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Telecom - Staff Letter addressed to Phillipe Gauvin (Bell Canada)

Ottawa, 9 February 2023

Our reference: 8740-B2-202209890

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario, K2P 2C4
bell.regulatory@bell.ca

Subject: Bell Canada Tariff Notice 7660 – Introduction of Network Extension Service

On 15 December 2022, the Commission received an application from Bell Canada, under Tariff Notice (TN) 7660 in which the company proposed changes to Bell Canada’s General Tariff CRTC 6716 to introduce Item 4624 – Network Extension Service.

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 23 February, 2023.

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.

Attach. (1)

Request for Information

  1. Refer to the proposed tariff pages for TN 7660 General Tariff (GT) CRTC 6716 – Item 4624 – Network Extension Service, 4. Rates and Charges, Part (d) which states “Access Local Loop rates and service charges apply to each end of each video transmission circuit”
    1. Confirm the understanding that a typical video transmission circuit represents an “A-end” and “Z-end”, where the “A-end” refers to the originating point of a circuit and the “Z-end” represents the termination point of a circuit – such that two sites are required for a complete circuit. If, in the instance of TN 7660, this is not the intended design of a complete circuit, provide clarification.
  2. Refer to APP - PROPOSED - GROUP B - Bell Canada TN 7660 - APP_ABR
    1. Refer to Tab “Demand Table 3” and clarify if the year-end demand and the Present Worth of demand (PWOD) are expressed in complete circuits (including both the A and the Z end) or per end of a circuit.
    2. Refer to GT Cost Summary Tables 5(a), 5(b), 5(c), 5(d), 5(e), 5(f), 5(g), and 5(h), where results are expressed in units of “$ per circuit per month”
      1. Explain if the cost is specific to each end of the circuit (per site), or applicable to a complete circuit, including both ends.
  3. Based on the response to the above RFI questions, explain how the costs expressed on a “$ per circuit per month” were converted to develop the tariffed rates expressed in APP - PROPOSED- GROUP B – Bell Canada TN 7660 – Tariff Pages ABR, which are provided as “Access Local Loop - Pricing per site”. Provide all assumptions and factors utilized.
  4. Refer to APP - PROPOSED - GROUP B - Bell Canada TN 7660 - ATT (the Study Report), paragraph 29, sub-section “Switching Equipment”, where it states:

“The costs associated with network address translator and data encapsulation equipment and aggregation switches were developed based on explicit actual unit cost.”

  1. Explain, with supporting rationale, why explicit actual unit costs were developed as the appropriate incremental costing methodology to determine the costs of the aforementioned capital components, rather than the capacity costing methodology as indicated in the most recent “Regulatory Economic Studies Manual” (the Manual) filed by the company with the Commission.
  2. Provide the methodology, calculations and assumptions used to estimate the explicit actual unit cost, including the applicable cost driver used to develop the unit cost.
  3. Provide the working fill factor(s) used within the cost calculations for the aforementioned capital components. If the working fill factors used within the cost calculations are not consistent with the working fill factors provided in the Attachment to Appendix V of the Company’s Manual, explain why the working fill factors used within the cost calculations are appropriate.
  4. Explain how the explicit unit costs were adjusted for the different bandwidths (i.e. 1 gigabit per second (Gbps) to 5 Gbps) for full time versus part time use. For illustrative purposes, explain how the explicit unit cost was adjusted for the following, providing the applicable unit cost, assumptions and calculations:
    1. 2 Gbps full time, 2 year minimum contract period ; and
    2. 2 Gbps short duration use for each of 1 day and for 1 month
  5. Are the aforementioned capital components dedicated to this service or can other services utilize these components? If other services can utilize these capital components, provide a list of the affected services.
  1. Provide revised versions of the file APP-PROPOSED - GROUP B - Bell Canada TN 7660 - APP_ABR and APP-PROPOSED - GROUP B - Bell Canada TN 7660 - APP_CONF assuming that the costs associated with network address translator and data encapsulation equipment and aggregation switches are calculated as shared equipment using capacity costs and the cost of advancement consistent with the Manual.

Yours sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation, Telecommunications Sector

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