ARCHIVED - Letter

Ottawa, 16 October 2009

Our Reference: 8740-B2-200904989
                    8740-B54-200904971

BY EMAIL

Distribution

Dear Madams, Sirs:

Re: Bell Aliant Tariff Notice 242 and Bell Canada Tariff Notice 7181

The Bell companies are requested to respond to the supplemental interrogatories provided in attachment 1. The ISPs are requested to respond to the interrogatories provided in attachment 2.

A copy of each interrogatory response must be served on all other parties by 3 November 2009. When 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,

Original signed by

Paul Godin
Director General
Competition, Costing & Tariffs Telecommunications

c.c.: Richard Pagé, CRTC 819-997-4298, richard.page@crtc.gc.ca
Daphne Fry, CRTC 819-953-5373, daphne.fry@crtc.gc.ca

Distribution List

Bell Aliant, regulatory@bell.aliant.ca
Bell Canada, bell.regulatory@bell.ca
Canadian Association of Internet Providers, tom.copeland@caip.ca
Union des consommateurs, union@consommateur.qc.ca
The Coalition of Internet Service, regulatory@cfai-cisp.ca
Vaxination Informatique, jfmezei@vaxination.ca
EGATE Networks Inc., info@egate.net
Primus Telecommunications Canada Inc., regulatory@primustel.ca
Ontario Telecommunications Association, jonathan.holmes@ota.on.ca
Execulink Telecom, kstevens@execulink.com
Distributel Communications Limited, regulatory@distributel.ca
Aventures en Excellence Inc (AEI Internet), info@aei.net
MTS Allstream Inc., iworkstation@mtsallstream.com
Cybersurf Corp., marcel.mercia@cybersurf.com
Managed Network Systems, Inc., clayton@MNSi.Net
Yak Communications, lisagoetz@globalive.com
TekSavvy Solutions Inc., info@teksavvy.com
Christian Tacit, ctacit@tacitlaw.com
Acanac Inc., paul@acanac.ca
Electronic Box Inc., regulatory@electronicbox.net
Accelerated Connections, mgarbe@dsl4u.ca
Telnet Communications, regulatory@telnetcommunications.com
AOL Canada Inc., regulatoryca@aol.com

Attachment 1

Questions to the Bell Companies

1. Refer to pages 1 to 3 of the response to The Companies(CRTC)20Aug09-4(a) TN 242 & 7181.

a. Further refer to paragraph 52 of Execulink’s submission dated 14 April 2009 where it states that any customer of Execulink can access Execulink’s network from any telephone number associated with another GAS customer. Further refer to paragraph 16 of the Bell companies’ reply comments dated 5 June 2009 where they state that GAS customers should be able to maintain records of their end users’ WTNs and should be able to associate usage data with that WTN.

Assume a scenario where two different end-user customers of a GAS-ISP (ISP-1) access ISP-1`s network -- at different points in time during a single billing period -- using a WTN that is not associated with ISP-1 (i.e. WTN is associated with another GAS-ISP), thereby generating uncorrelated usage for which ISP-1 would be billed.

 

If ISP-1 wants (i) to implement its own usage based billing with its end-users and (ii) to reconcile its GAS bill with its own records, explain how ISP-1 would be able to associate the uncorrelated usage in question with each of its two end-user customers.

b. Confirm that:

i. uncorrelated usage will also arise in the following sample scenario: two family members reside at the same address with a single WTN associated with ISP-1, one member has and uses an Internet account with ISP-1, the other member has and uses an Internet account with a different ISP (ISP-2) that is a GAS customer;

ii. in the scenario identified in (i) above where the use of ISP-2 service would appear as uncorrelated usage, this uncorrelated usage would be included on ISP-2's GAS bill.

c. Confirm that the Bell companies can identify the login ID associated with any usage. If not, explain why not.

d. If the Bell companies can identify the login ID associated with any usage, comment on the feasibility and the implications of including on their GAS customers’ bills the login ID information and associated usage. Include the companies’ estimated costs, and supporting assumptions, associated with providing this additional billing information.

e. Confirm that the Bell companies are able to assign uncorrelated usage to the telephone number from which that usage originated. If not, explain why not.

f. If the Bell companies are able to assign uncorrelated usage to the telephone number from which that usage originated, comment on the feasibility and the implications of charging each GAS customer for the aggregated usage (correlated and uncorrelated) originating from the telephone number of a GAS customer’s end-user. In this scenario, it is assumed that the Bell companies would assign uncorrelated usage to the telephone number from which that usage originated and therefore to the GAS end-user responsible for that telephone number.

g. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users.

2. Refer to column C titled “Frequency of activity per trouble ticket” in the table shown on page 3 of the response to The Companies(CRTC)20Aug09-11 TN 242 & 7181. With respect to the activity labelled “Outgoing Calls”, describe the types of outgoing calls and provide the reasons that explain the frequency value provided in the table, identifying the source and vintage of the data used to determine the frequency value, and indicating whether this frequency value is based on only wholesale GAS customer inquiries.

If the frequency value is not based on only wholesale GAS customer inquiries, explain why not, and further provide an estimate of the frequency based on only wholesale GAS customer inquiries, with supporting rationale.

3. Refer to table 1 in the attachment to the response to The Companies(CRTC)20Aug09-15 TN 242 & 7181:

a. Provide the proportion of the costs causal to the introduction of UBB that was incurred prior to Telecom Order 2009-484, including a description of these costs.

b. Provide the Bell companies’ views on whether the costs causal to the introduction of UBB incurred prior to Telecom Order 2009-484 as identified in response to a) above should be treated as pre-introduction costs.

c. Explain whether most of the costs causal to the introduction of wholesale UBB were estimated based on an allocation of UBB costs that are common to both retail and wholesale. If so, provide the methodology and assumptions used to allocate these common UBB costs to wholesale UBB, with supporting rationale.

4. Refer to table 5c of the Bell companies’ economic evaluation report and to the table titled “2004 Cost Studies – As Filed” on page 2 of the response to The Companies(CRTC)20Aug09-17 TN 242 & 7181:

a. With respect to the table titled “2004 Cost Studies – As Filed”, for each of (i) the 128 Kbps, (ii) the 3 Mbps, and (iii) the 4 Mbps speed options, provide the in-service GAS access demand for the month preceding the date of the upgrade of the 3 Mbps and 4 Mbps services to 5 Mbps, specifying the month.

b. With respect to the table titled “2004 Cost Studies – As Filed”, for the 3 Mbps speed options, for each of the (i) switching equipment and (ii) transmission equipment, provide the monthly capital causal to demand cost per access.

c. For each of (i) switching and (ii) transmission equipment capital causal to demand costs, explain the differences between the monthly costs per access provided in response to b) above and those provided in table 5c, identifying the differences in costing methodologies and assumptions, with supporting rationale for any significant differences.

5. Refer to page 2 of the response to The Companies(CRTC)20Aug09-8 TN 242 & 7181:

a. Confirm that to estimate the costs provided in the Bell companies’ economic evaluation report, the average usage per end-user per month was applied to the IFC per Kbps at the peak period as identified at page 3 of the response to The Companies(CRTC)20Aug09-7 TN 242 & 7181.

b. Provide the methodology and assumptions used in estimating the average usage per end-user per month associated with the Residence – Lite Plus speed option.

c. For each of (i) Residence – Lite, (ii) Residence - Lite Plus and (iii) Residence - Basic, provide a revised estimate of the average usage per end-user per month based on the Bell companies’ expectation of curtailment for usage greater than the respective monthly usage allowances of 2 GB, 20 GB and 60 GB following the implementation of UBB. Further provide the methodology and assumptions used to estimate the usage curtailment, with supporting rationale.

d. With respect to the table titled “2009 Cost Study – Including Revenues and Costs Causal to the Introduction of Usage Based Billing” on page 3 of the response to The Companies(CRTC)20Aug09-17 TN 242 & 7181, provide a revised table which reflects the revised estimate of the average usage per end-user per month provided in response to c) above.

6. Refer to the table titled “Major Switching and Transmission Components per unit of Demand Included in the Cost Study” on page 3 of the response to The Companies(CRTC)20Aug09-7 TN 242 & 7181:

a. For each of the 3 major components driven by the Kbps bandwidth consumption at the peak period identified in the table, for each of (i) Residence – Lite, (ii) Residence - Lite Plus and (iii) Residence – Basic, provide the cost per access per month included in tables 5a, 5b and 5c of the Bell companies’ economic evaluation report.

b. With respect to the DSLAM Common Equipment and the DSLAM Port Card components identified in the table,

i. confirm that the same type of equipment ant type of port card are used regardless of the speed option and specify the type of equipment and port card assumed; and

ii. confirm that the same cost per access per month is included in each of tables 5a, 5b and 5c of the Bell companies’ economic evaluation report. If not, explain why not.

7. Refer to page 1 of the response to The Companies(CRTC)20Aug09-8 TN 242 & 7181 where the Bell companies identify the required bandwidth during the peak period for every 1 GB of average usage per end-user per month.

a. Identify the month(s) and year(s) and the level of data aggregation (e.g. geographic, service level) used by the Bell companies in their analysis to determine the impact of usage during the peak period.

b. Explain whether the analysis referred to in a) above was based on wholesale usage, retail usage, or both.

c. Provide the required bandwidth during the peak period for every 1 GB of average usage per end-user per month which was assumed for the 2004 GAS cost studies.

8. For each of GAS Residence – Lite and Residence – Basic, provide the average GB usage per end-user for the month of September 2009. If not available by speed option, provide the requested information for all speed options combined.

Attachment 2

Question to the ISPs

1. If the company were to implement usage based billing with its own end-users, explain the implications for doing so in light of the Bell companies’ proposal for uncorrelated usage.

2. Provide, with reasons, the company’s views on the feasibility and implications if the Bell companies were to charge each GAS customer for the aggregated usage (correlated and uncorrelated) originating from the telephone number of a GAS customer’s end-user. In doing so, the Bell companies’ would assign uncorrelated usage to the telephone number from which that usage originated and therefore to the GAS end-user responsible for that telephone number.

3. Comment on the feasibility and implications of an alternative approach whereby the Bell companies would charge each GAS-ISP, for each speed option, based on its end-users’ total aggregate usage (correlated and uncorrelated), averaged over its end-users.

Date modified:

2009-10-16