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ARCHIVED - Telecom Commission Letter - 8622-R11-200515505

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Letter

Ottawa, 22 February 2006

File No:  8622-R11-200515505

By E-mail

regulatory.matters@aliant.ca
bell.regulatory@bell.ca
reg.affairs@mts.ca
document.control@sasktel.sk.ca
willie.grieve@telus.com

Mr. David Hennessey, Manager - Regulatory Matters, Aliant Telecom Inc.
Mr. Mirko Bibic, Chief, Regulatory Affairs, Bell Canada
Ms. Teresa Griffin-Muir, Vice President, Regulatory Affairs, MTS Allstream Inc.
Mr. Bill Beckman, General Manager Regulatory Affairs, Saskatchewan Telecommunications
Mr. Willie Grieve, Vice-President Telecom Policy & Regulatory Affairs, TELUS Communications Inc.

Re: Part VII Application by Rogers Wireless Partnership: Clarification on the Applicability of Retail Digital Network Access (DNA) Link Charges on Competitor Digital Network (CDN) Facilities

The companies are requested to provide comprehensive answers, including any supporting information, to the attached questions with regard to the above referenced application by 24 March 2006.

Yours Sincerely,

Original signed by

Yvan Davidson
Senior Manager, Competitor Services and Costing

c.c.:   Ms. Dawn Hunt, Rogers Wireless       dawn.hunt@rci.rogers.com
          Mr. Jonathan Holmes, Primus               regulatory@primustel.ca
          Bob Martin - CRTC (819) 953-3361

Attachment

Aliant Telecom

Rogers Wireless Partnership (Rogers Wireless), in its 23 December 2005 application, and as well the additional information submitted 10 January 2006 on behalf of Rogers Telecom Inc. (Rogers Telecom), raises the matter of incumbent local exchange carriers (ILECs) applying retail Digital Network Access (DNA) link charges in conjunction with facility configurations that involve the use of Competitor Digital Network (CDN) facilities leased by Rogers Wireless and Rogers Telecom.

Aliant Telecom Inc. (Aliant Telecom), in its 3 February 2006 response to Rogers Wireless' application, stated:

        Aliant charges interconnecting carriers for in-house DS1s under its duly approved tariff, CRTC 21491, Item 608.6., Interconnecting Circuits with Trunk-Side Access, (a) General, part vi), which states:

              The facility over which interconnecting circuits with trunk-side access and CCS7 links are provided is furnished at the rates and charges specified in Item 302 of the National Services Tariff CRTC 7400.

  1. Explain precisely where in item 302 of the National Services Tariff the application of rates of the company's in-house DS-1s is clearly defined and specified. If not specified in item 302 of the National Services Tariff, provide the precise tariff reference(s) that defines and specifies the application of the rates of the company's in-house DS-1s. If not in any tariff, explain why not
  2. With respect to arrangements where Aliant Telecom applies its in-house DS-1 rates for CDN services that connect to non-CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of in-house DS-1s as of December 2005 for each service scenario identified.
  3. With respect to arrangements where Aliant Telecom applies its in-house DS-1 rates for CDN services that connect to other CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of in-house DS-1s as of December 2005 for each service scenario identified.
  4. Provide schematics for all configurations identified in questions 2 and 3 above. The response should clearly identify all major resource components (e.g., electronic/optical hardware, frames, multiplexers, patch panels, etc.) of the arrangements. The response should also identify the specific tariff element(s) through which the company's costs for the various components are recovered.
  5. Provide a cost study for Aliant Telecom's in-house DS-1 service, identifying all cost components and underlying assumptions.

Bell Canada

Rogers Wireless Partnership (Rogers Wireless), in its 23 December 2005 application, and as well the additional information submitted 10 January 2006 on behalf of Rogers Telecom Inc. (Rogers Telecom), raises the matter of incumbent local exchange carriers (ILECs) applying retail Digital Network Access (DNA) link charges in conjunction with facility configurations that involve the use of Competitor Digital Network (CDN) facilities leased by Rogers Wireless and Rogers Telecom.

Bell Canada, in its 3 February 2006 response to Rogers Wireless' application, stated:

  . CDN customers will continue to be billed for DNA links relates to what has been commonly referred to as "in-house" links. In-house links are physical facilities that connect competitor services to other ILEC services or connect one competitor's service to another competitor's service. These facilities are not part of CDN services identified in Decision 2005-6, but instead provide connection to other services, (e.g., TOPS switches for DA, switching and aggregation, Message Relay Service, 9 1 1, SS7 STP's and Wireless Access) that were clearly outside of the scope of services deemed to be eligible for CDN rating in Decision 2005-6. These facilities are subject to the terms and conditions of the Company's retail DNA link charge, as specified in Item 300.2 of Bell Canada 's NST.

  1. Explain precisely where in item 300.2 of the National Services Tariff the application of rates of the company's in-house links is clearly defined and specified.   If not specified in item 300.2 of the National Services Tariff, provide the precise tariff reference(s) that defines and specifies the application of the rates of the company's in-house links. If not in any tariff, explain why not.
  2. With respect to arrangements where Bell Canada applies its in-house link rates for CDN services that connect to non-CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of in-house links as of December 2005 for each service scenario identified.
  3. With respect to arrangements where Bell Canada applies its in-house link rates for CDN services that connect to other CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of in-house links as of December 2005 for each service scenario identified.
  4. Provide schematics for all configurations identified in questions 2 and 3 above. The response should clearly identify all major resource components (e.g., electronic/optical hardware, frames, multiplexers, patch panels, etc.) of the arrangements. The response should also identify the specific tariff element(s) through which the company's costs for the various components are recovered.
  5. Provide a cost study for Bell Canada 's in-house link service, identifying all cost components and underlying assumptions.

MTS Allstream

Rogers Wireless Partnership (Rogers Wireless), in its 23 December 2005 application, and as well the additional information submitted 10 January 2006 on behalf of Rogers Telecom Inc. (Rogers Telecom), raises the matter of incumbent local exchange carriers (ILECs) applying retail Digital Network Access (DNA) link charges in conjunction with facility configurations that involve the use of Competitor Digital Network (CDN) facilities leased by Rogers Wireless and Rogers Telecom.

MTS Allstream Inc. (MTS Allstream), in its 3 February 2006 response to Rogers Wireless' application, stated:

MTS Allstream acknowledges that in some cases it had inadvertently charged competitors for retail DNA links in certain situations similar to those raised in this application. As soon as this matter was brought to its attention MTS Allstream removed these charges from competitor invoices and has already started to process rebates for these charges back to 3 February 2005 .

  1. With respect to the situations where MTS Allstream had charged competitors its retail DNA link rates for CDN services that connect to non-CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of DNA links as of December 2005 for each service scenario identified.
  2. With respect to the situations where MTS Allstream had charged competitors its retail DNA link rates for CDN services that connect to other CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of DNA links as of December 2005 for each service scenario identified.

SaskTel

Rogers Wireless Partnership (Rogers Wireless), in its 23 December 2005 application, and as well the additional information submitted 10 January 2006 on behalf of Rogers Telecom Inc. (Rogers Telecom), raises the matter of incumbent local exchange carriers (ILECs) applying retail Digital Network Access (DNA) link charges in conjunction with facility configurations that involve the use of Competitor Digital Network (CDN) facilities leased by Rogers Wireless and Rogers Telecom.

Saskatchewan Telecommunications (SaskTel), in its 3 February 2006 response to Rogers Wireless' application, stated:

Central office arrangements or links required to connect the above services with each other or with other SaskTel services are included within the above services. Link services included in SaskTel Competitor Access Tariff Item on Co-location Arrangements for Interconnecting Canadian Carriers and Item on Interconnecting Circuits with Trunk Side Access apply as appropriate.

  1. Explain whether SaskTel's current approach with regard to the application of rates of the company's link services in conjunction with CDN services is clearly defined and specified in its tariffs. If so, provide the precise tariff reference(s) that defines and specifies the application of the rates of the company's link services in conjunction with CDN services. If not, explain why not.
  2. With respect to arrangements where SaskTel applies its link service rates for CDN services that connect to non-CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of links as of December 2005 for each service scenario identified.
  3. With respect to arrangements where SaskTel applies its link service rates for CDN services that connect to other CDN services, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of links as of December 2005 for each service scenario identified.
  4. Provide schematics for all configurations identified in questions 2 and 3 above. The response should clearly identify all major resource components (e.g., electronic/optical hardware, frames, multiplexers, patch panels, etc.) of the arrangements. The response should also identify the specific tariff element(s) through which the company's costs for the various components are recovered.
  5. Provide a cost study for the SaskTel link service(s) required for CDN services that connect to non-CDN services and other CDN services, identifying all cost components and underlying assumptions.

TCI

Rogers Wireless Partnership (Rogers Wireless), in its 23 December 2005 application, and as well the additional information submitted 10 January 2006 on behalf of Rogers Telecom Inc. (Rogers Telecom), raises the matter of incumbent local exchange carriers (ILECs) applying retail Digital Network Access (DNA) link charges in conjunction with facility configurations that involve the use of Competitor Digital Network (CDN) facilities leased by Rogers Wireless and Rogers Telecom.

  1. Clarify whether TELUS Communications Inc. (TCI) currently applies its retail DNA link rates for CDN services that connect to non-CDN services. If so, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of DNA links as of December 2005 for each service scenario identified.
  2. Clarify whether TCI currently applies its retail DNA link rates for CDN services that connect to other CDN services. If so, provide an exhaustive list of all scenarios and all services involved, as well as the in-service demand of DNA links as of December 2005 for each service scenario identified.
  3. Provide schematics for all configurations identified in questions 1and 2 above. The response should clearly identify all major resource components (e.g., electronic/optical hardware, frames, multiplexers, patch panels, etc.) of the arrangements. The response should also identify the specific tariff element(s) through which the company's costs for the various components are recovered.
  4. Provide a cost study for any TCI link service(s) required for CDN services that connect to non-CDN services and other CDN services as described in 1 and 2 above, identifying all cost components and underlying assumptions.

Date Modified: 2006-02-22

Date modified: