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Ottawa, 1 September 2006

Our file: 8640-C12-200507618 and 8640-B2-200401506 

To: Distribution List 

Re: Framework for forbearance from regulation of high-speed intra-exchange digital services, Telecom Public Notice CRTC 2005-8, as amended by Public Notice 2005-8-1 and Public Notice 2005-8-2 (PN 2005-8)  

In reviewing the record in the proceeding initiated by the Public Notice referenced above, Commission staff identified a number of areas where additional information is required in order to ensure the establishment of a full record upon which to base the Commission's determination.

Accordingly, the process in this proceeding is extended as follows:

1- Responses to interrogatories in the attachment to this letter - 22 September 2006

2- Comments restricted to the subject matter raised in the interrogatories - 6 October 2006

3- Requests for further responses and public disclosure - 13 October 2006

4- Responses to requests for further responses and public disclosure - 20 October 2006

5- A determination with respect to requests for further information and for public disclosure will be issued as soon as possible. Any information to be provided pursuant to that determination must be filed with the Commission and served on all parties, by 3 November 2006

6- Reply comments - 10 November 2006

Parties are reminded that the documents must be filed with the Commission, serving copies on all interested parties.   Where a document is to be filed or served by a specific date, the document must actually be received, not merely sent, by that date.

Please note that to the extent possible all documents should be filed with the Commission using the Procedure on-line form specifying the Commission file number indicated on this letter.   You can access the forms on the Commission website ( by selecting "Contact Us" and then choosing the appropriate form.

Yours sincerely,


Paul Godin
Acting Director General
Competitor Services, Costing and Tariffs


Distribution List: ; ; ; ; ; ; ; ; ; ; ; ; ; ; ; roy.wiseman@peelr ; ; ; ; ; ; ; ; ; ; ; ;

cc:    M. Bertrand, CRTC, (819) 994-0294



All Parties, including Municipal Electric Utilities


Given that CDN services at DS-3 speeds and above are categorised as Category II competitor services, which are offered at cost plus a mark-up that is intended to, among other things, encourage competitor self-supply of underlying facilities, comment on:

a)            Whether or not the Commission should rely solely on non-ILEC supply to sustain competition in a forborne retail market;

b)            Whether the appropriate geographic market should be smaller than the exchange, for competitors to be expected to reasonably expand their networks in response to ILEC offerings.   If the appropriate geographic market under the above circumstances should be smaller, identify what the appropriate geographic market should be; and

c)            The percentage of non-ILEC supply within a geographic market which would indicate the absence of ILEC supply dominance in that market.


High-speed DNA services are services primarily used by medium to large business customers.   Such customers are usually situated in urban centres.   Bell Canada 's request for forbearance includes many exchanges that are not urban centres, where the demand for high-speed DNA   services is very small.   Given the low-demand in these geographic markets, identify:

a)            The minimum number of retail high-speed DNA access circuits that must be provisioned within the relevant geographic area, to enable a complete forbearance assessment based market share, supply conditions and demand conditions; and

b)            Whether it is appropriate for the Commission to forbear geographic markets with low-demand;

i.             If it is appropriate to forbear in these markets, identify the factors that are good indicators that the market would remain competitive in a forborne environment.

ii.             For each of the factor identified, provide rationale as to why the factor is proposed and, if appropriate, suggest quantifiable minimum criteria with rationale.


Provide in confidence, a list of buildings across Canada that are connected to your network at speeds of DS-3 or greater.   The information should be provided electronically in the following format below:

Building Name

Street Address

Postal Code

Equipped to provision DNA services (Yes or No)

Equipped to provision Ethernet service(Yes or No)

Dark fibre(Yes or No)

Future plans to light the fibre or increase capability / capacity of fibre over next 5 years.*








* The plans that should be identified are plans to increase capacity, enhance the capabilities to offer DNA access based services to the building where currently only Ethernet access based services are offered, or plans to commission (light) dark fibre.


Provide, in confidence, a list of buildings across Canada to which network construction is currently underway or is planned to be completed over the next 5 years that will allow for the provisioning of services at speeds of DS-3 or greater. The information should be provided electronically in the following format below:

Building Name

Street Address

Postal Code

Estimated completion date (month, year)

Specify which services are to be offered following completion i.e. DNA, Ethernet (specify)






Additional interrogatories to Bell Canada only

Bell Canada (CRTC)31Aug06-3005

Provide electronically in the following table format, a list of all postal codes within the 119 exchanges for which Bell Canada is requesting HSDS forbearance.

Exchange Name

Wire Centre Name

Postal Code




Bell Canada (CRTC)31Aug06-3006

Provide evidence of rivalrous behaviour for each wire centre, in the 119 exchanges that Bell Canada is seeking forbearance.   Evidence of rivalrous behaviour may include, but not limited to, falling prices, aggressive marketing campaigns, bidding activity, press releases / public information, promotions etc.

Additional interrogatories to TELUS Communication Inc., Aliant Telecom Inc., MTS Allstream Inc. and Saskatchewan Telecommunications only

MTS Allstream(CRTC)31Aug06-3005

Within your territories of incumbency, identify wire centres and exchanges, where in your view it is likely that you would request forbearance within the next three years.   For each wire centre identified:

a)            Provide rationale as to why a forbearance request is likely within the next 3 years. 

b)            Provide the total number of high-speed DNA service, by speed for 2004 and 2005. 

c)            Provide evidence on competitor position with relation to high-speed DNA services.   Such evidence may include, but need not be limited to rivalrous behaviour. 

d)            Provide electronically in the following table format, a list of all postal codes.  

Exchange Name

Wire Centre Name

Postal Code





Date Modified: 2006-09-01
Date modified: