Disclosure Telcos CRTC 2010-632

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    5 April 2011 Our Reference: 8638-C12-201016882

    BY E-MAIL

    To Distribution List:

    Re: Follow up to Telecom Regulatory Policy CRTC 2010-632, Wholesale high-speed

    access services proceeding Request for disclosure of costing information filed in

    confidence

    This letter addresses requests for disclosure of information for which a claim of confidentialityhas been made by Bell Aliant Inc. in Ontario and Quebec, and Bell Canada (collectively the Bellcompanies), Bell Aliant Inc. in the Atlantic provinces, MTS Allstream Inc., SaskatchewanTelecommunications and TELUS Communications Company, collectively the incumbent localexchange carriers (ILECs).

    On 18 March 2011, the Canadian Network Operators Consortium Inc. (CNOC) and PrimusTelecommunications Canada Inc. (Primus) each filed requests for disclosure of information forwhich confidentiality had been claimed.

    On 25 March 2011, the ILECs filed with the Commission their responses to the above requestsfor disclosure of information.

    In a letter dated 28 March 2011, the Bell companies filed revisions to their proposed GAS-FTTNservices in order to introduce an aggregated volume pricing (AVP) proposal to replace theirprevious usage-based billing (UBB) model. In attachment to their letter, the Bell companiesprovided new costing information in support of the proposed new pricing structure. The Bellcompanies further indicated that the proposed revised access rates were based on costs whichexclude all usage cost components.

    The Bell companies are asked to confirm whether the 28 March 2011 proposed cost information(including all methodologies and assumptions) associated with the non-usage cost components isthe same as that provided on 11 March 2011. If not, the Bell companies are to provide detaileddocumentation of the changes in costs, methodologies and assumptions, with supportingrationale.

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    The Bell companies are also asked to confirm whether the 28 March 2011 proposed costinformation (including all methodologies and assumptions) for the usage cost components is thesame as that provided on 11 March 2011. If not, the Bell companies are to provide detaileddocumentation of the changes in costs, methodologies and assumptions, with supporting

    rationale.

    Disclosure

    Requests for disclosure of information for which confidentiality has been claimed are addressedin light of sections 38 and 39 of the Telecommunications Actand section 331 of the CanadianRadio-television and Telecommunications Commission Rules of Practice and Procedure (theRules of Procedure). In evaluating a request, an assessment is made as to whether there is anyspecific direct harm likely to result from the disclosure of the information in question. Further, inorder to justify a claim of confidence, any such harm must be sufficient as to outweigh the publicinterest in disclosure. In making this evaluation, a number of factors are taken into consideration,

    including the following:

    The degree of competition that exists in a particular market or that is expected to occur isan important consideration in assessing requests for disclosure. All things being equal,the greater the degree of actual or expected competition, the greater the specific harm thatcould be expected to result from disclosure;

    Another factor in assessing the extent of harm is the expected usefulness of theinformation at issue to parties in furthering their competitive position. In this regard, animportant consideration is the degree to which the information at issue is disaggregated.Generally speaking, the more aggregated the information, the less likelihood that harmwill flow from its disclosure;

    The expectation that specific direct harm might result from disclosure is not, by itself,sufficient to justify maintaining a claim of confidentiality. In certain circumstances,substantial harm from disclosure may still be outweighed by the public interest indisclosure; and

    It should be noted that the treatment of confidentiality requests should not be taken as anindication of the manner in which such matters would be dealt with in the future indifferent circumstances.

    Having regard to all of the considerations set out above, the information filed under a claim ofconfidentiality in response to the interrogatories and cost studies listed in Attachments 1 is, to theextent set out in the Attachment, to be placed on the public record of this proceeding. In eachcase where full or partial disclosure is to occur, it is considered that the specific direct harm, ifany, likely to be caused by disclosure would not outweigh the public interest in disclosure.

    1The new Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure(the

    Rules of Procedure) came into force on 1 April 2011; section 33 of the new Rules of Procedure replaces section 19 ofthe old CRTC Telecommunications Rules of Procedure.

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    Other Matters

    It should be noted that in several interrogatory responses, certain requested information waseither not provided or was incomplete. Accordingly, the ILECs are to revise their responses to

    4 February 2011 and 11 February 2011 interrogatories, and provide responses to reflect thedirections specified in Attachment 2.

    In addition, certain information is being requested which is considered to be important to therecord of this proceeding. The ILECs are each requested to respond to the interrogatoriesincluded in Attachment 3.

    In their responses to Attachments 3, the ILECs are to provide information on the public recordconsistent with the disclosure requirements above.

    Filing Requirement

    As noted above, additional questions are required to assess the additional information providedin response to the 4 February 2011 interrogatories. Accordingly the process is modified to allowadditional time to provide responses to the additional questions identified in attachment 3. TheILECs are accordingly required to provide the information sought in Attachments 1, 2 and 3 by20 April 2011.

    The information to be disclosed by the ILECs, as set out in Attachment 1, or to be provided, asset out in Attachments 2 and 3, is to be filed with the Commission and served on all interestedparties, by 20 April 2011. The information to be provided by the Bell companies regarding anycost changes proposed in their 28 March 2011 submission is also to be filed with theCommission and served on all interested parties by 20 April 2011. The above material must bereceived, not merely sent, by this date. Copies of the documents should also be sent [email protected]

    Yours sincerely,

    Yvan Davidson / forLynne FancyDirector GeneralCompetition, Costing and TariffsTelecommunications

    cc: Yvan Davidson,[email protected] Pag,[email protected]

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    DISTRIBUTION LIST:

    [email protected]; [email protected]; [email protected];[email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected] ; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];

    [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected] ; [email protected];[email protected]; [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected];

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    Attachment 1

    Disclosure of Confidential Information

    The ILECs are to provide on the public record the information that they filed with theCommission in confidence, as set out below:

    Bell Aliant

    Bell Aliant(CRTC)15Sep10-104

    All information

    Bell Aliant(CNOC)11Feb11-3For tables 5a, 5b and 5d of Bell Aliants revised study report filed on 11 March 2011,provide the percentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

    Bell Aliant(CNOC)11Feb11-4

    For tables 5a, 5b and 5d of Bell Aliants revised study report filed on 11 March 2011,provide the percentage of service provisioning calculated as(Service Provisioning PWAC) / (Total PWAC)

    The Companies(Primus)11Feb11-3

    All information in Table 3 of the Bell Aliants study report filed on 10 Dec 2010

    All information in Table 3 of the Bell Aliants revised study report filed on 11 Mar 2011

    The Bell companies

    The Companies(CRTC)15Sep10-104 b) i) and ii)

    2011 Forecasted average usage (GB per month) for each New Wholesale Speed

    Number of retail DSL customers per month used in the study to assess usage

    Increase in the average per end user monthly average traffic volumes and peak periodtraffic levels

    The Companies(CNOC)11Feb11-4

    For tables 5f, 5g, 5h, 5m and 5n of the Bell companies revised study report filed on 11March 2011, provide the percentage of maintenance calculated as

    (Maintenance PWAC) / (Total PWAC) For tables 5a, 5b, 5c, 5d, 5e and 5o of the Bell companies revised study report filed on

    28 March 2011, provide the percentage of maintenance calculated as(Maintenance PWAC) / (Total PWAC)

    The Companies(CRTC)04Feb11-110c)

    All information

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    The Companies(Primus)11Feb11-3

    All information in Table 3 of the Bell companies revised study report filed on 10 Dec2010

    All information in Table 3 of the Bell companies revised study report filed on 11 Mar2011

    MTS Allstream

    MTS Allstream(CNOC)11Feb11-4

    For tables 6.4.5-1 to 6.4.5-9 ofMTS Alstreams revised study report filed on 11 March 2011,provide the percentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

    SaskTel

    Sasktel(CNOC)11Feb11-4

    For tables 20 to 28 of SaskTels revised study report filed on 11 March 2011, provide thepercentage of maintenance calculated as (Maintenance PWAC) / (Total PWAC)

    TELUS

    Telus(CNOC)4Feb11-1 A) 2) and TQ(CNOC)4Feb11-1 A) 2)

    List of equipment for each of the resource types provided in answer to the interrogatory.

    Telus(CRTC)15Oct10-103Average working fill factors

    Telus(Primus)4Feb11-2

    All information in Table 3 of the TELUS study report filed on 10 Dec 2010

    All information in Table 3 of the TELUS revised study report filed on 11 Mar 2011

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    Attachment 2

    Further responses to Interrogatories

    The ILECs are to provide further responses to the interrogatories identified below, to the extentset out below:

    The Bell companies

    The Companies(CRTC)4Feb11-105 Attachment

    Provide on the public record all maximum capacities

    The Companies(CRTC)4Feb11-106

    Provide on the public record all maximum capacities

    MTS Allstream

    MTS Allstream(CRTC)4Feb11-106

    Provide on the public record all maximum capacities

    SaskTel

    Sasktel(CRTC)4Feb11-103A Attachment

    Provide on the public record all maximum capacities and working fill factors

    Sasktel(CRTC)4Feb11-111A AttachmentProvide on the public record all maximum capacities and working fill factors

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    Attachment 3

    Interrogatories

    Aggregated ADSL tariffs: matching speeds - Interrogatories to Bell Aliant (defined to

    include Bell Aliant in the operating territory of the four Atlantic Provinces)

    1. In response to Bell Aliant(CRTC)04Feb11-102, Bell Aliant indicated that the FTTNdevelopment costs should be recovered from all customers regardless if they are retail orwholesale customers. Bell Aliant further provided an estimate of the wholesale share oftotal DSL end-user demand at year-end 2015 that it used to allocate its FTTNdevelopment costs to wholesale ADSL Access Service-FTTN.

    a. Identify all services that make or plan to make use of the FTTN network (e.g.retail Internet, IPTV, GAS-FTTN).

    b. For each of the services identified in a) above, for each of the years 2010 to 2015,provide an estimate of the number of retail end-users.

    c. Provide an estimate of the proportionate share of each services use of the FTTNnetwork. Further provide Bell Aliants views on the appropriateness of assigningthe above noted FTTN development costs to the FTTN related services based onthese proportionate shares.

    2. In response to Bell Aliant(CRTC)04Feb11-113, Bell Aliant provided a revised study with

    a 10 year study period.

    a. Provide a revised table 3 of the attachment to Bell Aliant(CRTC)04Feb11-113

    which shows the demand for all 10 years of the study period.

    b. Using the format of tables 1, 2, 3 and 5 of the cost study and proposed tables of

    Bell Aliant(CRTC)15Sep10-103, provide revised 10 year cost study information

    for each of the following changes in assumptions:

    i. For each year of the study period, apply a CIF of -2% for access driven

    cost components (e.g. DSLAM) and -10% for traffic driven cost

    components (e.g. IP router).

    ii. For each year of the study period, apply a CIF of -5% for access driven

    cost components (e.g. DSLAM) and -15% for traffic driven cost

    components (e.g. IP router).

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    c. Comment on the extent to which equipment capacity for traffic driven cost

    components are increased over time to satisfy higher traffic demand without

    significantly increasing the overall provisioning costs per end-user and thereby

    causing significant decreases in unit cost per peak hour Kbps for this category of

    costs.

    3. Refer to response to Bell Aliant(CRTC)04Feb11-201. For each of the Service Order,

    Cross-connect at DSLAM and Customer Premises Work sub-activities, identify the

    associated method, measurement and/or tracking system used to determine the proposed

    time estimate.

    4. For each of retail and wholesale, in situations where a POTS splitter is already installed

    and a line optimization and testing has already been performed, explain if and why a

    truck roll would be required when a customer requests ADSL Access Service-FTTN;

    further provide an estimate of the percentage of time where a POTS splitter is already

    installed and a line optimization and testing has already been performed as (i) at the start

    of the study period and (ii) at the end of the study period, with supporting rationale.

    5. In response to Bell Aliant(CRTC)04Feb11-204, the company indicated that a truck roll is

    not required in the case of subsequent speed upgrades on an existing access line which do

    not require use of a VDSL modem or reconfiguration of an existing VDSL modem or

    where the ADSL Access Service-FTTN customer has provided and installed its own

    modem.

    Provide the percentage of time that subsequent speed upgrades were assumed to require atruck roll, with supporting rationale.

    6. In response to Bell Aliant(CRTC)04Jan11-1, Attachment, the company provided the time

    estimate for the sub-activity Technician performing on-site testing and line optimization

    at customer premises. Provide a further breakdown of activities performed for this sub-

    activity, identifying the associated minutes, with supporting rationale.

    7. Refer to SaskTel(CRTC)4Feb11-201

    a. Comment with supporting rationale on SaskTels proposal to remove serviceestablishment activity costs that are common to both the VDSL Access service

    and the Dry Loop or Unbundled Loop service such as costs for Service Call

    Taking, Service Call Problem Resolution and Assignment from its VDSL Service

    connection costs when provisioned with either a Dry Loop or Unbundled Loop in

    order to avoid double recovery of these costs. Further, identify Bell Aliants

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    activities that are common to both the provision of the companys ADSL Access-

    FTTN service and Dry Loop or Unbundled Loops.

    b. Explain, with supporting rationale, if and why Bell Aliants activities identified in

    response to a) above cannot be performed at the same time if both ADSL

    Access-FTTN Service and Dry Loop or Unbundled Loop services are required at

    the time of the ISP request; further comment on the expected cost efficiencies and

    reductions if the service establishment activities for both ADSL Access-FTTN

    service and Dry Loops or Unbundled Loops are provisioned at the same time,

    identifying the activities which would be subject to cost efficiencies.

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    Aggregated ADSL tariffs: matching speeds - Interrogatories to Bell Canada (defined to

    include Bell Canada and Bell Aliant in the operating territory of Ontario and Quebec)

    1. In response to The Companies(CRTC)15Sep10-105 b) i) Revised Update, the Bell

    companies provided estimates of percentage trouble tickets per end user per year for helpdesk activities. In response to The Companies(CRTC)28May10-8 TNs 269 & 7205, theBell companies indicated that 7.08% of all copper-related trouble tickets were directlyattributable to DSL service.

    a. Explain why the Bell companies are proposing a methodology to estimate helpdesk costs which is different from that employed in the TN 269\7205 proceeding.

    b. Provide a revised estimate of the help desk costs based on the methodology usedin TN 269\7205 and adjusted as per Telecom Decision 2011-24 determinations.

    2. In response to The Companies(CRTC)04Feb11-101, the Bell companies indicated thatthe network conditioning activities are performed for the FTTN service as a whole andthat since both retail customers and wholesale end-users ultimately benefit from thesenetwork conditioning activities, the network conditioning costs should be recovered fromboth retail and wholesale customers.

    In response to The Companies(CRTC)04Feb11-103, the Bell companies indicated thatthe initial business plan to develop FTTN-based services was premised on the expectationthat there would be recovery of the up-front investment from the entire base of futureend-users and not just a portion thereof.

    In response to The Companies(CRTC)15Sep10-102, the Bell companies provided anestimate of the wholesale share of total residential DSL end-user demand at year-end2015 that it used to allocate its network conditioning and FTTN development costs towholesale GAS-FTTN.

    a. Identify all services that make or plan to make use of the FTTN network (e.g.retail Internet, IPTV, GAS-FTTN).

    b. For each of the services identified in a) above, for each of the years 2010 and2015, provide an estimate of the number of retail end-users.

    c. Provide an estimate of the proportionate share of each services use ofthe FTTNnetwork. Further provide the Bell companies views on the appropriateness of

    assigning the above noted FTTN development and network conditioning costs tothe FTTN related services based on these proportionate shares.

    3. Refer to The Companies(CRTC)04Feb11-201, Attachment 2, where the Bell companies

    have identified external vendor fees and the use of Bell Technical Solutions (BTS)

    technicians.

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    a. Confirm that BTS was formerly called Entourage Technology Solutions, and that

    BTS is currently a wholly owned subsidiary of Bell Canada Enterprises.

    b. Identify the duration of the current contract with BTS to perform installation

    activities, including the expected renewal date of the contract.

    c. Indicate whether the external vendor fees provided in the response included the

    Ontario Provincial Sales Tax. If so, provide a revised proposed table in The

    Companies(CRTC)04Feb11-201, Attachment 2 and further revised proposed

    tables 5m and 5n of the Bell companies revised Economic Evaluation Report

    filed 11 March 2011, to reflect the exclusion of this tax.

    d. Confirm that the costs for VDSL modems are not recovered through the GAS-

    FTTN rates. If so, explain with supporting rationale, why a portion of the truckroll required for testing and optimization of the lines for all new FTTN orders

    should not be attributed to the installation of VDSL modems; further provide a

    proportion of the truck roll costs that should be attributed to VDSL modems.

    4. Refer to the response to The Companies (CRTC)04Feb11-201, Attachments 1 and 2.

    a. In response to The Companies(CRTC)04Feb11-116, the Bell companies indicated

    that for all new FTTN customers, a truck roll to the customer premises occurs in

    order for technicians to perform testing and line optimization at the customer

    premises. The Bell companies also stated that at that time, the technician mayalso install a POTS splitter at the customer premises.

    i. Identify the proportion of the cost of this truck roll that is attributed to

    each of the monthly and service charge rate elements, with supporting

    rationale.

    ii. Explain how the proportion of the truck roll cost attributed to the service

    charge is reflected in Attachment 2 of The Companies (CRTC)04Feb11-

    201(showing the derivation of the associated vendor fee and occurrence

    rate, including all supporting assumptions). The response should provide

    the external vendor fee for this truck roll and should confirm that this fee

    provided in Attachment 2 reflects the external vendor fee charged to the

    Bell companies, as adjusted to remove the portion of the truck roll

    activity assigned to POTS splitters.

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    iii. Explain whether the Bell companies incur a similar truck roll, with

    similar occurrence rates and external vendor fee, for their retail FTTN

    Internet services, with supporting rationale for any differences.

    b. In response to The Companies(CRTC)04Feb11-116, the Bell companies further

    indicated that the same truck that has been sent to the customer premises to

    perform testing and line optimization may also go on to visit the remote DSLAM

    site serving that customer in order to perform field work at that remote

    i. Confirm that this additional visit to the remote DSLAM site represents

    an additional truck roll activity which implies additional costs over and

    above those associated with the truck roll identified in part a) above.

    ii. Explain how the truck roll cost associated with the additional visit to theremote DSLAM site is reflected in Attachment 2 of The Companies

    (CRTC)04Feb11-201(showing the derivation of the associated vendor

    fee and occurrence rate, including all supporting assumptions). The

    response should provide the External Vendor Fee charge to the Bell

    companies for this type of truck roll.

    iii. Explain whether the Bell companies incur a similar truck roll, with

    similar occurrence rates and external vendor fee, for their retail FTTN

    Internet services, with supporting rationale for any differences.

    c. In light of the responses to parts a) and b) above, confirm that the Bell companies

    have assumed that a GAS-FTTN order would cause them to require one truck roll,

    but would cause them to incur, on average, more than one vendor fee associated

    with this truck roll. If so, given the high frequency of occurrence for these two

    vendor fees, explain, with supporting rationale, whether the Bell companies

    intend to re-negotiate this part of the vendor contract to reduce its truck roll costs;

    further explain whether this frequency of occurrence is expected to decline over

    time, and further provide the expected frequency of occurrence in the first and last

    years of the study, with supporting rationale.

    d. Provide the Bell companies best estimate of the traveling time for each of the two

    truck roll activities identified in parts a) and b) above.

    5. For each of retail and wholesale, in situations where a POTS splitter is already installed

    and a line optimization and testing has already been performed, explain if and why a

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    truck roll would be required when a customer requests FTTN service; further provide an

    estimate of the percentage of time that a POTS splitter is already installed and a line

    optimization and testing has already been performed as (i) at the start of the study period

    and (ii) at the end of the study period, with supporting rationale.

    6. Refer to the response to The Companies (CRTC)04Feb11-201, Attachment 2. Provide the

    assumptions, with supporting rationale, used to develop the Sales Management cost

    estimate for Business office activities, reflected in the Actual Expenditures (or Spend)

    for Sub-activity column.

    7. In response to The Companies (CRTC)04Feb11-206, the Bell companies indicated that a

    truck roll is not required in the case of subsequent speed upgrades which do not require

    use of a VDSL modem or reconfiguration of an existing VDSL modem, such as when a

    speed other than 25 Mbps has been selected without the optional 7 Mbps upload speed, or

    where the FTTN customer is providing and installing its own modem.

    Provide the percentage of time that subsequent speed upgrades were assumed to require a

    truck roll, with supporting rationale.

    8. In response to The Companies(CRTC)04Feb11-117, the Bell companies provided a

    revised study with a 10 year study period.

    a. Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of the

    response to The Companies(CRTC)15Sep10-103, provide revised 10 year cost

    study information and proposed revised rates per end-user for each of thefollowing changes in assumptions:

    i. For each year of the study period, apply a CIF of -2% for access driven

    cost components and -10% for traffic driven cost components.

    ii. For each year of the study period, apply a CIF of -5% for access driven

    cost components and -15% for traffic driven cost components.

    b. For access driven cost components, derive and provide the average annual change

    in DSLAM Alcatel 7300 equipment unit cost per end-user from 2006 to 2010, as

    derived from the information provided in the response to The

    Companies(CRTC)04Feb11-109. Further explain how the average annual change

    in DSLAM Alcatel 7300 equipment unit cost per end-user was derived from the

    information provided in the response, with supporting rationale.

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    c. For traffic driven cost components, derive and provide the average annual change

    in IP router unit cost per Kbps for peak hour from 2006 to 2009, as derived from

    the information provided in the response to The Companies(CRTC)04Feb11-109.

    Further explain how the average annual change in IP router unit cost per Kbps for

    peak hour was derived from the information provided in the response, with

    supporting rationale.

    d. Comment on the extent to which equipment capacity for traffic driven cost

    components are increased over time to satisfy higher traffic demand without

    significantly increasing the overall provisioning costs per end-user and thereby

    causing significant decreases in unit cost per peak hour Kbps for this category of

    costs.

    9.

    Refer to SaskTel(CRTC)4Feb11-201.

    a. Comment with supporting rationale on SaskTels proposal to remove service

    establishment activity costs that are common to both the GAS-FTTN Access

    service and the Dry Loop or Unbundled Loop service such as costs for Service

    Call Taking, Service Call Problem Resolution and Assignment from its VDSL

    Service connection costs when provisioned with either a Dry Loop or Unbundled

    Loop in order to avoid double recovery of these costs. Further, identify the

    Companies activities that are common to both the provision ofthe Companies

    GAS-FTTN Access service and Dry Loop or Unbundled Loops.

    b. Explain, with supporting rationale, if and why the Companies activities identified

    in response to a) above cannot be performed at the same time if both GAS-FTTN

    Access service and Dry Loop or Unbundled Loop services are required at the time

    of the ISP request; further comment on the expected cost efficiencies and

    reductions if the service establishment activities for both GAS-FTTN Access

    service and Dry Loops or Unbundled Loops are provisioned at the same time,

    identifying the activities which would be subject to cost efficiencies.

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    Aggregated ADSL tariffs: matching speeds - Interrogatories to MTS Allstream

    1. Refer to the companys response to MTS Allstream(CRTC)15Sep10-103, where thecompany provided IFC per Access as well as the PWAC for the Fibre Umbilical

    Buried Fibre Cable associated with the V-AHSSPI services. Further refer to thecompanys response to MTS Allstream(CRTC)15Sep10-103 Revised, where thecompany provided revised costs for the buried fibre cable.

    a. Provide the methodology and assumptions used to estimate the revised IFC perAccess for the Buried Fibre Cable component associated with the 100 Mbps V-AHSSPI service.

    b. Explain the differences in costing methodology and/or assumptions between theburied fibre cable costs provided in response to MTS Allstream(CRTC)15Sep10-103Revised and those provided in MTS Allstream(CRTC)15Sep10-103, with supporting

    rationale.

    2. At paragraph 17 of its cost study report updated 11 March 2011, MTS Allstreamindicated that the Phase II capital costs have been adjusted to reflect capital and expenseincrease factors and productivity improvements in each year of the study starting in 2011and ending in 2015. MTS Allstream also provided, in table 6.5.2, the capital increasefactors used for each account code.

    a. Identify which account code applies to the DSLAM All Equipment component ofVDSL access service. Further identify the changes in capacity and cost per accessfor DSLAM All Equipment over the last five years; further comment on theappropriateness of using the corporate average CIF proposed for DSLAM AllEquipment over the study period.

    b. Identify which account code applies to the cabinet component of VDSL accessservice. Further identify the changes in capacity and cost per access for cabinetequipment over the last five years; further comment on the appropriateness ofusing the corporate average CIFs proposed for cabinet equipment over the studyperiod.

    c. Identify which account code applies to the Internet computers hardwarecomponent for the V-AHSSPI services. Further identify the changes in capacityand cost per access for Internet computers hardware over the last five years;further comment on the appropriateness of using the corporate average CIFproposed for Internet computers hardware over the study period.

    3. In its revised economic study filed 11 March 2011, MTS Allstream used a 5 year studyperiod for the costs causal to demand and a 10 year study period for its costs causal toservice.

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    a. For each of VDSL access service and the three V-AHSSPI services, provide arevised proposed cost study which reflects a study period of 10 years. Theresponse should include revised proposed tables 6.4.5-1 to 6.4.5-9 as provided inAppendix 1 of Attachment 1 of the cost study report, and revised proposed tables

    of MTS Allstream(CRTC)15Sep10-103 and 105. The response should alsoidentify, with supporting rationale, any change in methodology or assumptions.Further comment on the appropriateness of the use of a 10 year study period.

    b. Using the format of tables 6.4.5-1 to 6.4.5-9 of the cost study, and tables of theresponses to MTS Allstream(CRTC)15Sep10-103 and 105, for the VDSL accessservice, provide revised 10 year cost study information and proposed revised ratesper end-user for each of the following changes in assumptions:

    i. For each year of the study period, apply a CIF of -2% for all equipmentsand facilities.

    ii. For each year of the study period, apply a CIF of -5% for all equipmentsand facilities.

    c. Using the format of tables 6.4.5-1 to 6.4.5-9 of the cost study, and tables of theresponses to MTS Allstream(CRTC)15Sep10-103 and 105, for the three V-AHSSPI services, provide revised 10 year cost study information and proposedrevised rates per end-user for each of the following changes in assumptions:

    i. For each year of the study period, apply a CIF of -10% for allequipments and facilities.

    ii. For each year of the study period, apply a CIF of -15% for allequipments and facilities.

    The response should include revised proposed tables 6.4.5-1 to 6.4.5-9 asprovided in Appendix 1 of Attachment 1 of the cost study report of the coststudy, and revised proposed tables of MTS Allstream(CRTC)15Sep10-103 and105.

    d. Comment on the extent to which equipment capacity for traffic driven costcomponents are increased over time to satisfy higher traffic demand withoutsignificantly increasing the overall provisioning costs per end-user and therebycausing significant decreases in unit cost per peak hour Kbps for this category ofcosts.

    4. Refer to the companys responses to MTS Allstream(CRTC)4Feb11-106 Revised, wherethe company has provided IFC per 100 Mbps V-AHSSPI service associated with variouscomponents of the dedicated 1 GB port on 7450 to Competitors equipment.

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    a. Provide a diagram showing how the following four components are connected: (i)7450 ESS 12 SLOT DC 400G BUNDLE, (ii) 7450 ESS SFM 2 400G, (iii) IOM 7450 ESS-6/7/12 IOM-20G, and (iv) 7450 ESS 10-port GigE MDA-B no opt.Further provide a brief description of the purpose and function of each of theabove components.

    b. Confirm that a 1 GB dedicated interface is required to provide a 100 Mbps V-AHSSPI service and that this would result in under utilization of the 1 GBdedicated interface. If so, explain why.

    c. Provide the companys view, with rationale, on providing two distinct tariffcomponents for the V-AHHSPI interface consisting of (i) resources related todedicated port and (ii) resources related to the shared ports.

    5. Refer to the companys responses to MTS Allstream(CRTC)15Sep10-106 and MTSAllstream(CRTC)4Feb11-111.

    a. With regard to the description of the activities provided by the company in part b)of MTS Allstream(CRTC)4Feb11-111, explain why an Outward: IPMP - Orderfulfillment activity requires activities such as creating the VLAN, configuringthe VLAN and testing the operation.

    b. With regard to the Outward: Facilities Management Issue Order activityprovided by the company, explain with supporting rationale why this activity is aone-time activity specific to each outward movement of VDSL Access service. Ifthis activity is not specific to each VDSL Access outward movement, providesupporting rationale as to why the cost associated with this activity is viewed tobe incremental to the outward movement of the service.

    6. Refer to the companys responses to MTS Allstream(CRTC)15Sep10-106 where thecompany provided the frequencies and Unit Costs for various Recurring activities

    associated with trouble reports. Also refer to part d) of MTS Allstream(CRTC)4Feb11-111 VDAS where the company provided the percentage of trouble tickets based on thecompanys retail VDSL Data Access service.

    a. Confirm that the Expenses causal to demand Service Provisioning expensesshown in Table 6.4.5-1 of the companys revised Economic Evaluation studyreport was derived based on the Outward and Recurring cost elements

    identified in MTS Allstream(CRTC)15Sep10-106.

    b. Provide the calculations showing how the company derived the PWAC for VDSLAccess - Expenses causal to demand Service Provisioning as shown in Table6.4.5-1 of the companys revised Economic Evaluation study report, using thewholesale in-service demand data for the VDSL Data Access service as well asthe percentage of trouble tickets based on the companys retail VDSL Data

    Access service as provided in part d) of MTS Allstream(CRTC)4Feb11-111.

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    7. Refer to the companys responses to MTS Allstream(CRTC)15Sep10-106, where thecompany has provided the time estimates and unit costs for various V-AHSSPI Inward,Outward and Recurring activities.

    a. For each of the companys 100 Mb, 400 Mb and 1 Gb V-AHSSPI interfaces,

    provide the Inward and Outward demand for the years 2011 to 2020

    b. Explain why the time estimates provided for the various Inward and Outwardactivities (e.g., IP Traffic Configuration / De-configuration, FacilitiesManagement Issue Order, and IPMP Order Fulfillment) associated with the V-AHSSPI service are the same, given that, unlike Inward movement, the interfaceand connections for Outward movement already exist.

    c. Explain, with supporting rationale, how the time estimates for the Inward andOutward sub-activities were derived.

    8. Refer to the companys response to MTS Allstream(CRTC)15Sep10-105, where thecompany provided Vendor Support PWAC associated with the maintenance expensecausal to demand for the VDSL access as well as the interface services.

    Provide the calculations used to estimate the annual maintenance Vendor Supportcashflows used to derive the PWAC for the 1000 Mbps V-AHSSPI interface serviceprovided in this interrogatory response. The response should show the values andsources of the unit cost and demand information used as well as all assumptions, withsupporting rationale.

    9. Refer to the response to MTS Allstream(CRTC)4Feb11-205, Attachment 1, where MTSAllstream provided, by major activity, LUCs and time estimates for V-AHSSPI andAHSPPI as well as VDSL and ADSL access service charges. Explain, with supportingrationale, the changes in time estimates between (i) V-AHSSPI and AHSPPI and (ii)VDSL and ADSL access service charges. Further explain whether there are changes otherthan those related to changes in LUCs and time estimates that have contributed to thechanges in service charge costs; if so, identify each of these changes, with supportingrationale.

    10.Refer to the response to MTS Allstream(CRTC)4Feb11-202.

    a. For V-AHSSPI service charge, provide a description for each of the followingmajor activities: broadband coordinator-order coordination; IP traffic-designnetwork order; Facilities management-design and issue orders; IPMP(TECNET)-configure the network; and CO Tech

    b. For VDSL service charge, provide a description for each of the following majoractivities: IPMP(TECNET)-configures subscriber to network; Facilitiesmanagement-design and issue orders; Assignment-records management;

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    Workforce controller- dispatch FSTs; Co expediter-dispatch for CO techs; COTech; FST-Wire cabinet, Cut endtap, test; FST replace drop; and FST-Install NID.

    11.Refer to the response to MTS Allstream(CRTC)04Feb-204. Provide the Occurrence ratesfor each sub-activity for each of National Account representative-Customer's point of

    contact activity and the CSG Systems Engineering- Tech Sales support activity, withsupporting rationale.

    12.Refer to SaskTel(CRTC)4Feb11-201

    a. Comment with supporting rationale on SaskTels proposal to remove service

    establishment activity costs that are common to both the VDSL Access service

    and the Dry Loop or Unbundled Loop service such as costs for Service Call

    Taking, Service Call Problem Resolution and Assignment from its VDSL Service

    connection costs when provisioned with either a Dry Loop or Unbundled Loop in

    order to avoid double recovery of these costs. Further, identify MTS Allstreams

    activities that are common to both the provision of VDSL Access service and Dry

    Loops or Unbundled Loops.

    b. Explain, with supporting rationale, if and why MTS Allstreams activities

    identified in response to a) above cannot be performed at the same time if both

    VDSL Access service and Dry Loop or Unbundled Loop services are required at

    the time of the ISP request; further comment on the expected cost efficiencies and

    reductions if the service establishment activities for both VDSL Access service

    and Dry Loops or Unbundled Loops are provisioned at the same time, identifying

    the activities which would be subject to cost efficiencies.

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    Aggregated ADSL tariffs: matching speeds - Interrogatories to SaskTel

    1. In its response to SaskTel(CRTC)4Feb11-107, SaskTel stated that it assumed that afirmware upgrade is required on an annual basis and requires a 1 hour customer premises

    visit.

    a. Explain, with supporting rationale, whether Sasktel plans to also do annual visitsto its retail customer premises to perform a firmware upgrade on an annual basis.

    b. Explain, with supporting rationale, whether the firmware upgrades couldeventually be done on a remote basis or required on a less frequent basis as theproduct matures.

    c. Explain, with supporting rationale, what would happen if the firmware upgradeswere done on an as required basis and provide an estimate of the revised cost per

    access for this activity under this approach.

    2. With reference to SaskTel(CRTC)15Sep10-103, confirm that there is no double countingof capital expenditures for the following IP Core items:

    a. Page 2 of 5: IP Core costs (Transport) described as This equipment includestraffic driven costs connecting redundant trunks between SaskTel IP Core EdgeRouter and SaskTel IP Core Router.

    b. Page 3 of 5: IP Core costs described as This equipment is used to connect andaggregate DSLAM traffic and includes costs for connecting redundant trunks toSaskTel IP Core Edge Routers.

    If not, explain why not.

    3. With reference to SaskTel(CRTC)15Sep10-103 and Attachment toSaskTel(CRTC)4Feb11-103 interrogatory response, explain the discrepancy in theDSLAM port costs per access between the two responses.

    4. With reference to SaskTel(CRTC)15Sep10-103, for each of the Installed First Costs(IFCs) associated with IP Core equipment, provide a detailed breakdown of the IFC peraccess into the following components:

    a. Material cost (specify equipment)b. Engineeringc. Installationd. Other (specify)

    The answer should identify the WFF and the capacity of each equipment.

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    5. Refer to the response to SaskTel(CRTC)4Feb11-204 h). Provide the requested estimate ofthe percentage of existing loops with bridge taps or load coils, identifying the source andvintage of the data.

    6. Refer to the response to SaskTel(CRTC)4Feb11-204 i) where SaskTel indicated thatcertain inside wiring work occurs 100% of the time and other inside wiring work occurs50% of the time. Provide the list of inside wiring work activities that occur 100% of thetime and the time estimate for each of these activities.

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    Aggregated ADSL tariffs: matching speeds - Interrogatories to Telus

    1. In response to Telus(CRTC)4Feb11-105, Telus provided the IFCs for ATM PVC and

    Gigabit Ethernet per Mbps that were used to calculate its transport costs. For each of thefirst and last year of the study, provide the assumed proportions of ATM PVC andGigabit Ethernet used to calculate the final costs for transport, with supporting rationale.

    2. In response to Telus(CRTC)4Feb11-116, Telus indicated that it does not include usage-based billing in its tariff. Confirm that there are costs which are driven by traffic demand(e.g. ATM PVC) regardless of whether the company offers usage-based billing. Providethe cost per GB of usage per month for those costs that are driven by traffic demand only.

    3. In response to Telus(CRTC)4Feb11-115, Telus provided revised proposed cost studiesfor a 5 and 10 year study period for the Alberta and British Columbia territories. For

    Telus operating territory of Quebec, provide revised proposed cost studies (tables 1, 2, 3and 5) for all of Telus proposed matching speed services reflecting a study period of 5years. If Telus is unable to provide the requested information in the requested timeframe,comment on the use of the 5 year cost study sensitivity information of Alberta and BritishColumbia as a proxy.

    4. With reference to service provisioning expenses, in response to Telus(CRTC)4Feb11-108, Telus stated that the source data for the service provisioning unit cost is the ABC byproduct study which is created by assigning costs from the SAP system to products andprocesses. Explain whether the cost driver used to develop the estimate of serviceprovisioning expenses was inward demand. If not, provide revised cost estimates forprovisioning expenses based on inward demand, including all supporting costassumptions.

    5. With reference to Telus(CRTC)15Oct10-103, for each of BRAS/Aggregation and ATMPVC (Gigabit Ethernet) unit costs, provide a detailed breakdown into the followingcomponents:

    a. Material cost (specify equipment)b. Engineeringc. Installationd. Other (specify)

    The answer should identify the WFF and the capacity of each equipment.

    6. On 15/16 March 2011,Telus provided a revised cost study (with a 3 year study period).Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of Attachments 1 toTELUS(CRTC)15Oct10-103 and TELUS(CRTC)4Feb11-101A, provide revised 3 year

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    b. Explain, with supporting rationale, if and why the above-noted activities cannotbe performed at the same time if both WIAS and Dry Loop or Unbundled Loopservices are required at the time of the ISP request.

    c. Comment with supporting rationale on SaskTels proposal in its response to

    SaskTel(CRTC)4Feb11-201 to remove service establishment activity costs thatare common to both the VDSL Service and the Dry Loop or Unbundled Loopservice such as costs for Service Call Taking, Service Call Problem Resolutionand Assignment from its VDSL Service connection costs when provisioned witheither a Dry Loop or Unbundled Loop in order to avoid double recovery of thesecosts. Further, identify TELUS activities that are common to both the provisionof WIAS and Dry Loop or Unbundled Loops.

    10.Refer to Telus(CRTC)4Feb11-204 b) where Telus indicated that the timing estimates arebased on its experience with the activities and that the timing estimates are the same forwholesale and retail service.

    d. For each of the Order Entry, Update and Correction activities, explain, withsupporting rationale, why the timing estimates are the same for wholesale andretail service in light of the fact that retail services require additional task to beperformed (e.g. need to create / update / correct a Yellow Pages listing for retailbusiness customers, add / update / correct other services being ordered at the sametime by the retail customers, time spent by service representatives in selling otherservices to the retail customers while taking the order).

    e. For each of Order Entry, Update and Correction activities, further providerevised time estimates in light of the response to part a) above, with supportingrationale.

    11.Refer to Telus(CRTC)4Feb11-204 e). Explain with supporting rationale why the LoopQualification activity would be required for the 1.5 Mbps to 6 Mbps WIAS service. If theLoop Qualification activity would not be required, comment on the use of a differentservice charge rate for this service, based on the different service charge costs.

    12.Refer to Telus(CRTC)4Feb11-206 where Telus indicated that the proposed tariff forWholesale Internet ADSL service does not include a monthly payment option for the 15Mbps and 25 Mbps services. Further refer to Telus proposed Tariff page 226-7A, note 2b) indicates that service providers can elect to pay an amount of $3.00 per month; further,in its proposed Tariff page 226-7, note 2 (i.e. monthly payment option) indicates that thisamount is applicable to the 15 Mbps and 25 Mbps services. Explain the discrepancy.