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 confidentiality
has been made by Bell Aliant Inc. in Ontario and Quebec, and Bell Canada (collectively the Bell
companies), Bell Aliant Inc. in the Atlantic provinces, MTS Allstream Inc., Saskatchewan
Telecommunications and TELUS Communications Company, collectively the incumbent local
exchange carriers (ILECs).

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

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

In a letter dated 28 March 2011, the Bell companies filed revisions to their proposed GAS-FTTN
services in order to introduce an aggregated volume pricing (AVP) proposal to replace their
previous usage-based billing (UBB) model. In attachment to their letter, the Bell companies
provided new costing information in support of the proposed new pricing structure. The Bell
companies further indicated that the proposed revised access rates were based on costs which
exclude 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 is
the same as that provided on 11 March 2011. If not, the Bell companies are to provide detailed
documentation of the changes in costs, methodologies and assumptions, with supporting
rationale.
 2

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

Disclosure

Requests for disclosure of information for which confidentiality has been claimed are addressed
in light of sections 38 and 39 of the Telecommunications Act and section 331 of the Canadian
Radio-television and Telecommunications Commission Rules of Practice and Procedure (the
Rules of Procedure). In evaluating a request, an assessment is made as to whether there is any
specific direct harm likely to result from the disclosure of the information in question. Further, in
order to justify a claim of confidence, any such harm must be sufficient as to outweigh the public
interest 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 is
an 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 that
could be expected to result from disclosure;

Another factor in assessing the extent of harm is the expected usefulness of the
information at issue to parties in furthering their competitive position. In this regard, an
important consideration is the degree to which the information at issue is disaggregated.
Generally speaking, the more aggregated the information, the less likelihood that harm
will 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 in
disclosure; and

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

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

1
The 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 of
the old CRTC Telecommunications Rules of Procedure.
 3

Other Matters

It should be noted that in several interrogatory responses, certain requested information was
either 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 the
directions specified in Attachment 2.

In addition, certain information is being requested which is considered to be important to the

record of this proceeding. The ILECs are each requested to respond to the interrogatories
included in Attachment 3.

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

Filing Requirement

As noted above, additional questions are required to assess the additional information provided
in response to the 4 February 2011 interrogatories. Accordingly the process is modified to allow
additional time to provide responses to the additional questions identified in attachment 3. The
ILECs are accordingly required to provide the information sought in Attachments 1, 2 and 3 by
20 April 2011.

The information to be disclosed by the ILECs, as set out in Attachment 1, or to be provided, as

set out in Attachments 2 and 3, is to be filed with the Commission and served on all interested
parties, by 20 April 2011. The information to be provided by the Bell companies regarding any
cost changes proposed in their 28 March 2011 submission is also to be filed with the
Commission and served on all interested parties by 20 April 2011. The above material must be
received, not merely sent, by this date. Copies of the documents should also be sent to
richard.page@crtc.gc.ca.

Yours sincerely,

Yvan Davidson / for

Lynne Fancy
Director General
Competition, Costing and Tariffs
Telecommunications

cc: Yvan Davidson, yvan.davidson@crtc.gc.ca

Richard Pagé, richard.page@crtc.gc.ca
 4

DISTRIBUTION LIST:

regulatoryaffairs@nwtel.ca; bell.regulatory@bell.ca; reglementa@telebec.com;

iworkstation@mtsallstream.com; regulatory@bell.aliant.ca;
Regulatory.Matters@corp.eastlink.ca; Regulatory@sjrb.ca; marcel.mercia@cybersurf.com;
reglementation@xittel.net ; regulatory@distributel.ca; lisagoetz@globalive.com;
regulatory@primustel.ca; telecom.regulatory@cogeco.com; regaffairs@quebecor.com;
ken.engelhart@rci.rogers.com; regulatory.affairs@telus.com; crtc@mhgoldberg.com;
eric@rothschildco.com; gfletcher@incentre.net; berzins@nucleus.com;
babramson@mccarthy.ca; regulatory@execulink.com; ctacit@tacitlaw.com; abriggs@cogeco.ca;
slavalevin@ethnicchannels.com; crtc@les.net; LBC_Consulting@live.ca;
andre.labrie@mcccf.gouv.qc.ca; bob.Allen@abccomm.com; ghariton@sympatico.ca;
lefebvre@rogers.com; kirsten.embree@fmc-law.com; bruce@brucebuchanan.net;
jonathan.holmes@ota.on.ca; cataylor@cyberus.ca; chris.allen@abccomm.com;
regulatory@vianet.ca; piac@piac.ca; tom.copeland@caip.ca ; hemond@consommateur.qc.ca;
blackwell@giganomics.ca; jhpratt@msn.com; crtc@paul.ca; regulatory@lya.com;
regulatory@teksavvy.com; dmckeown@viewcom.ca; David.Wilkie@tbaytel.com;
regulatory@fibernetics.ca; jfmezei@vaxination.ca; stephen.scofich@tbaytel.com;
regulatory@bcba.ca; crtcmail@gmail.com; telecom@gov.bc.ca;
regulatory@telnetcommunications.com; apilon@acninc.com; regulatory@cnoc.ca;
jp@electronicbox.net; pris@pris.ca; michelle.duguay@telus.com;
document.control@sasktel.sk.ca;
 5

Attachment 1

Disclosure of Confidential Information

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

Bell Aliant

Bell Aliant(CRTC)15Sep10-104
All information

Bell Aliant(CNOC)11Feb11-3
For tables 5a, 5b and 5d of Bell Aliant‟s 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 Aliant‟s 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 Aliant‟s study report filed on 10 Dec 2010
 All information in Table 3 of the Bell Aliant‟s 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 period
traffic levels

The Companies(CNOC)11Feb11-4
 For tables 5f, 5g, 5h, 5m and 5n of the Bell companies‟ revised study report filed on 11
March 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
 6

The Companies(Primus)11Feb11-3
 All information in Table 3 of the Bell companies‟ revised study report filed on 10 Dec
2010
 All information in Table 3 of the Bell companies‟ revised study report filed on 11 Mar
2011

MTS Allstream

MTS Allstream(CNOC)11Feb11-4
For tables 6.4.5-1 to 6.4.5-9 of MTS Alstream‟s 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 SaskTel‟s revised study report filed on 11 March 2011, provide the
percentage 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)15Oct10-103
Average 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
 7

Attachment 2

Further responses to Interrogatories

The ILECs are to provide further responses to the interrogatories identified below, to the extent
set 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 Attachment
Provide on the public record all maximum capacities and working fill factors
 8

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 FTTN

development costs should be recovered from all customers regardless if they are retail or
wholesale customers. Bell Aliant further provided an estimate of the wholesale share of
total DSL end-user demand at year-end 2015 that it used to allocate its FTTN
development 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 service‟s use of the FTTN
network. Further provide Bell Aliant‟s views on the appropriateness of assigning
the above noted FTTN development costs to the FTTN related services based on
these 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).
 9

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 a
truck 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 SaskTel‟s 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 Bell Aliant‟s
 10

activities that are common to both the provision of the company‟s ADSL Access-
FTTN service and Dry Loop or Unbundled Loops.

b. Explain, with supporting rationale, if and why Bell Aliant‟s 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.
 11

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 help
desk activities. In response to The Companies(CRTC)28May10-8 TNs 269 & 7205, the
Bell companies indicated that 7.08% of all copper-related trouble tickets were directly
attributable to DSL service.

a. Explain why the Bell companies are proposing a methodology to estimate help
desk 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 used
in 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 that

the network conditioning activities are performed for the FTTN service as a whole and
that since both retail customers and wholesale end-users ultimately benefit from these
network conditioning activities, the network conditioning costs should be recovered from
both retail and wholesale customers.

In response to The Companies(CRTC)04Feb11-103, the Bell companies indicated that

the initial business plan to develop FTTN-based services was premised on the expectation
that there would be recovery of the up-front investment from the entire base of future
end-users and not just a portion thereof.

In response to The Companies(CRTC)15Sep10-102, the Bell companies provided an

estimate of the wholesale share of total residential DSL end-user demand at year-end
2015 that it used to allocate its network conditioning and FTTN development costs to
wholesale 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 and
2015, provide an estimate of the number of retail end-users.

c. Provide an estimate of the proportionate share of each service‟s use of the FTTN
network. Further provide the Bell companies‟ views on the appropriateness of
assigning the above noted FTTN development and network conditioning costs to
the 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.
 12

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 truck
roll 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 may
also 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.
 13

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 the
remote 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
 14

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 the
following 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.
 15

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 SaskTel‟s 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 of the 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.
 16

Aggregated ADSL tariffs: matching speeds - Interrogatories to MTS Allstream

1. Refer to the company‟s response to MTS Allstream(CRTC)15Sep10-103, where the

company 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 the
company‟s response to MTS Allstream(CRTC)15Sep10-103 Revised, where the
company provided revised costs for the buried fibre cable.

a. Provide the methodology and assumptions used to estimate the revised IFC per
Access 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 the

buried fibre cable costs provided in response to MTS Allstream(CRTC)15Sep10-103
Revised 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 Allstream
indicated that the Phase II capital costs have been adjusted to reflect capital and expense
increase factors and productivity improvements in each year of the study starting in 2011
and ending in 2015. MTS Allstream also provided, in table 6.5.2, the capital increase
factors used for each account code.

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

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

c. Identify which account code applies to the Internet computers hardware

component for the V-AHSSPI services. Further identify the changes in capacity
and cost per access for Internet computers hardware over the last five years;
further comment on the appropriateness of using the corporate average CIF
proposed for Internet computers hardware over the study period.

3. In its revised economic study filed 11 March 2011, MTS Allstream used a 5 year study
period for the costs causal to demand and a 10 year study period for its costs causal to
service.
 17

a. For each of VDSL access service and the three V-AHSSPI services, provide a
revised proposed cost study which reflects a study period of 10 years. The
response should include revised proposed tables 6.4.5-1 to 6.4.5-9 as provided in
Appendix 1 of Attachment 1 of the cost study report, and revised proposed tables
of MTS Allstream(CRTC)15Sep10-103 and 105. The response should also
identify, 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 the
responses to MTS Allstream(CRTC)15Sep10-103 and 105, for the VDSL access
service, provide revised 10 year cost study information and proposed revised rates
per 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 equipments
and facilities.

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

c. Using the format of tables 6.4.5-1 to 6.4.5-9 of the cost study, and tables of the
responses to MTS Allstream(CRTC)15Sep10-103 and 105, for the three V-
AHSSPI services, provide revised 10 year cost study information and proposed
revised 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 all
equipments and facilities.

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

The response should include revised proposed tables 6.4.5-1 to 6.4.5-9 as

provided in Appendix 1 of Attachment 1 of the cost study report of the cost
study, and revised proposed tables of MTS Allstream(CRTC)15Sep10-103 and
105.

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.

4. Refer to the company‟s responses to MTS Allstream(CRTC)4Feb11-106 Revised, where

the company has provided IFC per 100 Mbps V-AHSSPI service associated with various
components of the dedicated 1 GB port on 7450 to Competitors equipment.
 18

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 the
above 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 GB
dedicated interface. If so, explain why.

c. Provide the company‟s view, with rationale, on providing two distinct tariff
components for the V-AHHSPI interface consisting of (i) resources related to
dedicated port and (ii) resources related to the shared ports.

5. Refer to the company‟s responses to MTS Allstream(CRTC)15Sep10-106 and MTS

Allstream(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 - Order
fulfillment” activity requires activities such as creating the VLAN, configuring
the VLAN and testing the operation.

b. With regard to the “Outward: Facilities Management – Issue Order” activity

provided by the company, explain with supporting rationale why this activity is a
one-time activity specific to each outward movement of VDSL Access service. If
this activity is not specific to each VDSL Access outward movement, provide
supporting rationale as to why the cost associated with this activity is viewed to
be incremental to the outward movement of the service.

6. Refer to the company‟s responses to MTS Allstream(CRTC)15Sep10-106 where the

company 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 the
company‟s retail VDSL Data Access service.

a. Confirm that the “Expenses causal to demand – Service Provisioning” expenses

shown in Table 6.4.5-1 of the company‟s revised Economic Evaluation study
report 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 VDSL
Access - “Expenses causal to demand – Service Provisioning” as shown in Table
6.4.5-1 of the company‟s revised Economic Evaluation study report, using the
wholesale in-service demand data for the VDSL Data Access service as well as
the percentage of trouble tickets based on the company‟s retail VDSL Data
Access service as provided in part d) of MTS Allstream(CRTC)4Feb11-111.
 19

7. Refer to the company‟s responses to MTS Allstream(CRTC)15Sep10-106, where the

company has provided the time estimates and unit costs for various V-AHSSPI Inward,
Outward and Recurring activities.

a. For each of the company‟s 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 Outward
activities (e.g., IP Traffic – Configuration / De-configuration, Facilities
Management – Issue Order, and IPMP – Order Fulfillment) associated with the V-
AHSSPI service are the same, given that, unlike Inward movement, the interface
and connections for Outward movement already exist.

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

8. Refer to the company‟s response to MTS Allstream(CRTC)15Sep10-105, where the

company provided “Vendor Support PWAC” associated with the maintenance expense
causal to demand for the VDSL access as well as the interface services.

Provide the calculations used to estimate the annual maintenance Vendor Support
cashflows used to derive the PWAC for the 1000 Mbps V-AHSSPI interface service
provided in this interrogatory response. The response should show the values and
sources of the unit cost and demand information used as well as all assumptions, with
supporting rationale.

9. Refer to the response to MTS Allstream(CRTC)4Feb11-205, Attachment 1, where MTS

Allstream provided, by major activity, LUCs and time estimates for V-AHSSPI and
AHSPPI as well as VDSL and ADSL access service charges. Explain, with supporting
rationale, 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 other
than those related to changes in LUCs and time estimates that have contributed to the
changes in service charge costs; if so, identify each of these changes, with supporting
rationale.

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

a. For V-AHSSPI service charge, provide a description for each of the following
major activities: broadband coordinator-order coordination; IP traffic-design
network 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 major
activities: IPMP(TECNET)-configures subscriber to network; Facilities
management-design and issue orders; Assignment-records management;
 20

Workforce controller- dispatch FSTs; Co expediter-dispatch for CO techs; CO

Tech; 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 rates
for each sub-activity for each of National Account representative-Customer's point of
contact activity and the CSG Systems Engineering- Tech Sales support activity, with
supporting rationale.

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

a. Comment with supporting rationale on SaskTel‟s 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 Allstream‟s
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 Allstream‟s 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.
 21

Aggregated ADSL tariffs: matching speeds - Interrogatories to SaskTel

1. In its response to SaskTel(CRTC)4Feb11-107, SaskTel stated that it assumed that a

firmware 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 visits
to its retail customer premises to perform a firmware upgrade on an annual basis.

b. Explain, with supporting rationale, whether the firmware upgrades could

eventually be done on a remote basis or required on a less frequent basis as the
product matures.

c. Explain, with supporting rationale, what would happen if the firmware upgrades
were 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 counting

of capital expenditures for the following IP Core items:

a. Page 2 of 5: IP Core costs (Transport) described as “This equipment includes

traffic driven costs connecting redundant trunks between SaskTel IP Core Edge
Router and SaskTel IP Core Router”.

b. Page 3 of 5: IP Core costs described as “This equipment is used to connect and

aggregate DSLAM traffic and includes costs for connecting redundant trunks to
SaskTel IP Core Edge Routers”.

If not, explain why not.

3. With reference to SaskTel(CRTC)15Sep10-103 and Attachment to

SaskTel(CRTC)4Feb11-103 interrogatory response, explain the discrepancy in the
DSLAM 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 per
access into the following components:

a. Material cost (specify equipment)

b. Engineering
c. Installation
d. Other (specify)

The answer should identify the WFF and the capacity of each equipment.
 22

5. Refer to the response to SaskTel(CRTC)4Feb11-204 h). Provide the requested estimate of

the percentage of existing loops with bridge taps or load coils, identifying the source and
vintage of the data.

6. Refer to the response to SaskTel(CRTC)4Feb11-204 i) where SaskTel indicated that

certain inside wiring work occurs 100% of the time and other inside wiring work occurs
50% of the time. Provide the list of inside wiring work activities that occur 100% of the
time and the time estimate for each of these activities.
 23

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 the
first and last year of the study, provide the assumed proportions of ATM PVC and
Gigabit 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. Provide
the 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 studies

for 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, 3
and 5) for all of Telus‟ proposed matching speed services reflecting a study period of 5
years. 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 British
Columbia 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 by
product study which is created by assigning costs from the SAP system to products and
processes. Explain whether the cost driver used to develop the estimate of service
provisioning expenses was inward demand. If not, provide revised cost estimates for
provisioning expenses based on inward demand, including all supporting cost
assumptions.

5. With reference to Telus(CRTC)15Oct10-103, for each of BRAS/Aggregation and ATM

PVC (Gigabit Ethernet) unit costs, provide a detailed breakdown into the following
components:

a. Material cost (specify equipment)

b. Engineering
c. Installation
d. 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 to
TELUS(CRTC)15Oct10-103 and TELUS(CRTC)4Feb11-101A, provide revised 3 year
 24

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

For each of the years 2006 to 2011, apply a retrospective CIF of -10% to the ATM
PVC/Gigabit Ethernet equipment. For each of the years 2009 to 2011, apply a
retrospective CIF of -10% to the BRAS aggregation equipment and a retrospective CIF of
-2% to the DSLAM equipment.

7. In response to TELUS(CRTC)04Feb11-115, Telus provided a revised study with a 10

year study period. Using the format of tables 1, 2, 3 and 5 of the cost study, and tables of
Attachments 1 to TELUS(CRTC)15Oct10-103 and TELUS(CRTC)4Feb11-101A,
provide revised 10 year cost study information and proposed revised rates per end-user
for each of the following changes in assumptions:

a. For each year of the study period, a CIF of -2% for access driven cost components
(e.g. DSLAM) and -10% for traffic driven cost components (e.g. ATM
PVC/Gigabit Ethernet, BRAS aggregation).

b. For each year of the study period, a CIF of -4% for access driven cost components
(e.g. DSLAM) and -15% for traffic driven cost components (e.g. ATM
PVC/Gigabit Ethernet, BRAS aggregation).

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.

8. Refer to Telus(CRTC)4Feb11-201 c) where Telus indicated that for the Product

Management expense category, activities are incurred when additional service orders are
initiated to ensure the orders are being processed properly, error-free and without delay.
Explain why Product Management costs are viewed to be volume sensitive in light of
Telus‟ classification of these costs as Non-Volume sensitive on page 5 of Attachment 1 to
Telus(CNOC)4Feb11-06. Further comment on the appropriateness of including these
costs in the monthly recurring cost studies.

9. Refer to Telus‟ response to Telus(CRTC)4Feb11-201 where Telus indicated that costs

associated with “assign”, “install”, “activate” and “ensure delivery” are included in the
WIAS monthly rate costs.

a. Confirm that the costs for “assign”, “install”, “activate” and “ensure delivery”
activities, as well as other order processing activities, are also recovered by either
the Dry Loop or Unbundled Loop service order charge. If so, comment on the
appropriate adjustments to the Dry Loop or Unbundled Loop service order charge
that would be required to avoid double recovery of the costs for these activities.
 25

b. Explain, with supporting rationale, if and why the above-noted activities cannot
be performed at the same time if both WIAS and Dry Loop or Unbundled Loop
services are required at the time of the ISP request.

c. Comment with supporting rationale on SaskTel‟s proposal in its response to

SaskTel(CRTC)4Feb11-201 to remove service establishment activity costs that
are common to both the VDSL 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 TELUS‟ activities that are common to both the provision
of WIAS and Dry Loop or Unbundled Loops.

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

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

e. For each of “Order Entry”, “Update” and “Correction” activities, further provide
revised time estimates in light of the response to part a) above, with supporting
rationale.

11. Refer to Telus(CRTC)4Feb11-204 e). Explain with supporting rationale why the Loop
Qualification activity would be required for the 1.5 Mbps to 6 Mbps WIAS service. If the
Loop Qualification activity would not be required, comment on the use of a different
service 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 for
Wholesale Internet ADSL service does not include a monthly payment option for the 15
Mbps and 25 Mbps services. Further refer to Telus‟ proposed Tariff page 226-7A, note 2
b) 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 this
amount is applicable to the 15 Mbps and 25 Mbps services. Explain the discrepancy.