questions

Distribution list

Requests for Information (RFI)

The following questions pertain to the cost model titled “Detailed Summary of Causal Costs” for each SILEC company identified in Appendix 1, in respect to both wireline and combined wireline and wireless services, filed in support of their proposed NG9-1-1 service rate. Each individual SILEC company is requested to respond to the following questions related to their respective cost model. 

1. Provide a definition of all acronyms used in the revised cost study.
2. Verify that the “Wholesale WSP” demand has been driven by billing address, as opposed to NPA/NXX, in the current submission.
3. Provide a new tariff rate proposal (including all inputs, costs, and demands) with a wireline plus wireless demand, with wireless demand based on the NPA/NXX approach.
4. The cost study does not indicate whether all cost items are reflective of the Net Present Value (NPV) of the NG9-1-1 all-carrier demand and related costs.
   1. Specify if all cost items are reflective of the NPV of the NG9-1-1 all-carrier demand.  If so, provide the discount rate 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, assumptions, vintage, and source of costs. Further, provide the discount rate and the methodology used to estimate it.
5. Refer to all cost items related to wireline and wireless estimates:
   1. For all functions outsourced to a third party, provide a brief description of the activities outsourced, including the terms and conditions of the respective service agreement.
   2. For all functions outsourced to a third party, provide the costs, separating the costs between causal to service and causal to demand, one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
6. Refer to the tab “Cost Summary Table”, cost category “Expenses causal to the service”, cost line item “Switch software licenses and support”:
   1. Explain how the cost provided was calculated, separating the cost between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
   2. If the revised Switch software licenses and support costs include any licensing charges or other long-term service contracts beyond the study period, state whether there is any end of study value attributable to these costs.
   3. Explain how the above mentioned software helps deliver the NG9-1-1 service.
7. Refer to the tab “Cost Summary Table”, cost category “Capital causal to the service”, cost line item of “Switches and support”:
   1. Explain how the cost provided was calculated, separating the costs between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
   2. For each capital component included in the study within Capital causal to service, indicate the expected service life of the equipment, and the estimated worth of any such equipment at the end of the study period.
   3. State whether any of the components of the Switches and support cost are dependent on the incremental demand (such as number of customers served or anticipated NG9-1-1 calls) and identify such components as well as their expected capacity
   4. Explain how the above mentioned components help deliver the NG9-1-1 service.
8. Refer to the tab “Cost Summary Table”, cost category “Capital causal to the service”, cost line item “Software”:
   1. Confirm that no software is required for to deliver the NG9-1-1 service.
   2. If software is required to deliver the NG9-1-1 service, provide the capital causal to the service costs, separating the costs between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.  Further indicate how such software helps to deliver the NG9-1-1 service.
9. Refer to the tab “Cost Summary Table”, cost category “Capital causal to demand”, line items “Outside Plant Equipment”, “Switching Equipment”, “Transmission Facilities”, and “Land, Building and Other”:
   1. Confirm that there is no capital causal to demand for NG9-1-1 for the above line items.
   2. If costs are required for the above line items, provide the capital causal to demand costs, separating the costs between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions,  and indicate how such equipment helps to deliver the NG9-1-1 service.
10. Refer to the tab “Cost Summary Table”, cost category “Expenses causal to demand”, line item “Outsourced services”:
    1. Explain how the costs provided were calculated, separating the costs between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
    2. Describe the nature of any service agreements pertaining to the outsourcing of any services related to NG9-1-1 with third parties, along with the applicable costs. Identify which costs are variable (based on a per-user or per NG9-1-1 call, for example) and which are not. Include information such as the nature of the service agreement and duration, and itemize costs that are initial and ongoing, identifying which are dependent upon demand, including the driver of each cost component.
11. Refer to the tab “Cost Summary Table”, cost category “Expenses causal to demand”, line item “Circuit rentals and associated costs”:
    1. Explain how the cost provided was calculated, separating the cost between one-time costs and ongoing costs, including all detailed calculations, methodology, vintage of costs, source of costs, and economic assumptions.
    2. 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.
    3. 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.
12. Refer to tab “Demand Forecast Table”, table “Retail / Wholesale Demand Forecast (Annual average)”, line items “Retail NAS (Residential and Business)” and “Wholesale WSPs”:
    1. Provide all calculations, methodology, vintage of costs, source of costs, growth assumptions, and economic assumptions used to determine the demand forecast for both wireless and wireline (no wireless) NG9-1-1 services.
13.  Refer to the requirements set forth in paragraph 145 of Telecom Regulatory Policy CRTC 2017-182 ^Footnote4 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 SILEC’s 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 on 1 June 2017 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.
14. 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 information requested, where applicable, for both wireline-only and wireline and wireless services combined.

Date modified:

2022-01-14