ARCHIVED - Letter

Ottawa, 22 July 2009

File No.:   8663-C12-200907321

BY E- MAIL

Distribution

Re: Telecom Notice of Consultation CRTC 2009-261, Proceeding to consider the appropriateness of mandating certain wholesale high-speed access services

Pursuant to the procedures specified at paragraph 22 of Telecom Notice of Consultation CRTC 2009-261, attached are the Commission interrogatories associated with this proceeding.

Relevant parties are to file their responses with the Commission, serving a copy on all other parties, by 10 August 2009.   These responses are to be received, and not merely sent, by this date.

Appendix 1 contains the distribution list.

Appendix 2 contains interrogatories to designated incumbent local exchange carriers, cable carriers and competitors.

Appendix 3 contains tables to be filled in for responses to specific interrogatories.

Yours sincerely,

Original signed by 

Paul Godin
Director General
Competition, Costing and Tariffs

Attachment (3)

Appendix 1:   Distribution List

regulatoryaffairs@nwtel.ca ;  bell.regulatory@bell.ca ;  regulatory.affairs@telus.com ;  reglementa@telebec.com ;  document.control@sasktel.sk.ca ;  iworkstation@mtsallstream.com ;  regulatory@bell.aliant.ca ;  Regulatory.Matters@corp.eastlink.ca ;  Regulatory@sjrb.ca ;  marcel.mercia@cybersurf.com ;  reglementation@xittel.net ;  regulatory@distributel.ca ;  lisagoetz@globalive.com ;  regulatory@primustel.ca ;  telecom.regulatory@cogeco.com ;  regaffairs@quebecor.com ;  ken.engelhart@rci.rogers.com ;  crtc@mhgoldberg.com ;  eric@rothschildco.com ;  gfletcher@incentre.net ;  berzins@nucleus.com ;  babramson@mccarthy.ca ;  regulatory@execulink.com ;  ctacit@tacitlaw.com ;  abriggs@cogeco.ca ;  slavalevin@ethnicchannels.com ;  crtc@les.net ;  LBC_Consulting@live.ca ;  andre.labrie@mcccf.gouv.qc.ca ;  bob.Allen@abccomm.com ;  ghariton@sympatico.ca ;  lefebvre@rogers.com ;  kirsten.embree@fmc-law.com ;  bruce@brucebuchanan.net ;  jonathan.holmes@ota.on.ca ;  cataylor@cyberus.ca ;  chris.allen@abccomm.com ;  regulatory@vianet.ca ;  piac@piac.ca ;  tom.copeland@caip.ca ;  hemond@consommateur.qc.ca ;  blackwell@giganomics.ca ;  jhpratt@msn.com ;  crtc@paul.ca ;  pris@pris.ca ;  regulatory@lya.com ;

Appendix 2:   Interrogatories

Interrogatories to the following incumbent local exchange carriers (ILECs):

• Bell Aliant Regional Communications, Limited Partnership, Bell Canada and Télébec, Société en commandite (collectively, The Bell Companies);
• TELUS Communications Company (TELUS);
• Saskatchewan Telecommunications (SaskTel); and
• MTS Allstream Inc. (MTS Allstream)

1.  For July 2009 (or for the most recent month of available data), for each incumbent operating territory by province, provide the following information:

a. The total number of Central offices (COs).

b. The total number of DSL -capable COs.

c. The total number of local wireline NAS, further broken down between business and residence.

d. The total number of DSL -capable NAS, further broken down between business and residence.

e. The total number of DSL -capable NAS in COs where there is at least one co-located competitor, further broken down between business and residence.

f. The total number of retail DSL high-speed service lines broken down between business and residence

g. The total number of wholesale aggregated ADSL access service lines broken down between business and residence

h. The total number of retail DSL high-speed service lines and the maximum service speed   provisioned over DSLAM equipment located at:

i. The ILEC CO.

ii. ILEC remotes (non-FTTN).  

iii. ILEC FTTN remotes.

i. The total number of wholesale aggregated ADSL access service lines and the maximum service speed   provisioned over DSLAM equipment located at:

i. The ILEC CO.

ii. ILEC remotes (non-FTTN).

iii. ILEC FTTN remotes.

2. Provide the three year forecast of DSL capable NAS broken down by the serving DSLAM equipment, located at:

i. The ILEC CO .

ii. ILEC remotes (non-FTTN).

iii. ILEC FTTN remotes.

3. For July 2009 (or for the most recent month of available data), for each DSL -capable CO where there is at least one co-located competitor, provide the information requested below by filling out Table 1.

a. The list of COs, by name, for each ILEC operating territory.

b.  Identify the total number of local wireline NAS served by each CO.

c.  Identify the number of DSL capable NAS served by each CO.

d.  The number of co-located competitors at each CO.

e.  Identify, separately for residential and business customers, the number of retail DSL high-speed service lines provisioned over DSLAM equipment located at:

i. The ILEC CO.

ii. ILEC remotes (non-FTTN).

iii. ILEC FTTN remotes.

f. Identify, separately for residential and business end-customers, the number of wholesale aggregated ADSL access service lines provisioned over DSLAM equipment located at:

i. the ILEC CO.

ii. ILEC remotes (non-FTTN).

iii. ILEC FTTN remotes.

g. Identify the number of unbundled data loop end-customers.

h. Identify the number of line-sharing end-customers.

4. Provide the three-year total demand forecast with rationale, separately for retail and wholesale, for each of the following scenarios:

 i. The Commission mandates a narrow ADSL-CO service (e.g. Option 1 for Bell Companies or a ADSL-CO service limited to max. speed provided as at 3 March 2008, as proposed by TELUS), describing the narrow ADSL-CO service.

 ii. The Commission mandates an ADSL-CO service at max. speed available to ILEC retail customers; and

 iii. An ADSL-CO service is not mandated.

5.  See ILEC-specific Question 5 for the Bell Companies, TELUS, SaskTel, and MTS Allstream.

6. TELUS in its submission noted that, if required, it would provide the ADSL-CO service at the maximum speeds that were available on 3 March 2008 , the date that the Commission released Decision 2008-17.

a. Identify the maximum speeds that the company offered to its customers for its retail DSL high-speed services as of 

 i. 3 March 2008,

 ii. July 2009.

b. Comment, with supporting rationale, on TELUS' proposal to limit the ADSL-CO service offering to speeds available as at 3 March 2008 .

c. What activities, processes, equipment and / or costs would need to be incurred to impose speed restrictions for wholesale end-customers.

7.  Provide, with detailed reasons, the company's views on whether resale-based competition (e.g. using aggregated ADSL access) relative to competition that places greater reliance on self-supplied facilities (e.g. using ADSL-CO service), represents (a) a more sustainable basis for retail service competition and (b) permits greater innovation in retail service features and greater pricing flexibility. The response should relate the company's view to section 7 of the Telecommunications Act and to the Policy Direction.

8.  Provide, with reasons, the company's views on the proposition that the concepts of (a) regulatory symmetry and (b) competitive neutrality, as each applies to wholesale services provided by ILECs and incumbent cable carriers and relates to the achievement of the objectives of section 7 of the Telecommunications Act , should take into account differences in these carriers' specific network architectures. Explain the technical differences, if any, that would warrant asymmetric provision of the high-speed access service at the CO relative to the cable carriers' local head-end based service.

9.  See ILEC-specific Question 9 for the Bell Companies.

10.  See ILEC-specific Question 10 for the Bell Companies.

  Interrogatories for Bell Companies

5.  The Bell Companies proposed four options for ADSL-CO service. Options 1 and 2 allow competitors to offer service to end-customers served by legacy remotes while Options 3 and 4 allow competitors to serve all end-customers.  

The Bell Companies also submitted that Bell Canada has standardized a new Ethernet Layer 2 switch that can connect to its ATM DSLAMs. It further submitted that standardization of the new devices was initiated as part of a plan to relieve congestion in certain areas of the network.

a.  For each CO listed in response to question 2 (as per Table 1), identify whether the CO is equipped with an Ethernet switch, ATM Layer 2 switch, or both.

b.  With respect to the start-up cost estimates associated with Option 3, provide breakdown of the start-up costs into its major components, identifying the major resources and the associated resource unit costs, and the associated number of COs assumed with rationale. Further, the company should identify the timeframes required to appropriately equip a CO once a firm order for ADSL-CO service is received.

c. Further provide a per CO estimate of the start-up costs associated with offering a universal ADSL CO service under Option 3 for each of the four scenarios identified below:

 i. ATM Layer 2 switches are being replaced with the standardized Ethernet Layer 2 switches to relieve congestion.

 ii. ATM Layer 2 switches are being replaced with the standardized Ethernet Layer 2 switches to accommodate the competitors ADSL-CO service request.

 iii. Ethernet Layer 2 switches are installed at COs that do not currently have a Layer 2 switch.

 iv. An Ethernet Layer 2 switch does not need to be added as it already exists.

d. Provide a revised start-up cost estimate for Option 3, assuming that the service would be initially developed only for the COs where competitor(s) are already co-located.

e. Provide details, including start-up cost estimates of an ADSL-CO option that would allow competitors to offer high-speed access service to all end-customers currently served by the ILEC using its remote or FTTN located DSLAMs. In estimating costs assume that the service would be initially developed only for the COs where competitor(s) are currently co-located.

f.  With respect to the Bell Companies' proposed Option 3, comment on the following approaches to recover the costs caused by competitors when the ADSL-CO service is implemented at a particular CO:

 i. Applying a minimum demand threshold of competitor end-cus tom ers per CO (e.g. requirement for term and volume commitment) to make the service viable; the response should provide an estimate of this minimum threshold and the associated unit start-up cost impact.

• ii.   Applying a minimum upfront charge per co-located competitor; the response should provide an estimate of the upfront charge per competitor, as well as the minimum number of co-located competitors required per CO.

 

9.  In paragraph 99 of their submission, the Bell Companies submitted that, where an ILEC is forced to provide wholesale high-speed access service over its own FTTN network, it cannot provide its IPTV service to an end-user subscribing to a wholesaler's high-speed Internet service over the same line.

g.  When the Bell Companies provision both high-speed internet service and IPTV service to an end-customer, identify the expected percentage of end-customers that will be provisioned using the same copper pair.

h.  In circumstances where both services are provisioned on the same copper-pair, identify the expected percentage of end-customers that would have an available spare copper-pair.

i.  Where both retail services are provisioned over the same copper-pair, describe the service limitation or conditions imposed on the retail high-speed internet access service.

j.  Identify and describe the technical limitations, if any, that would prevent the ILEC from provisioning wholesale ADSL-CO service and ILEC retail IPTV service:

 i.   On the same copper-pair;

 ii. On separate copper-pairs, where available.

k.  Identify any service limitations or conditions that would be imposed on the wholesale ADSL-CO service, if the end-customer chooses to subscribe to a competitor's high-speed DSL service that relies on the ASDL-CO service and also subscribe to the ILEC's retail IPTV service and both services are provisioned on the same copper-pair .

10.  The Bell Companies in paragraph 185 of their submission stated that over the course of 2009 they plan to install a number of Layer 2 switches to relieve congestion in their aggregation network. In paragraph 188 the Bell Companies further noted that in order to provide ADSL-CO service they would have to connect and migrate the traffic from all the DSLAMs in that CO to the new Layer 2 switch and provision new interfaces in the switch to deliver the traffic to wholesale customers.

l.  Identify the COs that have been designated for installation of new Layer 2 switches to relieve congestion in the aggregation network in 2009.

m.  Explain whether the step of migrating traffic over to the new Layer 2 switch is necessary to relieve congestion in the aggregation network. If the step is necessary, explain why.

n.  If migration of all traffic to the new Layer 2 switch is not being initially contemplated, describe what new or existing customers would be migrated to the new switch.

Interrogatories for SaskTel

5. SaskTel in its submission noted that ADSL-CO service would not be available to end-user locations that are not within the service area of an appropriately equipped wire centre. SaskTel further noted that in order to be appropriately equipped, a SaskTel wire centre must contain both Ethernet-based ADSL equipment and broadband aggregation equipment.

a.  For each CO listed in response to question 2 (as per Table 1) identify whether the CO is appropriately equipped.

b.  With respect to the introduction of an ADSL-CO service, provide the company's estimate of the start-up costs, identifying the major resources and the associated resource unit costs and the associated number of COs assumed with rationale. Further, the company should identify the timeframes required to appropriately equip a CO once a firm order for ADSL-CO service is received.

c.  Further provide a per CO estimate of the start-up costs associated with offering a ADSL CO service for each of the two scenarios identified below:

 i. The CO is appropriately equipped.

ii. The CO is not appropriately equipped.

d.  Comment on the following approaches to recover the costs caused by competitors when the ADSL-CO service is implemented at a particular CO:

 i. Applying a minimum demand threshold of competitor end-cus tom ers per CO (e.g. requirement for term and volume commitment) to make the service viable; the response should provide an estimate of this minimum threshold and the associated unit start-up cost impact.

 ii. Applying a minimum upfront charge per co-located competitor; the response should provide an estimate of the upfront charge per competitor, as well as the minimum number of co-located competitors required per CO.

 

  Interrogatories for MTS Allstream

5.  MTS Allstream stated that the ADSL-CO service could be deployed on request at virtually any CO in Manitoba . The service may require the addition of an Ethernet switch or MPLS router in certain COs .

a.  For each CO listed in response to question 2 (as per Table 1) identify whether the CO is equipped with Ethernet switch or MPLS router.

b.  With respect to the introduction of an ADSL-CO service, provide the company's estimate of the start-up costs, identifying the major resources and the associated resource unit costs and the associated number of COs assumed with rationale. Further, the company should identify the timeframes required to appropriately equip a CO once a firm order for ADSL-CO service is received.

c.  Further provide a per CO estimate of the start-up costs associated with offering a ADSL CO service for each of the three scenarios identified below:

 

 i. The CO requires the addition of an Ethernet Switch.

ii. The CO requires the addition of an MPLS router.

 iii. The CO is already equipped with an Ethernet Switch or MPLS router.

d. Comment on the following approaches to recover the costs caused by competitors when the ADSL-CO service is implemented at a particular CO:

 i. Applying a minimum demand threshold of competitor end-cus tom ers per CO (e.g. requirement for term and volume commitment) to make the service viable; the response should provide an estimate of this minimum threshold and the associated unit start-up cost impact.

ii. Applying a minimum upfront charge per co-located competitor; the response should provide an estimate of the upfront charge per competitor, as well as the minimum number of co-located competitors required per CO.

  Interrogatories for TELUS

5.  TELUS in its submission indicated that it has both ATM-connected DSLAMs and Ethernet-connected DSLAMs. TELUS submitted that where ATM-connected DSLAMs are used an additional protocol conversion step involving an ATM/Ethernet gateway has to be undertaken, with possible inter-office connectivity expenses which have to be borne by competitors. TELUS further noted that an Ethernet concentrator switching equipment is required at every CO where competitors require the ADSL-CO service.

a.  For each CO listed in response to question 2 (as per Table 1), identify whether the CO is equipped with Ethernet or ATM concentrators.

b.  For each CO listed in response to question 2 (as per Table 1), identify whether end-customers are served by ATM-connected DSLAMs or Ethernet-connected DSLAMs or both.

c.  Provide the reasons why competitors cannot be offered with a choice of ATM-based or Ethernet-based NNI connectivity at each serving CO, based on availability.

d.  If competitors are offered a choice of NNI connectivity, based on availability, indicate whether:

 i. there would be a need to install Ethernet concentrator switching equipment at COs, with the exception of growth; and

ii. there is any reason for Ethernet gateway equipment and related inter-office connectivity expenses to apply.

 

e.  With respect to the introduction of an ADSL-CO service, provide the company's estimate of the start-up costs, identifying the major resources and the associated resource unit costs and the associated number of COs assumed with rationale. Further, the company should identify the timeframes required to appropriately equip a CO once a firm order for ADSL-CO service is received.

f.  Further provide a per CO estimate of the start-up costs associated with offering a ADSL CO service for each of the two scenarios identified below:

 

 i. The CO is requires the addition of an Ethernet concentrator.

 ii. The CO is equipped with an Ethernet concentrator.

g.  Comment on the following approaches to recover the costs caused by competitors when the ADSL-CO service is implemented at a particular CO:

 i. Applying a minimum demand threshold of competitor end-cus tom ers per CO (e.g. requirement for term and volume commitment) to make the service viable; the response should provide an estimate of this minimum threshold and the associated unit start-up cost impact.

 ii. Applying a minimum upfront charge per co-located competitor; the response should provide an estimate of the upfront charge per competitor, as well as the minimum number of co-located competitors required per CO.

 

h.  Identify the COs that currently have the ATM/Ethernet Gateway equipment and provide a list of COs with ATM concentrators that each Ethernet Gateway switch serves.

  Interrogatories to the following Cable Carriers:

•  Bragg Communications Inc. (Bragg);

•  Cogeco Cable Inc. (Cogeco);

•  Quebecor Media Inc. on behalf of its affiliate Videotron Ltd. (Videotron);

•  Rogers Communication Inc. (Rogers); and

•  Shaw Communications Inc. (Shaw)

1.  For July 2009 (or for the most recent month of available data), for each cable carrier operating territory by province, provide the following information:

 

a. The total number of local head-ends.

b.  The total number of high-speed internet service capable local head-ends.

c.  The total number of cable subscribers.

d.  The total number of high-speed internet-capable subscribers.

e.  The total number of retail high-speed service customers broken down between business and residence, if applicable.

f.  The total number of TPIA service end-customers.

 

2.  For July 2009 (or for the most recent month of available data), for each high-speed access capable local head-end, provide the information requested below by filling out Table 2.

 

a.  The list of local head-ends, by name, for each cable carrier operating territory.

b.  Identify whether the local head-end is a designated Point of Interconnection ( POI ) location.

c.  Identify the name of the POI location serving each local head-end.

d.  Identify the total number of cable subscribers served by each local head-end.

e.  Identify the number of high-speed capable subscribers served by each local head-end.

f.  Identify the number of competitors interconnected at each POI .

g.  Identify, the number retail high-speed internet subscribers by each local head-end.

h.  Identify, the number TPIA end-customers by each local head-end.

 

3.  Provide the three year demand forecast of high-speed internet access retail . Provide your response in view of each of the following regulatory scenarios providing rationale and supporting evidence for any differences in outcome between the scenarios:

i. Cable carriers are not required to offer competitors a local head-end based high-speed access service; and

 ii. Cable carriers are required to offer competitors a local head-end based high-speed access service.

4. With regards to the local head-end based high-speed access service for competitor use:

a.  Provide an estimate of the start-up costs per local head-end, identifying the major resources and the associated resource unit costs. Further provide the timeframe required to appropriately equip a local head-end once a firm order for local head-end based high-speed access service is received from a competitor.

b. With respect to the response to part a) above, comment on the following approaches to recover the costs caused by competitors when the local head-end based high-speed access service is implemented at a particular head-end:

i. Applying a minimum demand threshold of competitor end-cus tom ers per local head-end (e.g. requirement for term and volume commitment) to make the service viable; the response should provide an estimate of this minimum threshold and the associated unit start-up cost impact.

 ii. Applying a minimum upfront charge per competitor; the response should provide an estimate of the upfront charge per competitor, as well as the minimum number of competitors required per local head-end

 

5. Refer to section 7.2 of the Bell Companies’ submission regarding the possible solutions for Wholesale Access to Cable Network.

a. Provide the company’s comments on the technical and economic feasibility and the practicality of each of the solutions listed below for providing access to competitors as proposed by the Bell Companies in their submission. Provide a discussion of any technical issues, the start-up cost estimates for each solution, and where required, the costs of providing co-location to a competitor:

i. Solution 5 – RF Channel with partitioned CMTS

ii. Solution 6 – RF Channel with ISP CMTS

iii. Solution 7 – Open PacketCable (Logical Bandwidth Unbundling)

b. The Bell Companies submitted in paragraph 223 of their submission that additional cable bandwidth would be freed up when cable networks have migrated to digital distribution. Identify when the company expects to migrate its cable services to digital and comment on the anticipated number of RF channels that would be freed up at that time, and the availability of any such capacity for provision of channels to competitors.

c. With respect to part b) above, provide a detailed description and associated competitor interconnection arrangement on how any spare channels could be made available as an input to competitors for providing a high-speed access service.

6. Provide, with detailed reasons, the company’s views on whether resale-based competition (e.g. using TPIA) relative to competition that places greater reliance on self-supplied facilities (e.g. using local head-end based high-speed access service), represents (a) a more sustainable basis for retail service competition and (b) permits greater innovation in retail service features and greater pricing flexibility. The response should relate the company’s view to section 7 of the Telecommunications Act and to the Policy Direction.

7. Provide, with reasons, the company’s views on the proposition that the concepts of (a) regulatory symmetry and (b) competitive neutrality, as each applies to wholesale services provided by ILECs and incumbent cable carriers and relates to the achievement of the objectives of section 7 of the Telecommunications Act, should take into account differences in these carriers’ specific network architectures. Explain the technical differences, if any, that would warrant asymmetric provision of the high-speed access service at the local head-end relative to the ILECs ADSL-CO service.

8. Provide, with reasons, your views on the extent to which provision of the wholesale service requested by Cybersurf would raise competitive neutrality concerns. Include a discussion of whether doing so:

a. Would artificially favour competitors using the service to offer voice and data services to their end-customers relative to the cable carriers’ who utilize distinct channels for each service.

b. Would artificially favour competitors using a cable carrier’s access network relative to competitors using an ILEC access network, who would need, with some exceptions, to obtain separate wholesale services to provision voice and data services.

Interrogatories to:

1. As of July 2009, by ILEC, provide a list of all ILEC COs that you are co-located at.

a. For each co-located CO:

i. Separately indicate the residential and business services offered to end-customers

ii. Identify the number of end-customers served using self-provisioned DSLAMs.

iii. Identify the number of end-customers served using the ILECs aggregated ADSL service.

iv. Identify whether you self supply your transport facilities to the co-location space.

c. For COs where you are not co-located (all other COs):

i. Identify the number of end-customers served using the ILECs aggregated ADSL service.

2. If a wholesale ADSL-CO service as contemplated in this proceeding, is mandated at the following price points per end-customer: (i) 25% below the current lowest aggregated ADSL access price; and (ii) 50% below the current lowest aggregated ADSL access price. For each of the price points identified:

a. Describe the company’s plans to offer high-speed internet access service to residential and business customers and associated demand forecasts over the next five years by CO.

b. Identify the forecasted additional ILEC COs where the company plans to co-locate over the next five years

c. Identify with supporting rationale the price point that the company expects to pay for the ADSL-CO service, and if different from that proposed above provide revised demand estimates and co-location plans over the next five years.

3. If a wholesale local head-end based high-speed access service as contemplated in this proceeding, is mandated at the following price points per end-customer: (i) 25% below the current lowest TPIA price; and (ii) 50% below the current lowest TPIA price. For each of the price points identified:

a. Describe the company’s plans to offer high-speed internet access service to residential and business customers and associated demand forecasts over the next five years by local head-end.

b. Identify with supporting rationale the price point that the company expects to pay for the local head-end based high-speed access service, and if different from that proposed above provide revised demand estimates over the next five years.

4. Provide the company’s views on the Bell Companies submission that it is possible for co-located competitors using their own DSLAMs, in conjunction with unbundled data loops or line-sharing service, to provide internet access to the vast majority of Bell Companies’ end-users.

5. With reference to the three competitor input services listed below, provide your views with supporting rationale on competitor investments required; the risks that would be incurred; and the market opportunities available for innovation and profit. Further, describe with supporting rationale which of the three scenarios, either by itself or in combination, would best serve consumers in the downstream market.

i. The existing aggregated ADSL access (GAS/HAS) service as an input to offer high-speed internet access services to all end-users that the ILEC is able to serve.

ii. The contemplated ADSL-CO service used as an input to offer high-speed internet access services to all end-users that the ILEC is able to serve.

iii. The contemplated ADSL-CO service to access only ILEC remote served end-users (includes legacy and growth remotes).

6. Refer to paragraph 154 of the Bell Companies’ submission, where it stated, “Should the Commission nevertheless grant cost-based access to FTTN facilities through an ADSL-CO service, a pricing structure that would adequately recognize the financial risks that the Companies had undertaken would be necessary. One such structure would require competitors to provide a one-time payment for each end-user they access via such facilities”.

a. Provide the company’s view on the above pricing structure proposed by the Bell Companies requiring one-time payments for each end-customer.

b. If the company does not agree with the Companies’ pricing proposal for an ADSL-CO service offered over the FTTN network, provide the company’s proposal for a pricing approach for this service that would take into account the suggested financial risk of the Companies.

c. Provide the company’s view on whether the ILECs should be compensated for their potential revenue loss associated with other services such as IPTV, if a wholesale service is made available over the FTTN architecture. If not, explain why not.

7. With reference to competitors offering retail high-speed internet access service to its end-customers:

a. Describe any input facilities beyond those offered by ILECs or cable carriers that the company currently utilizes to offer retail high-speed internet access services to its end-customers.

b. Identify, separately, the number of residential and business end-customers served using the alternate input facilities identified in response to part a).

c. Describe why the company decided to use the specific alternative input facilities noted above and include the pros and cons of each alternative.

8. Describe any input facilities beyond those offered by ILECs or cable carriers that the company considered using, but determined not to use to offer retail high-speed internet access services to its end-customers. Include your company’s view of the pros and cons of each alternative considered.

9. With respect to using ILEC or cable carrier access facilities as an input to offer retail high-speed internet access services to end-customers:

a. Identify whether the company currently uses the aggregated ADSL access service from ILECs and / or the TPIA service from cable carriers, with detailed rationale for the choice of input service provider, including the company’s views on the pros and cons of using either service.

b. If the Commission were to mandate both the ADSL-CO service and the local head-end based cable high-speed access service, describe the basis that the company would use to select its input service provider.

10. Provide, with detailed reasons, the company’s views on whether resale-based competition (e.g. using TPIA) relative to competition that places greater reliance on self-supplied facilities (e.g. using local head-end based high-speed access service), represents (a) a more sustainable basis for retail service competition and (b) permits greater innovation in retail service features and greater pricing flexibility. The response should relate the company’s view to section 7 of the Telecommunications Act and to the Policy Direction.

11. Provide, with reasons, the company’s views on the proposition that the concepts of (a) regulatory symmetry and (b) competitive neutrality, as each applies to wholesale services provided by ILECs and incumbent cable carriers and relates to the achievement of the objectives of section 7 of the Telecommunications Act, should take into account differences in these carriers’ specific network architectures. Explain the technical differences, if any, that would warrant asymmetric implementation of the high-speed access service at the local head-end relative to the ILECs ADSL-CO service.

12. Provide, by POI as of 31 July 2009, the total number of your company’s customers with high-speed Internet access service provided using TPIA service.

13. If a wholesale local head-end based high-speed access service POI is mandated:

a. Describe the company’s plans to offer high-speed internet access service to residential customers and associated demand forecasts over the next five years by local head-end or municipality. The response should identify the price points that the company would expect to pay in support of its demand forecast.

b. Identify the forecasted local head-ends where the company plans to co-locate over the next five years

14. With reference to the existing TPIA service and a mandated local head-end based high-speed access service, provide the company’s views with supporting rationale on competitor investments required; the risks that would be incurred; and the market opportunities available for innovation and profit. Further, describe with supporting rationale on how these services, either by itself or in combination, would best serve consumers in the downstream market.

15. Provide, with reasons, your views on the extent to which provision of the wholesale service requested by Cybersurf would raise competitive neutrality concerns. Include a discussion of whether doing so:

a. Would artificially favour competitors using the service to offer voice and data services to their end-customers relative to the cable carriers’ who utilize distinct channels for each service.

b. Would artificially favour competitors using a cable carrier’s access network relative to competitors using an ILEC access network, who would need, with some exceptions, to obtain separate wholesale services to provision voice and data services.

Appendix 3:   Tables

Table 1: Table format for Question 2 to ILECs

Table 2:   Table format for Question 2 to Cable Carriers

Date modified:

2009-07-22