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

Ottawa, 1 October 2024

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 – Supplemental 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).

On 17 July 2024, Commission staff addressed requests for information (RFIs) to Bell Canada. In response, Bell Canada provided the requested information on 21 August 2024.

To clarify the responses referenced above, Bell Canada is to file responses to the supplemental RFIs set out in Attachment 2 of this letter.

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

• Commission staff requests that Bell Canada submit its respective responses to the attached supplemental requests for information (RFIs) no later than 23 October 2024.
• Parties can submit comments with respect to the response(s) to the attached RFIs, by
  6 November 2024.
• Parties may file replies to the above noted comments by 13 November 2024.

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 in 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
Lauren Purdy, CRTC lauren.purdy@crtc.gc.ca

Attach. (2)

• Distribution List
• Request for Information Questions

Distribution List

Supplemental Requests for Information (RFI)

1. Refer to Bell Canada(CRTC)17Jul24-5 TN 981. Calculate NBV per pole for Ontario poles and NBV per pole for Quebec poles. Provide the methodology, formulae, including the numerator and denominator, and assumptions for this calculation. Explain and provide evidence to support any significant variances in NBV per pole in Quebec versus NBV per pole in Ontario.
2. Provide reasoning for the variance in the average number of third party attachers per pole for Quebec (1.27) and Ontario (1.01). Specifically, explain why the rate is relatively higher in Quebec.
3. Justify how the average number of third party attachers per pole of 1.19 is representative of the average number of third party attachers on Hydro-owned joint use poles?
4. Provide the number of Hydro Quebec poles with third party attachers for which Bell charges a tariff. Provide all supporting calculations, formulae and assumptions.
5. According to Bell’s response in Bell Canada(CRTC)17Jul24-12 TN 981, 165,347 poles in the pole sample did not have third party attachers present. Inversely, 158,964 poles in the sample had at least one third party attacher present. These amounts represent 51.0% and 49.0% of the sample population, respectively.
   1. Explain why applying the 49.0% to the total population of poles to obtain the number of poles with third party attachers would be an inappropriate approach.
6. In Bell’s response Bell Canada(CRTC)17Jul24-6 TN 981, Bell indicates that loss in productivity (LIP) is applicable to spans maintained rather than spans installed.
   1. Provide a methodological justification and rationale for applying LIP calculations to copper and aerial cables placed within Ontario and Quebec.
   2. Provide the number of spans maintained in 2022. If the explicit value is not available, provide an estimate and justify its validity.
   3. Recalculate the LIP costs based on the value obtained in question 6) b).
7. Refer to tab ‘IS-IT’ of the updated cost study submitted in response Bell Canada(CRTC)17Jul24-16 TN 981.
   1. For each type of cost, provide a detailed description of the tasks and time required for completion.
   2. Provide the input values and calculations used to develop each explicit estimate of Bell internal labour.
8. Justify the 100% allocation of costs of the new IS/IT system to third party pole attachers.
9. Provide a revised Appendix 2 cost study, including the associated revised proposed rates and cost information, along with revised, related costs that incorporate any changes due to the above RFI questions. Include all calculations, assumptions, supporting information, and explanations. Ensure that all formulae demonstrating the calculations and equations are provided.

Date modified:

2024-10-01