Telecom - Commission Letter addressed to the Distribution List

Ottawa, 18 July 2022

Multiple references

BY EMAIL

Distribution List

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

In Telecom Decision 2021-199 ^Footnote1 , 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. The Commission received tariff applications, as well as supporting information, from the telecommunications providers referenced in Appendix 1 (Distribution List) further to the direction provided under Telecom Decision 2021-199, requesting approval for proposed changes to their national services tariffs to introduce Next Generation 9-1-1 (NG9-1-1) Service.

Commission staff have reviewed the applications and all supporting information and documentation filed in response to Telecom Decision 2021-199. Commission staff requests additional supporting information from the applicants, set out in the Distribution List, 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 5 August 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 “Telecom Cover Page” located on the Commission’s website.

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;
B. Natraj (Nat Natraj), CRTC, 819-953-5081, nat.natraj@crtc.gc.ca
Applicants
Interveners

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

Distribution List

Requests for Information (RFI)

Section 1A:  Questions for All ITPA Member SILECs:

1. Refer to the tab “Cost Summary Table” in each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV ^Footnote6 _07Feb2022_ABRIDGED ^Footnote7 ”.
   • For all pre-service (i.e., year 0) costs:
   1. Provide the related vintage of each individual cost item specified.
   2. Where applicable, demonstrate if and how the above costs were restated for inclusion at the beginning of the study period.
2. Refer to the tab “Cost Summary Table” in each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
   1. For any ongoing, service-driven costs, confirm whether they are treated as capital or expense, and provide the supporting rationale.
   2. For any ongoing capital cost identified in 2) a), provide the capital life estimate for the asset.
   3. For any one-time, service-driven costs, confirm whether they are treated as capital or expenses, and provide supporting the rationale.
   4. For any one-time, service-driven capital cost identified in 2) c), provide the capital life estimate for the asset.
3. Refer to the tabs “Table 3 Cross Connects Circuits” and “Table 4 Hardware, Equipment” in each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
   1. Explain if annual productivity has been factored into the annual cost increase adjustments. If it has not, explain with rationale why.
4. Refer to the tab “Table 3 Cross Connects Circuits” in each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
   1. For any costs calculated using a cost factor, provide an explanation as to how each factor was calculated, including all inputs and formulae used in the development of the factor. The response should include why the use of a factor is appropriate.
5. Refer to the tab “Cost Summary Table” in each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
   1. Confirm if bad debt expenses were included in the submitted NG9-1-1 cost models and respective NG9-1-1 rates.
      1. If bad debt expenses were included, state how they were calculated and/or determined, and provide the tab names, row and column references where it is reflected in the cost model.
      2. If bad debt expenses were not included, state the rationale.
   2. The Commission imposes a Revenue Contribution Charge (RCC) payable to the National Contribution Fund on telecom service providers with at least $10 million in Canadian telecom revenue, as mandated under Decision CRTC 2000-745 ^Footnote8 and detailed in Telecom Information Bulletin CRTC 2019-396 ^Footnote9
      1. For those companies who are required to pay into the National Contribution Fund, state whether the Revenue Contribution Charge has been factored into the cost estimates.
      2. For those companies who are required to pay into the National Contribution Fund, state the factor or cost used, and demonstrate how the RCC is applied within the cost model.
   3. Identify all one-time or ongoing third-party costs that are incurred by way of a contract with a third-party provider.
      1. For any of the ongoing third-party costs identified above, specify if there are costs incurred during the study period that do not change from year to year.
   4. For all other ongoing costs which are not incurred by way of a third party contract, confirm whether the costs have been adjusted annually (i.e., by way of capital increase factors, expense increase factors, productivity impacts). If they have not, explain why.
6. Refer to the file, "Réponse-Response - ITPA - 18 February 2022 - Claude_Doucet_CRTC_NG9-1-1_Proposed_Tariffs_ITPA_RFI_Responses_Attachment_2_07Feb2022_ABRIDGED”.
   • As stated within part b) of the answer to “CRTC Question 4”:
   • “The ITPA chose a discount rate of 3% as a proxy for inflation at the time.”
   • Commission staff considers the use of an after-tax weighted average cost of capital (AT-WACC) as the appropriate method of determining the net present value of an economic evaluation ^Footnote10 . As referenced in footnote 31 of Telecom Decision CRTC 2021-181 ^Footnote11 , wherein the Commission stated:
   • “The AT-WACC is a factor used in the process of estimating a monthly costs (discounting cost to reflect estimated costs throughout the study period at one point in time).”
   1. In the event that the ITPA-member SILECs disagree with the use of AT-WACC as the appropriate method of determining the net present value of an economic evaluation, explain why.
      • Commission staff further note that the ITPA-member SILECs (with the exclusion of 9315-1884 Québec incorporated) have provided the information used in the development of an ATWACC in a previous cost study in relation to direct connect services, as mandated under Telecom Regulatory Policy CRTC 2013-160 ^Footnote12.
   2. For all ITPA-member SILECs (with the exclusion of 9315-1884 Québec incorporated), state whether the information on file with the Commission in respect to the economic parameters related to AT-WACC in Telecom Regulatory Policy 2013-160 are still valid and applicable to each respective ITPA-member SILECs for use within each respective NG9-1-1 cost study.
   3. If the parameters on file are no longer valid (or in the case of 9315-1884 Québec incorporated, nonexistent), provide the following components of the AT-WACC along with the vintage of each component:
      1. Cost of debt
      2. Cost of common equity
      3. Cost of preferred equity
      4. Debt ratio
      5. Common equity ratio
      6. Preferred equity ratio
   4. Provide, in Microsoft Excel format, the calculation of AT-WACC using the AT-WACC inputs provided, clearly showing the calculations with formulae using the above cost components. Access to various Phase II costing manuals ^Footnote13 , which would include information on how to calculate the AT-WACC, can be referenced on the CRTC website ^Footnote14 .
7. If the responses to any of the above RFI questions alter the company’s submission in any way, provide the revised ITPA-member SILEC NG9-1-1 cost models, along with the revised, related NG9-1-1 rates, for the period 1 March 2022 to 1 March 2027 that incorporates the responses to all of the above RFI, where applicable, for both wireline-only and wireline and wireless services combined, using the respective AT-WACCs calculated in RFI Question 6d. Provide the revised cost models in Microsoft Excel format, ensuring that all formulae demonstrating the calculations, equations and applications of the AT-WACCs are provided. The abridged version of the economic model should include the row and column description(s) and the respective table headings so that interveners and all parties are aware of the cost components included in the cost study.
8. Refer to the file, "Réponse-Response - ITPA - 18 February 2022 - Claude_Doucet_CRTC_NG9-1-1_Proposed_Tariffs_ITPA_RFI_Responses_Attachment_2_07Feb2022_ABRIDGED”.
   • As stated within part b) of the answer to CRTC Question 4:
   • “ITPA members have outsourced the entirety of their NG9-1-1 networks to a third party.”
   1. Provide a copy of each company’s respective commercial service agreement(s) with the third party.

Section 1B – Questions applicable only to Nexicom Telecommunications, Nexicom Telephones, Cochrane Telecom Services, and North Frontenac Telephone Corporation Ltd.:

9. Refer to the tabs “Demand Forecast Table” and “Table 2 – SILEC NAS and WSPs ^Footnote15 ” in the respective ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
   1. Provide the historic wireline year-end NAS ^Footnote16 demand for 2019, 2020, and 2021.
   2. Explain the methodology and assumptions made for the wireline NAS demand forecasted for the study period.

Section 1C – Question applicable only to Bruce Telecom Ontario Inc. and Cochrane Telecom Services:

10. Refer to the tab “Table 1 – Model” in the respective ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_CostSummary_NPV_07Feb2022_ABRIDGED”.
    1. Explain why the abridged version of the cost model reflects a different NPV ^Footnote17 discount factor than the confidential cost model.

Section 2 – Questions for Tbaytel

11. Refer to the file, “Réponse-Response - 14 January 2022 - Tbaytel - NG9-1-1 Attachment 1 to RFI Responses February 7, 2022 ABRIDGED”.
    1. Confirm if bad debt expenses were included in the submitted NG9-1-1 cost models and respective NG9-1-1 rates.
    2. If bad debt expenses were included, state how they were calculated and / or determined, and provide the tab names, row and column references where it is reflected in the cost model.
    3. If bad debt expenses were not included, state the rationale.
12. Refer to the file, “Réponse-Response - 14 January 2022 - Tbaytel - NG9-1-1 RFI Responses - February 7, 2022 ABRIDGED”, Answer A4, wherein it is stated:
    • “Tbaytel was confident that all cost elements used reflected the Net Present Value (NPV) of the NG9-1-1 all-carrier demand.”
    • Commission staff considers the use of an after-tax weighted average cost of capital (AT-WACC) is the appropriate method of determining the net present value of an economic evaluation^Footnote18 .  As referenced in footnote 31 of Telecom Decision CRTC 2021-181^Footnote19 , wherein the Commission stated:
    • “The AT-WACC is a factor used in the process of estimating a monthly costs (discounting cost to reflect estimated costs throughout the study period at one point in time).”
    1. In the event that Tbaytel disagrees with the use of AT-WACC as the appropriate method of determining the net present value of an economic evaluation, explain why.
    2. Provide the following components of AT-WACC along with the vintage of each respective component:
       1. Cost of debt
       2. Cost of common equity
       3. Cost of preferred equity
       4. Debt ratio
       5. Common equity ratio
       6. Preferred equity ratio
    3. Provide, in Microsoft Excel format, the calculation of AT-WACC using the above information, clearly showing the calculations using the above cost components. Access to various Phase II costing manuals^Footnote20 , which would include information on how to calculate the AT-WACC, can be referenced on the CRTC website^Footnote21 .
13. The Commission imposes a Revenue Contribution Charge (RCC) payable to the National Contribution Fund on telecom service providers with at least $10 million in Canadian telecom revenue, as mandated under Decision CRTC 2000-745 and detailed in Telecom Information Bulletin CRTC 2019-396.
    1. State whether the Revenue Contribution Charge payable to the Commission has been factored into the cost estimates.
    2. If an RCC has been applied, state the factor or cost used, and demonstrate how the RCC is applied within the cost model.
14. If the responses to any of the above RFI questions alter the company’s submission in any way, provide the revised NG9-1-1 cost model, along with the revised, related NG9-1-1 rates, for the period 1 March 2022 to 1 March 2027 that incorporates the responses to all of the above RFI, where applicable, for both wireline-only and wireline and wireless services combined, using the respective AT-WACCs calculated in RFI Question 12) c). Provide the revised cost models in Microsoft Excel format, ensuring that all formulae demonstrating the calculations, equations and applications of the AT-WACCs are provided. The abridged version of the economic model should include the row and column description(s) and the respective table headings so that interveners and all parties are aware of the cost components included in the cost study.
15. Refer to the file, “Réponse-Response - 14 January 2022 - Tbaytel - NG9-1-1 RFI Responses - February 7, 2022 ABRIDGED”, Answer A5g, wherein it is stated:

    “As noted before Tbaytel has outsourced the meeting of its NG9-1-1 requirements to Bell Canada.”

    1. Provide a copy of the agreement with Bell Canada.

Section 3 – Questions for TELUS

16. Refer to “TELUS Communications Inc. - TN-565 Att 1 Abridged”:
    1. Refer to paragraph 39 where the following is stated:

       “The tariffed demand for the service does not include the Company’s wireless end-users.”

       1. As TELUS’ NG9-1-1 service will be applied to the company’s wireless and wireline end-users, explain the validity of the above statement.
       2. Confirm if TELUS has an NG9-1-1 rate for its retail wireless service. If not, explain with rationale why.
       3. If the costs for its retail wireless services have been excluded, explain how they will be recovered.
       4. Refer to paragraph 105 where the company stated that “…all causal costs were prorated to wholesale and retail demand except for Originating Network Provider (ONP) interconnect costs…which are attributed to wholesale demand only”.  Explain with supporting rationale why the company’s methodology to prorate causal costs as indicated above is appropriate. 
    2. Refer to paragraph 50 where the company stated that the cost study excluded costs which are “recovered through commercial service agreements with other ILECs^Footnote22 that partially rely on TELUS’ NG9-1-1 network for providing the service in their operating territories.”
       1. Explain if the corresponding demand driven by commercial service agreements was also excluded when developing the monthly NG9-1-1 cost per Network Access Service and the corresponding rate for wholesale and retail NG9-1-1 service. If not, please provide supporting rationale.
       2. Provide a breakdown, including descriptions, of the costs excluded and the corresponding demand, if applicable.
    3. Refer to paragraph 52 where the company stated that “Costs causal to the service that were incurred prior to service launch but after the Commission’s mandate to offer the service are restated into economically equivalent amounts as of the beginning of the study period using the Company’s weighted average cost of capital with no inflation.”
       1. Provide the reference within the cost study where the above costs incurred prior to the launch of the NG9-1-1 service are included, indicating the file name, tab name and row reference(s).
       2. Explain with supporting rationale why the company deviated from the methodology to restate costs indicated in section 1.2.9 (Cost Increase factors and Productivity Improvement factors) of the company’s Regulatory Economic Studies Manual (the Manual).
       3. Use the methodology indicated in section 1.2.9 of the Manual to restate the costs incurred prior to service launch with the appropriate application of the capital increase factors (CIF), Expense Increase Factor (EIF) and Productivity Increase Factors (PIF).
17. Refer to “TELUS Communications Inc. - TN-565 Att 2  Abridged”
    1. Refer to Tab ”Table 6c-CapExp Parm”:
       1. Explain why the company utilized an EIF which differs from that contained in the latest Phase II Manual - Appendix V filing (Sept 16, 2021) to process “default call routing” after year 1 of the study.
       2. Revise the NG9-1-1 costs to reflect the EIF contained in the company’s latest update to Appendix V.
18. Refer to “Réponse-Response  - 14 January 2022 - TELUS(CRTC)7Feb22-2d_Abridged”:
    1. Refer to the table in part i. of the response:
       1. Refer to row item a) “NG9-1-1 call forecast” and reconcile the annual number of NG9-1-1 calls forecasted within the NG9-1-1 study with the actual 9-1-1 call volumes reflected in “Telus 9-1-1 Annual report pursuant to Telecom Regulatory Policy 2016-165^Footnote23 ABR”. Further, provide the NG9-1-1 call volumes in TELUS’ annual report for each of the years 2019, 2020 and 2021.
       2. If the differences within the data of Question 18) a) i) cannot be reconciled, explain why the proposed annual number of 9-1-1 calls used in the NG9-1-1 study is appropriate and should not be revised.
       3. Refer to the actual 9-1-1 call volumes from “Telus 9-1-1 Annual report pursuant to Telecom Regulatory Policy 2016-165 ABR”. Adjust the annual call volumes for the NG9-1-1 cost study based on the average annual trend in 9-1-1 actual call volumes for the years 2019, 2020 and 2021.
19. Provide a revised NG9-1-1 cost study, along with the revised, related NG9-1-1 costs and rates, for the period 1 March 2022 to 1 March 2027 that incorporates the changes indicated in RFIs 16) c) iii), 17) a) ii) and 18) a) iii). Further provide the present worth of Annualized Cost of the restated costs incurred prior to service launch into capital and expense components referenced in 16 c) iii). Ensure that all formulae demonstrating the calculations and equations are provided, along with all supporting documents, attachments and appendices as applicable.

Section 4 – Questions for Bell

20. Refer to “Bell Canada TN 968 - ATT 1_ABR”:
    1.  Refer to paragraph 131 where the company stated:

       “Historical actual cash flows incurred from the date of TRP 2017-182 up to end of July 2021 have been expressed in 2022 dollars by applying the Bell Canada after tax weighted average cost of capital (AT-WACC) to the costs”

       1. Explain with supporting rationale why the company deviated from the methodology to restate costs indicated in section 1.2.9 (Cost Increase factors and Productivity Improvement factors) of the Manual.
       2. Use the methodology indicated in section 1.2.9 of the Manual to restate the costs incurred prior to service launch with the appropriate application of the CIF, EIF and PIF.
    2. Refer to paragraph 159:
       1. Explain why it is appropriate to include costs incurred as an ONP to interconnect to Bell Canada NG9-1-1 network in the company’s retail rate.
21. Refer to “Réplique - Reply- Bell Canada’s Abridged” (reply comments of Bell Canada TN968 / 968A dated January 17,  2022)
    1. Refer to paragraphs 120 and 121:

       “Telus excluded the portion of the costs that it attributed to other carriers, such as CityWest, with whom it has commercial agreements from its NG9-1-1 cost study… If we were to do a similar adjustment to our costs, in the context of the SILECs we have agreements with as their designated NG9-1-1 provider… our wholesale NG9-1-1 rate of $0.0951 would drop to $0.0942 per line (i.e., or by 1%)…”

       1. Confirm that the revised PWAC of $1,217,169 indicated in footnote 44 is the direct result of the removal of 1% of the PWAC costs.
       2. If the information in Question 21) a) i) cannot be confirmed, provide a corrected revised PWAC.
22. Refer to “Réponse-Response - 14 January 2022 -220207- Bell Canada(CRTC)14Jan22-3 TN 968 - ATT_ABR”:
    1. Refer to row item “Average number of 9-1-1 calls per month” and reconcile the annual number of NG9-1-1 calls forecasted within the NG9-1-1 study with the actual 9-1-1 call volumes reflected in the “Bell Canada -TNC 2016-165^Footnote24 Annual Resiliency Report 2018 ATT ABR”. The response should address how the average number of actual 9-1-1 calls per month for 2018 was estimated as indicated in Step 1^Footnote25 .
       1. If the differences within the data of Question 22) a) cannot be reconciled, explain why the proposed annual number of 9-1-1 calls used in the NG9-1-1 study is appropriate and should not be revised.
    2. Revise the study annual call volumes for the NG9-1-1 cost study based on the average annual trend in 9-1-1 actual call volumes for the years 2019, 2020 and 2021.
23. Provide a revised NG9-1-1 cost study, along with the revised, related NG9-1-1 costs and rates, for the period 1 March 2022 to 1 March 2027 that incorporates the changes indicated in RFIs 20) a) ii), and 22) b). Further provide the PWAC of the restated historic costs into capital and expense components referenced in 20) a) ii). Ensure that all formulae demonstrating the calculations and equations are provided, along with all supporting documents, attachments and appendices as applicable.

Section 5 – Questions for SaskTel

24. Refer to “Réponse-Response - 14 January 2022-220207-SaskTel_Cost_Study_TN373_ App1 NG9-1-1 ABR rev”:
    1. Refer to Table 3
       1. Provide the separate wireline and wireless annual demand for each of the following rows of data:
          1. “SaskTel”;
          2. “WSP” (wireless service providers);
          3. “CLEC” (Competitive local exchange carrier) and;
          4. “All Carriers Demand”
       2. Explain why the WSP and CLEC demand remain unchanged annually throughout the study period, despite paragraph 18 of the study report^Footnote26 , which states:

          “Year-end demand forecasts for SaskTel Wireline, SaskTel Wireless, CLEC, and Wireless Service Providers were developed using SaskTel’s 5-Year Subscriber Forecast and are outlined in Table 3 in Appendix 1.”

       3. Revise the all carrier demand referenced in question 24) a) ii) as required.
25. Refer to “211101 SaskTel_Cost_Study_TN373_NG9-1-1_Att1”:  
    1. Refer to paragraph 38 where it states:

       “…significant causal third-party start-up costs have been amortized over a life estimate of 10 years, with the costs beyond the 5-year study period being excluded from this study.” 

       1. Explain the method used to restate the above costs to the beginning of the study period.
       2. If the methodology used to restate start-up costs is not consistent with section 1.2.9 (Cost Increase factors and Productivity Improvement factors) of the company’s Manual, explain with supporting rationale why the company deviated from the methodology in its Manual.
       3. Restate the costs incurred prior to service launch using the methodology indicated in section 1.2.9 of the Manual (using CIF, EIF and PIF) and provide the revised PWAC of these costs broken down into capital and expense components.
26. Refer to “Réponse-Response 14 January 2022 -220207-SaskTel_Cost_Study_TN373_App2_NG9-1-1_ABR rev”:
    1. Refer to the tabs “Table 6a – Expenses” and “Table 8c - Third-Party Costs”:
       1. Provide the tab names, rows, and column references where the PSAP onboarding and ONP onboarding costs have been included.
       2. Explain how the above costs were estimated, including all calculations and formulae.
    2. Refer to Tab “Table 6d - Revenues”:
       1. As SaskTel has proposed a singular rate for its NG9-1-1 service for retail and wholesale, explain why the annual revenues are estimated using two different rates in the column “Proposed rates” in Item A “Proposed Rates and Projected Revenues”.
27. Refer to “Réponse-Response - 14 January 2022 - SaskTel_CRTC_2_ABR”:
    1. Refer to the table in a) i), “Major Expense Item” 7: “Network Operations Engineering (Ongoing)”, column “Manner in which it supports NG9-1-1 service” where it states:

       “Network Operations is responsible for installation of the required hardware and logical programming of all NG9-1-1 functional elements as well as proactive network monitoring and resolution of troubles…as they arise.”

       1. If the above includes resources associated with the capital required to provide the NG9-1-1 service, provide the file name, tab name, row and column references where the associated capital costs are included in the NG9-1-1 study.
       2. Explain if the maintenance factors used^Footnote27 to estimate maintenance expenses covers proactive maintenance and network monitoring.
       3. Briefly describe the major activities associated with proactive “network maintenance and resolution of troubles” as it relates to the NG9-1-1 network.
28. Provide a revised NG9-1-1 cost study, along with the revised, related NG9-1-1 costs and rates, for the period 1 March 2022 to 1 March 2027 that incorporates the changes indicated in RFIs 24) a) iii), and 25) a) iii). Further provide the PWAC of the restated start-up costs into capital and expense components referenced in 25) a) iii). Ensure that all formulae demonstrating the calculations and equations are provided, along with all supporting documents, attachments and appendices as applicable.

Date modified:

2022-07-18