ONTARIO ENERGY BOARD. IN THE MATTER OF the Ontario Energy Board Act, 1998, S.O. 1998, c.15 (Schedule B);

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1 ONTARIO ENERGY BOARD IN THE MATTER OF the Ontario Energy Board Act, 1998, S.O. 1998, c.15 (Schedule B); AND IN THE MATTER OF an application by Toronto Hydro- Electric System Limited for an order pursuant to section 29 of the Ontario Energy Board Act, PRE-FILED EVIDENCE OF TORONTO HYDRO-ELECTRIC SYSTEM LIMITED JUNE 13, 2013

2 ONTARIO ENERGY BOARD IN THE MATTER OF the Ontario Energy Board Act, 1998, S.O. 1998, c.15 (Schedule B); AND IN THE MATTER OF an application by Toronto Hydro- Electric System Limited for an order pursuant to section 29 of the Ontario Energy Board Act, PRE-FILED EVIDENCE OF TORONTO HYDRO-ELECTRIC SYSTEM LIMITED 1. THESL owns approximately 175,000 poles in its distribution system. 2. THESL s poles serve different functions, and individual poles may serve more than one function. The poles can be grouped roughly in four broad categories, as follows: (a) Poles whose principal function is to support primary distribution. These poles may also support secondary distribution. These poles can, depending on the circumstances, accommodate wireless telecommunications equipment ( wireless attachments ) and wireline telecommunications equipment ( wireline attachments ), but not as a general proposition on the top of the poles; (b) (c) (d) Poles whose principal function is to support secondary distribution. These poles can, depending on the circumstances, accommodate both wireless attachments and wireline attachments; Streetlighting poles, which either have or can have a distribution function. Under THESL s current standards, streetlighting poles do not accommodate wireline attachments but can, if modified or replaced, accommodate wireless attachments; Streetlighting poles that are decorative or historic. Such poles generally do not accommodate either wireless attachments or wireline attachments. 3. Whether any individual pole can be used for wireless attachments depends on the circumstances of that pole, the size of the proposed attachments, and where on the pole the devices are to be attached. THESL now reserves, and would continue to reserve, the right to preclude wireless attachments on any of its poles based on the circumstances of those poles. 4. THESL has no knowledge of the economic significance that the location of poles has to the attacher. As a result, that factor plays no role in THESL s decision whether to permit wireless attachments on a pole or poles

3 5. Although THESL s poles are located throughout its distribution system, the majority of its distribution poles are located outside the downtown core. The majority of distribution services in the downtown core are provided through underground ducts. THESL s poles in the downtown core are primarily streetlighting poles. 6. Attached as Appendix A is a map showing the location of THESL s poles, by type, in THESL s service territory. 7. There are approximately 119,000 poles in THESL s system available for wireless attachments. Given that number of poles in THESL s system, and given the broad geographic dispersion of those poles within that system, THESL can accommodate reasonable demands for wireless attachments to its poles. 8. In addition to THESL s poles, there are approximately 23,000 poles owned by THESL s affiliate, Toronto Hydro-Electric Services Inc. ( THESI ). All of THESI s poles are streetlighting poles, which do not under current standards accommodate wireline attachments but which can, if modified or replaced, accommodate wireless attachments. Some of THESI s poles are historic or decorative and as such generally do not accommodate either wireless or wireline attachments. 9. THESL owns approximately 40,000 streetlighting poles. As set out in the preceding paragraph, THESI owns approximately 23,000 streetlighting poles. Approximately 25% of the streetlighting poles in the downtown core of Toronto are historic or decorative. 10. Wireless attachments are in two categories. One is for WiFi services. The other is for cellular services. 11. There are now wireless attachments on 130 of THESL s poles, and 61 of THESI s poles. Of the wireless attachments on THESL s poles, 128 are for WiFi services, and 2 are for cellular services. Of the wireless attachments on THESI s poles, 52 are for WiFi services and 9 are for cellular services. 12. In his report dated June 13, 2013, Dr. Jeffrey Church distinguishes between incumbent wireless service providers and new entrants. There are no wireless attachments on THESL s or THESI s poles from any of the new entrants. 13. Since the date of the Board s Preliminary Decision and Order in EB there have been 19 permit applications, from two providers, for wireless attachments on THESL and THESI s poles. To date, one permit has been issued. Of those applications, 18 are for cellular services on 18 THESL poles. The remaining application contemplates WiFi attachments on 2 THESL poles. 14. With the exception of wireless attachments for Wi-Fi, the THESL and THESI poles on which there are wireless attachments, or for which applications for attachments have been made, are all located outside the downtown core. 15. Were the Board to refrain from regulating the terms, conditions, and rates for the wireless attachments on its poles, there would be no harm to THESL s distribution system

4 16. As a result of the Decision and Order of the Ontario Energy Board dated March 7, 2005, THESL is authorized to charge $22.35 for each pole attachment. That figure is intended to cover THESL s direct and indirect costs. THESL s direct and indirect costs for pole attachments are higher than that. 17. THESL proposes to charge a competitive rate for wireless attachments to its poles. Doing so will improve THESL s ability to recover its true costs, and provide a benefit to its ratepayers and to its shareholder. Dated June 13,

5 APPENDIX A TO THE PRE-FILED EVIDENCE OF TORONTO HYDRO-ELECTRIC SYSTEM LIMITED DATED JUNE 13, 2013

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