ARCHIVED - Telecom Commission Letter - 8622-D37-200504424
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Ottawa, 9 May 2005
File No.: 8622-D37-200504424
Mr. Ralph Doncaster
Dear Mr. Doncaster:
Subject: Part VII Application Regarding Bell Canada 's Naked DSL Service
The Commission is in receipt of Doncaster Consulting Inc.'s ( Doncaster ) Part VII application dated 11 April 2005 regarding Bell Canada 's Naked DSL  service.
In its Part VII application, Doncaster requested that the Commission issue an order requiring Bell Canada to cease offering retail "naked DSL" until the Commission had approved a tariff for the service.
It is noted that in Forbearance From Retail Internet Services, Telecom Order CRTC 99-592, 25 June 1999 , the Commission forbore from regulating retail internet services.
Doncaster also submitted that by offering "naked DSL" on a retail basis while refusing to offer it on a wholesale basis, Bell Canada was giving itself an undue preference and subjecting competitors to an unreasonable disadvantage.
In Gateway Access Service , Telecom Order 2005-144, 15 April 2005 , the Commission granted interim approval to Bell Canada 's TN 6862 which revised the Gateway Access Service (GAS) to remove the condition that the end-customer needed to subscribe to primary exchange service (PES). Under this new service, a competitor can provide high speed DSL internet services to its end-customers that do not subscribe to an incumbent local exchange carrier's (ILEC's) or a competitive local exchange carrier's (CLEC's) PES. Under this service arrangement, a competitor must purchase an unbundled local loop to be used in conjunction with GAS. This enables competitors to offer their own high-speed internet service to customers, without the customer subscribing to PES.
Bell Canada , is therefore offering wholesale "naked DSL" pursuant to an approved tariff, and no further action is required with respect to this aspect of the Part VII application.
On 21 April 2005 , Doncaster provided its reply comments. In these comments, Doncaster raised new issues that were not part of the original Part VII application. Notably, Doncaster provided comments regarding pricing for loops and sub-loops which suggested that a retail tariff was required for loops and sub-loops when combined with retail naked DSL.
It is noted that these comments are similar to comments raised by other parties as part of the proceeding related to Bell Canada 's TN 6862 application. Accordingly, the parts of Doncaster's application that relate to the pricing of loops and retail "naked DSL" will be introduced into the record of TN 6862, and will be dealt with in that proceeding.
In light of the above, Doncaster's Part VII application is considered to be closed, and no further action will be taken by the Commission in the context of this application.
"Original signed by Yvan Davidson for Scott Hutton"
c.c.: Interested Parties
 T he following clarification is offered over the usage of the term "naked DSL":
On a retail basis, "naked DSL" refers to the offering of retail high-speed internet services to end-customers using digital subscriber line (DSL) technology, where no primary exchange service (PES) is present on that end-customer's access facility.
On a wholesale basis, "naked DSL" refers to the offering of DSL access services to competitors where no PES is present on the end-customers' access facility.Date Modified: 2005-05-09
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