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

Ottawa, 17 July 2024

Our reference: 8740-B20-202305888

BY EMAIL

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

Subject: Bell Canada Tariff Notice 981 - Changes to Support Structure Service – Ontario and Quebec Pole Rental Unit Rate – Requests for Information

On 16 October 2023, the Commission received an application from Bell Canada proposing updated tariff pages and proposed rates for Bell Canada's National Services Tariff (NST) CRTC 7400 Item 901 – Support Structure Service (Item 901).

Commission staff notes that the analysis is ongoing but additional information is required.

In that respect, the process and associated dates are as follows:

Commission staff notes that its analysis is ongoing and further RFIs may be forthcoming in due course.

All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.

The Commission requires the responses 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.

As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin CRTC 2010-961, 23 December 2010, 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.: Josée Line Gendron, CRTC JoseeLine.Gendron@crtc.gc.ca

Attach. (3)

Distribution List

Bell Canada (bell.regulatory@bell.ca)
Cogeco Communications Inc. (mtl-telecom.regulatory@cogeco.com)
Bragg Communications Incorporated (regulatory.matters@corp.eastlink.ca)
Rogers Communications Canada Inc. (regulatory@rci.rogers.com)
Shaw Cablesystems G.P. (Regulatory@sjrb.ca)
Québecor Média inc., au nom de Vidéotron ltée (regaffairs@quebecor.com)
Independent Telecommunications Providers Association (jonathan.holmes@itpa.ca)
Développement Innovations du Haut-Richelieu (p.lapointe@ihrtelecom.com)
Canadian Communication Systems Alliance (CCSA) (ceo@ccsaonline.ca)
Coopérative de câblodistribution de l’arrière-pays (CCAP) (stephane.arseneau@ccap.coop)
Coopérative de câblodistribution de L’Île-aux-Coudres (cabloiac2115@gmail.com)
Coopérative de câblodistribution de Sainte-Hedwidge (coopcablo1986@gmail.com)
Cooptel (mrocheleau@cooptel.coop)
MRC de Montcalm (nrousseau@mrcmontcalm.com)
Fédération des coopératives de câblodistribution et de télécommunication du Québec (fallaire@ressources.coop)

Requests for Information (RFI)

For the following questions, refer to “Response to Requests for Disclosure - PROPOSED - Bell Canada TN 981 - ATT_APP 2 - REVISED_ABR” dated 8 November 2023 (referenced as the “cost study”).

  1. Refer to the cost study tab “% Communication”. For each of the years 2018 to 2023, complete Tab “RFI #1” of the attached Excel template.
    1. Provide the following:
      1. The number of poles that have a net book value (NBV) = 0 (Fully Depreciated) with the following criteria:
        1. Total Bell owned poles
        2. Bell wholly owned poles
        3. Joint use (JU) poles owned by Bell
      2. The number of poles that have a NBV > 0 with the following criteria
        1. Total Bell owned poles
        2. Bell wholly owned poles
        3. JU poles owned by Bell
      3. The total number of poles with the following criteria
        1. Total Bell owned poles
        2. Bell wholly owned poles
        3. JU poles owned by Bell
        4. JU poles owned by Hydro
        5. Grand Total of all poles.
  2. For each of the years 2018 to 2023, complete Tab “RFI #2” of the attached Excel template.
    1. For Bell owned poles provide
      1. The number of poles in service on 1 January
      2. Poles additions per year
      3. Poles removed per year
      4. The number of poles in service on 31 December
    2. If available, provide a breakdown of pole additions into replacement and growth poles.
  3. For each of the years 2018 to 2023, complete Tab “RFI #3” of the attached Excel template.
    1. For Bell owned poles provide
      1. The number of poles in Ontario
      2. The number of poles in Quebec
      3. The percentage of total poles associated with Quebec poles
  4. Refer to the cost study tab “Calculations” and tab “Depreciation”. For each of the years 2018 to 2023, complete Tab “RFI #4” of the attached Excel template.
    1. For Bell owned poles provide the total value and the value per pole by asset class
      1. The Embedded Cost (book value or original cost)
      2. The Net Embedded Cost (Net book value [NBV])
      3. The Depreciation Expense
  5. Refer to the cost study tab “Calculations”. For each of the years 2018 to 2023, complete Tab “RFI #5” of the attached Excel template.
    1. For Bell owned poles provide the following
      1. NBV associated with Ontario poles
      2. NBV associated with Quebec poles
      3. The percentage of NBV associated with Quebec poles.
  6. Refer to the cost study tab “Table 1” cell C32. In Bell Canada's prospective incremental cost estimates, the company included Loss in Productivity estimates based on the additional work time required because of the presence of licensee cables and equipment.
    1. Explain the calculation adjustment(s) that the company applied within its cost study to avoid counting the Loss in Productivity capitalized costs in both the embedded costs and the incremental costs.
    2. If no adjustment was applied within the company’s cost study, explain how the adjustment should be incorporated.
  7. Refer to the cost study tab “Maintenance”.
    1. Identify if the “Maintenance triggered by SSA pole access seekers (amount of corrective work invoiced to 3rd party attachers which we now have to absorb as per TRP 2023-31)” contains a markup. Provide an explanation for including a markup.
    2. If the “Maintenance triggered by SSA pole access seekers (amount of corrective work invoiced to 3rd party attachers which we now have to absorb as per TRP 2023-31)” contains a markup subtract this amount from the cost study “Maintenance” tab.
    3. For each of the years 2018 to 2023, complete Tab “RFI #7” of the attached Excel template. Provide the historical maintenance cost, categorized by SSA pole access seekers vs. non-SSA, by total and per pole.
  8. Refer to Bell Canada’s response within “NC_2009-432 – Section 5 - Responses to interrogatories - Bell Aliant Regional Communications, Limited Partnership and Bell Canada (the Companies) - Bell_Canada(CRTC)1Mar10-9 c) TNC 2009-432”, dated 17 March 2010, where it stated the following regarding the Revenue Charge:

    “There are three "Other costs" shown on the embedded cost template, namely Joint Use Management, Service Poles not Billed and Warehouse and Distribution.  Joint Use Management is not included in the calculation of the Revenue Charge since the AEC that was developed for Joint Use Management already includes the revenue charge. The Service Poles not Billed is not included in the calculation of the Revenue Charge since this cost is calculated from the capital carrying costs which already include the revenue charge.”

    Refer to the cost study, tab “Table 1” for items “joint-use management”, “pole inspection”, and “vegetation and tree-trimming”.

    1. Explain how the Revenue Charge related to each “joint-use management”, “pole inspection”, and “vegetation and tree-trimming” is captured in this cost study.
    2. If not incorporated, explain how to apply a correction with supporting underlying calculations.
  9. Refer to the cost study, tab “Inspection”.
    1. For each of the years 2013 to 2023, complete Tab “RFI #9” of the attached Excel template and provide the following:
      1. The number of poles replaced due to the inspection program
      2. The percentage of total poles that were replaced due to the inspection program
      3. The percentage of capitalized inspection costs
    2. Comment on the method of derivation of the percentage of capitalized inspection costs. Include all calculations, assumptions, and supporting information and calculations.
  10. Section 2.3 Regulatory Economic Studies for Wholesale Support Structure Services of the Bell Regulatory Economic Studies Manual, paragraph 2-26 provides the formula for calculating % Communication as follows:
    Percent-communication factor calculation
         
    Percent-communication factor for a wholly owned (non joint-use) pole A  
    Percent-communication factor for a joint-use pole B  
    Percentage of joint-use poles owned by a company relative to the total number of joint-use poles owned by both the company and the hydro company C  
    Percentage of joint-use poles owned by a company relative to the total number of joint-use and non-joint-use poles owned by the company D  
    Percentage of joint-use poles that can be accessed by a company related to the total number of joint-use and non-joint-use poles that can be accessed by the company If C = 0, E = 0, otherwise  
    E= (D/C) /
    (1-D + D/C)
    Percent-communication factor for the company F = (1-E)*A + E*B  
    1. Explain why Bell Canada has deviated from this formula when calculating Percent Communication Factor for its cost study on tab “% Communication” cell F14.
    2. Complete Tab “RFI #10” of the attached Excel template and recalculate the Percent Communication Factor using the prescribed formula.
  11. Refer to the cost study, tab “Attachers per pole”
    1. Explain the method of derivation and the source of information for the Average Number of 3rd Party Attachers per Pole values for Ontario, Quebec, and Total in Column E rows 7-9. Include all calculations, assumptions, and supporting information required to substantiate the calculations.
  12. Refer to paragraph 218 of Bell Canada’s reply comments where telecom and utility-owned poles are mentioned as populating the Company’s Pole Datamart.
    1. Using the data available in this database, complete the table on Tab “RFI #12” of the attached Excel template. Provide the information requested as of December 31, 2022. If the data is not available by date, identify the date and provide the most recent data available.
    2. Recalculate the overall average number of attachers per pole where there is competitor presence using a weighted average based on the percentage of total poles. Ensure that all formulae demonstrating the calculations and equations are provided.
    3. Recalculate the overall average percentage of spans with attacher presence based on the following formula:

      Average % of spans with attacher presence = # of poles with attachers ( ( # of poles with attachers ) + ( # of poles with 0 attachers ) )

      Ensure that all formulae demonstrating the calculations and equations are provided.

  13. Refer to the cost study, tab “Loss in Prod 2022”.
    1. Provide the rationale and applicability for the derivation of % spans with Cableco presence.
    2. Using the resulting percentage obtained in question 9 c), recalculate tab “Loss in Prod 2022”.
  14. Refer to the cost study, tab “Loss in Prod 2022”, tab “Admin & Joint Use 2023”, and tab “ISIT”.
    1. Provide the economic cost studies to support the annualized prospective incremental costs associated with loss in productivity costs, administration costs, ISIT costs and additional resources to manage a 3-year program after IS/IT system is implemented resulting in their respective Annual Equivalent Cost (AEC)
    2. Recalculate each of loss in productivity costs, administration costs, ISIT costs, and additional resources to manage a 3-year program after IS/IT system is implemented using the formula:

      AEC = # Billing Units * 12 * Present Worth of Annual Cost Present Worth of Demand

  15. Identify any subsidy amounts included in the cost study that were or will be recovered or funded through various public funding sources or other sources. For any costs recovered or funded as such, identify the source and the amount. If these amounts had not previously been removed from the cost study, explain with supporting rationale why not and adjust the cost study for their removal accordingly.
  16. Provide a revised Appendix 2 cost study, including the associated revised proposed rates and cost information, along with revised, related costs that incorporate the changes indicated in questions 6, 7, 8, 10, 12, 13, 14, and 15. Include all calculations, assumptions, supporting information, and explanations. Ensure that all formulae demonstrating the calculations and equations are provided.
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