ARCHIVED - Telecom Commission Letter - 8622-C12-200704321

Letter

Ottawa, 4 June 2007

File No.:   8622-C12-200704321

BY E-MAIL

To:   Distribution List (see Attached)

RE:    Proceeding to consider the requirement for a network interconnection device when a local exchange carrier's network is disconnected from residential inside wire

Pursuant to the procedure set out in Proceeding to consider the requirement for a network interconnection device when the incumbent local exchange carrier's network is disconnected from residential inside wire , Telecom Public Notice CRTC 2007-3, 19 March 2007, as amended by Proceeding to consider the requirement for a network interconnection device when a local exchange carrier's network is disconnected from residential inside wire , Telecom Public Notice 2007-3-1, 11 May 2007 (PN 2007-3-1), the parties are requested to respond to the interrogatories set out in the Attachments by 26 June 2007, serving copies on all other parties to the proceeding.

Bell Aliant Regional Communications, Limited Partnership and Bell Canada; MTS Allstream Inc.; Saskatchewan Telecommunications; Télébec, Société en commandite; and Telus Communications Company are to answer the Interrogatories set out in Attachment 1.

The Canadian Cable Systems Alliance (CCSA), Cogeco Cable Canada Inc., Quebecor Media Inc. on behalf of its affiliate Vidéotron ltée, Rogers Cable Communications Inc.; Shaw Communications Inc. and Bragg Communications Inc. (carrying on business as Eastlink) are to answer the Interrogatories set out in Attachment 2.

Globility Communications Corporation is to answer the interrogatories set out in Attachment 3.

Yours sincerely,

'Original signed by L. Fancy'

Lynne Fancy
A/Director - Competition Implementation and Technology
Telecommunications

Attach.

cc:   J. Mullaney, CRTC (819) 953-5255
       Interested parties to the PN 2003-3-1 proceeding

Attachment 1

1.    What, if any, arrangements are in place between the Company and the cable company (or companies) operating as a competitive local exchange carrier (CLEC) within the Company's territory, with respect to the disconnection of the Company's network from the customer's inside wire when the customer no longer wishes to use any services provided by the Company?   Provide all details including:

(a)    whether or not a network interconnection device (NID) is installed as part of the disconnection;

(b)    if so, the specifications of the NID, its advantages and disadvantages;

(c)    the cost of the NID and cost of installation;

(d)    who performs the work;

(e)    who pays for the cost of the NID and cost of installation; and

(f)     a copy of any written agreement or other document regarding this practice.

2.        (a)    Provide the number of the Company's residential customers at whose premises there is not currently a NID,

           (b)    Provide the number of the Company's residential customers that are also located within the operating territory of the cable company or companies that operate within the Company's territory; and

           (c)     Provide the number of NIDs installed for 2004, 2005 and 2006 by the Company, excluding NIDs installed in new builds.

3.    A residential customer is taking telephone service from a service provider using the network of an incumbent local exchange carrier (ILEC).   There is no NID installed.   The residential customer decides to no longer take any services provided on the ILEC's network and instead to take telephone service from a cable company operating as a CLEC.   The cable company will use the customer inside wire.   The customer then decides to terminate all service with the cable company and elects to re-take telephone service provided on the ILEC's network.

Provide a full description of the reconnection process including:

(a)   how the cable company's service is disconnected from the customer inside wire;

(b)   a copy of any written agreement or other document regarding this practice;

(c)   whether or not a NID is installed and, if so,

(i)    the specifications of the NID, its advantages and disadvantages;

(ii)   the cost of the NID and cost of installation;

(iii)   who performs the work; and

(iv)   who pays for the cost of the NID and cost of installation; and

(d)   who pays for the reconnection process.

4.    In the scenario described in question 3, for years 2004, 2005 and 2006, where repairs were required to the residential inside wire at the time of reconnection, provide the following:

(a)   a description of the type and the nature of the repairs;

(b)   the frequency of the damage;

(c)   who performed the repairs;

(d)   what were the average cost of repairs; and

(e)   who paid for the repairs.

5.    Describe the location of NIDs currently installed at the premises of residential customers in the Company's operating territory.   If NIDs have been installed at different locations in various premises, explain why.

6.    If as a result of the proceeding established by PN 2007-3-1, the Commission were to require the installation of a NID:

(a)   would the use of a NID that includes a switchable voice module (SVM), as described by Telus Communications Inc. in its submission dated 22 May 2007 , be appropriate?   Why or why not;

(b)   if the NID with a SVM would not be appropriate, describe the type of NID that should be installed.   State the cost of the NID, the costs of installation, and its advantages or disadvantages including its usefulness to the cable company as CLEC; and

(c)    where at the customer's premises should the NID be installed?   Explain why this is the appropriate location.

7.     In new subdivisions in your operating territory, where the Company as an ILEC installs infrastructure to each home, state:

(a)   whether the Company installs a NID in circumstances in which it will not be providing any services on its network to the residential customer; and

(b)   where a NID was not originally installed, whether the ILEC installs a NID when the customer later decides to take local exchange service from the Company.   If the NID then installed is different from the one described in Company's answer to question 3(c) above, provide all details for this NID.

8.    Given the Governor in Council's Direction to the CRTC on Implementing Canadian Telecommunications Policy Objectives (the Policy Directive) issued on 14 December 2006, which requires the Commission to rely on market forces to the maximum extent feasible to achieve the telecommunications objectives, should the Commission be setting a policy with respect to the situation described in paragraph 8 of PN 2007-3-1?

9.  If as a result of the proceeding established by PN 2007-3-1, the Commission were to require the installation of a NID, should the Commission set a standard for the NID to be installed, given the Policy Directive?

Attachment 2

1.   What, if any, arrangements are in place between the cable company operating as a competitive local exchange carrier (CLEC) and the incumbent local exchange carrier(s) (ILEC(s)) within whose territory the cable company operates, with respect to the disconnection of the ILEC's network from the customer's inside wire when the customer no longer wishes to use any services provided by the ILEC?   Provide all details including:

(a)    whether or not a network interconnection device (NID) is installed as part of the disconnection;

(b)    if so, the specifications of the NID, its advantages and disadvantages;

(c)    the cost of the NID and cost of installation;

(d)    who performs the work;

(e)    who pays for the cost of the NID and cost of installation; and

(f)      a copy of any written agreement or other document regarding this practice.

2.    A residential customer is taking telephone service from a service provider using the network of the ILEC.   There is no NID installed.   The residential customer decides to no longer take any services provided by on the ILEC'S network and instead to take telephone service from a cable company operating as a CLEC.   The cable company will use the customer inside wire.   In this scenario:

(a)   who pays for the costs of the cable company's connection; and

(b)    state whether the cable company informs the customer that a premises visit may be required for inside wire repairs should the customer want to migrate to any other service provider which utilizes the ILEC's network.   If so, provide a copy of any written communication with the customer and any other document regarding the transmission of such information to the customer.   If not, explain why not.

3.     If the customer described in question 2 subsequently decides to take services on the ILEC's network, describe how the customer inside wire is disconnected from the cable company's network.

4.    Provide the number of the residential customers located within the cable company's operating territory.

5.     If as a result of the proceeding established by PN 2007-3-1, the Commission were to require a NID to be installed:

(a)    would the use of a NID that includes a switchable voice module (SVM), as described by Telus Communications Inc. in its submission dated 22 May 2007 , be appropriate?   Why or why not;

(b)    if the NID with a SVM would not be appropriate, describe the type of NID that should be installed.   State the cost of the NID, the costs of installation and the usefulness of the NID to the cable company as CLEC; and

(c)    where at the customer's premises should the NID be installed?   Explain why this is the appropriate location.

6.     Given the Governor in Council's Direction to the CRTC on Implementing Canadian Telecommunications Policy Objectives (the Policy Directive) issued on 14 December 2006, which requires the Commission to rely on market forces to the maximum extent feasible to achieve the telecommunications objectives, should the Commission be setting a policy with respect to the situation described in paragraph 8 of PN 2007-3-1.

7.      If as a result of the proceeding established by PN 2007-3-1, the Commission were to require the installation of a NID, should the Commission set a standard for the NID to be installed, given the Policy Directive?

Attachment 3

1.     A residential customer is taking telephone service from a service provider using the network of an incumbent local exchange carrier (ILEC).   There is no network interconnection device (NID) installed.   The residential customer decides to no longer take any services provided on the ILEC's network and instead to take telephone service from a cable company operating as a competitive local exchange carrier (CLEC).   The cable company will use the customer's inside wire.   The customer then decides to terminate all service with the cable company and elects to re-take telephone service provided on the ILEC's network.

If you were the new service provider using the ILEC's network, provide a full description of the reconnection process including:

(a)     how the cable company's service is disconnected from the customer inside wire;

(b)   a copy of any documents regarding this practice;

(c)   whether or not a NID is installed and, if so,

(i)    the specifications of the NID, its advantages and disadvantages,

(ii)    the cost of the NID and cost of installation,

(iii)   who performs the work, and

(iv) who pays for the cost of the NID and the cost of installation; and

(d)   who pays for the reconnection process.

2.     In the scenario described in question 1, for years 2004, 2005 and 2006, where repairs were required to the residential inside wire at the time of reconnection, provide the following:

(a)    a description of the type and the nature of the repairs;

(b)    the frequency of the damage;

(c)    who performed the repairs;

(d)    what were the average cost of repairs; and

(e)    who paid for the repairs.

3.    If as a result of the proceeding established by PN 2007-3-1, the Commission were to require a NID to be installed:

(a)    would the use of a NID that includes a switchable voice module (SVM), as described by Telus Communications Inc. in its submission dated 22 May 2007 , be appropriate?   Why or why not;

(b)    if the NID with a SVM would not be appropriate, describe the type of NID that should be installed.   State the cost of the NID, the costs of installation and the usefulness of the NID to the cable company as CLEC; and

(c)    where at the customer's premises should the NID be installed?   Explain why this is the appropriate location.

4.      Given the Governor in Council's Direction to the CRTC on Implementing Canadian Telecommunications Policy Objectives (the Policy Directive) issued on 14 December 2006, which requires the Commission to rely on market forces to the maximum extent feasible to achieve the telecommunications objectives, should the Commission be setting a policy with respect to the situation described in paragraph 8 of PN 2007-3-1?

5.     If as a result of the proceeding established by PN 2007-3-1, the Commission were to require the installation of a NID, should the Commission set a standard for the NID to be installed, given the Policy Directive?

Distribution List :

regaffairs@quebecor.com ;  regulatory.affairs@telus.com ;  regulatory@bell.aliant.ca ;  ken.engelhart@rci.rogers.com ;  document.control@sasktel.sk.ca ;  natalie.macdonald@corp.eastlink.ca ;  Regulatory@sjrb.ca ;  telecom.regulatory@cogeco.com ;  bell.regulatory@bell.ca ;  iworkstation@mtsallstream.com ;  benrovet@rogers.com ;  cedwards@ccsa.cable.ca ;  reglementa@telebec.com ;