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

Ottawa, 11 December 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 – Supplemental Request 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 has sought clarification on several issues through requests for information (RFIs) to Bell Canada, the most recent of which was sent 1 October 2024. In response, Bell Canada provided its answers on 23 October 2024.

To supplement the responses previously sought, Bell Canada is to file a response to the RFI set out in Attachment 2 of this letter.

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 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

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)
Quebecor Media Inc., on behalf of Videotron Ltd. (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 Cablodistribution de LIle-aux-Coudres (cabloiac2115@gmail.com)
Coopérative de câblodistribution de Ste-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)

Supplemental Request for Information (RFI)

  1. Refer to Section 3.c) on pages 16-17 of Bell’s cost study report (Attachment 1) titled ‘Cost Study for the Bell Canada Ontario and Quebec Pole Rental Charge – Costing Methodology, Inputs, and Assumptions’.

    In this section, Bell refers to the new web-based IT system and states that specifically, “The new tool will provide a common interface for licensees no matter which Bell region they will be dealing with.”

    1. Clarify whether the new IS/IT system will be applicable to support structures other than poles.
    2. Clarify whether the new IS/IT system will be applicable to support structures outside of the Ontario and Quebec serving areas.
    3. If the new IS/IT system is applicable to other types of support structures and/or support structures outside of the Ontario and Quebec serving areas, explain, with supporting rationale, how the IS/IT costs (including all related ongoing support costs) were allocated to the Ontario and Quebec pole rental charge. Provide an allocation table that demonstrates how the allocation was calculated and the associated costs distributed by type of support structure and serving area, as applicable. Thoroughly explain any methodology and assumptions used to allocate the costs, including all calculations.
    4. If the new IS/IT system is applicable to other types of support structures and/or support structures outside of the Ontario and Quebec serving areas, and the company did not allocate the costs to other support structures and/or serving areas in their proposed rates, provide a revised cost study reflecting only the portion of the IS/IT costs (including all related ongoing support costs) related to poles in the Ontario and Quebec serving areas. Explain, with supporting rationale, how the IS/IT costs (including all related ongoing support costs) are allocated to the Ontario and Quebec pole rental charge and provide an allocation table that demonstrates how the allocation is calculated and the associated costs distributed by type of support structure and serving area, as applicable. Thoroughly explain any methodology and assumptions used to allocate the costs, including all calculations.
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