ARCHIVED - lt060901a

Letter

Ottawa, 1 September 2006

File No.: 8663-C12-200610924

By E-Mail

To: Distribution List

Re: File #: 8663-C12-200610924 - Telecom Public Notice CRTC 2006-12 - Proceeding to reassess certain aspects of the local forbearance framework established in Decision 2006-15

With respect to Proceeding to reassess certain aspects of the local forbearance framework established in Decision 2006-15, Telecom Public Notice CRTC 2006-12, 1 September 2006 (Public Notice 2006-12), Commission staff requests responses to the attached interrogatories.

Pursuant to the procedure set out in Public Notice 2006-12, responses are to be filed with the Commission and served on all parties to that proceeding by 15 September 2006 .   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.

Yours sincerely,

Scott Hutton
A/Director General, Policy & Consumer Affairs
Telecommunications 

Distribution List: regulatory.matters@aliant.ca ;   bell.regulatory@bell.ca ;   iworkstation@allstream.com ;   document.control@sasktel.sk.ca ;   reglementa@telebec.com ;   regulatory.affairs@telus.com ;   telecom.regulatory@cogeco.com ;   regaffairs@quebecor.com ;   david.watt@rci.rogers.com ; ken.englehart@rci.rogers.com ; jean.brazeau@sjrb.ca ; esther.snow@sjrb.ca ; regulatory.matters@corp.eastlink.ca ;   andrew@isptelecom.net ;   dave.jarrett@sympatico.ca ;   regulatory@corporate.fcibroadband.com ;   donald.dupuis@maskatel.qc.ca ;   johnp@mountaincable.on.ca ; documents@accesscomm.ca ; pwightman@wightman.ca ;   jesse@vianet.ca ; jschacter@babytel.ca ;   yb@comwave.net ;   marcel.mercia@cybersurf.com ;   christian.tacit@cybersurf.com ;   regulatory@primustel.ca ;   rwdelsesto@swidlaw.com ;   john.lacalamita@ca.mci.com ;   brovet@yak.ca ; Joe.parent@vonage.com ;

cc:   Ian MacMillan, CRTC (819) 934-6350   ian.macmillan@crtc.gc.ca
       William Lloyd, CRTC (819) 997-4654   william.lloyd@crtc.gc.ca

Attachments

Interrogatories for Bell Aliant Regional Communications, Limited Partnership, Bell Canada, MTS Allstream Inc., Saskatchewan Telecommunications, Société en commandite Télébec, TELUS Communications Company, Cogeco Cable Inc., Eastlink Telephone, Exatel Inc., FCI Broadband, a division of Futureway Communications Inc., Globility Communications Corporation, ISP Telecom Inc., Maskatel Inc., Mountain Cablevision Limited, Rogers Communications Inc., Quebecor Media Inc., Shaw Communications Inc., Access Communications Co-operative Limited, Wightman Communications Ltd., Voice and Data Systems Inc., Comwave Telecom Inc., Cybersurf Corp., Primus Telecommunications Canada Inc., Yak Communications (Canada) Inc., Vonage Holdings Corp., and WorldCom Canada Ltd.

(CRTC)1Sept06-1

For each local forbearance region (LFR) [as defined in Appendix A of Forbearance from the regulation of retail local exchange services, Telecom Decision CRTC 2006-15, 6 April 2006 (Decision 2006-15)] in which the company offers local exchange service(s):

Provide the number of network access services (NAS) and NAS-equivalents (connections) [as defined in paragraph 254 of Decision 2006-15], separate for the relevant local business and residential exchange service markets addressed in Decision 2006-15, as of year 31 December 2004, 31 December 2005, and 31 August 2006.

As defined in Decision 2006-15, a NAS-equivalent measures the total primary telephone numbers in service counted in the exchange that is native to the primary telephone number.

The NAS and NAS-equivalents to be provided are those associated with local exchange services

The response should include a detailed description of how the business/residential split was determined.

If the information requested is not available by LFR, provide the information by exchange or by numbering plan area (NPA)-NXX.

Local exchange carriers (LECs) should not include NAS or NAS-equivalents provided to resellers.

(CRTC)1Sept06-2

Provide, for each province, the revenues for the connections reported in the response to interrogatory (CRTC)1Sept06-1 above, including revenues associated with optional local services, separate for business and residential, as of 31 December 2004 , 31 December 2005 , and 31 August 2006 .   The response should include a detailed description of how the business/residential split was determined.

LECs should not include revenues associated with connections provided to resellers.

(CRTC)1Sept06-3

Provide, for each province, the average monthly churn rate for the connections reported in the response to interrogatory (CRTC)1Sept06-1 above, separate for business and residential, for the years 2004 and 2005, and for 2006 through to 31 August.

Monthly "churn" is defined as the number of units disconnected during the month divided by the average number of units in service during the same month.   Disconnections associated with customer moves (e.g. due to change of address) for the same service should not be included.

The response should include a detailed description of how the business/residential split was determined.

LECs should not include churn rates associated with connections provided to resellers.

(CRTC)1Sept06-4

Provide, for each province, ported number information for the connections reported in the response to interrogatory (CRTC)1Sept06-1 above, separate for business and residential, for the years 2004 and 2005, and for 2006 through to 31 August.

The "ported number information" to be provided is the percentage of telephone numbers that were ported into the company's local exchange services, either from another service offered by the company or from a service offered by another service provider.   Telephone numbers associated with customer moves (e.g. due to change of address) for the same service should not be included.

The response should include a detailed description of how the business/residential split was determined.

(CRTC)1Sept06-5

Provide, for each province, the company's latest forecast for the number of connections and revenues, including revenues associated with optional local services, identifying the split between business and residential, as of 31 December   (or the company's year-end) for the years 2006, 2007, and 2008, which its Board of Directors has approved as part of the overall Board-approved financials.

(CRTC)1Sept06-6

Provide all market surveys, projections, studies, and other research reports, dated no earlier than 1 January 2006, that the company, or an affiliate of the company, has in its possession that address the evolution of local exchange services in Canada.

(CRTC)1Sept06-7

In Review of regulatory framework, Telecom Decision CRTC 94-19, 16 September 1994 , the Commission considered that evidence of rivalrous behaviour was also important with respect to assessing the degree to which a market may be workably competitive.   Evidence of rivalrous behaviour may include falling prices, vigorous and aggressive marketing activities, or an expanding scope of competitor activities in terms of products, services, or geographic boundaries.   The Commission also considered that the nature of innovation and technological change in the relevant market may also be a useful indicator.   Industries characterized by rapid innovation in products, processes, and technology tend to experience greater price movements and new entry, thereby making it difficult to exercise market power.

a)            Provide the company's views on the extent to which rivalrous behaviour exists with respect to local exchange services, separately for the residence and business markets and any appropriate sub-markets, with examples of evidence of specific aspects as described above.   Also provide the company's views with respect to barriers to entry.

b)            If the company has experienced or observed rivalrous behaviour with respect to local exchange services, separately for the residence and business markets and any appropriate sub-markets, discuss how the company is responding from the perspective of its business plans, and marketing and customer retention strategies.

ATTACHMENT 1

Interrogatory for Cogeco Cable Inc., Eastlink Telephone, Mountain Cablevision Limited, Rogers Communications Inc., Quebecor Media Inc., Shaw Communications Inc. and Access Communications Co-operative Limited.

(CRTC)1Sept06-101

For each province, provide:

a)            As of 31 December 2005 , the actual number of households and businesses, separately for each:
i)passed in the company's cable footprint;
ii)that subscribe to the company's high-speed Internet access service; and
iii)to which the company currently is operationally capable of providing local telephone service. 

b)            As of 31 December for the years 2006, 2007, and 2008, the forecast number of households and businesses, separately for each:
i)that will be passed in the company's cable footprint;
ii)that will subscribe to the company's high-speed Internet access service; and
iii)to which the company will be operationally capable of providing local telephone service.