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ARCHIVED - Telecom Notice of Consultation CRTC 2010-43

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Ottawa, 28 January 2010

See also : 2010-43-1, 2010-43-2 and 2010-43-3
 

Notice of consultation and hearing
 

25 October 2010
Gatineau, Quebec
 

Proceeding to review access to basic telecommunications services and other matters
  File numbers: 8663-C12-201000653, 8663-C12-200912437, and 8663-C12-200909658
  In this notice, the Commission initiates a proceeding to review issues associated with access to basic telecommunications services, including the obligation to serve, the basic service objective, and local service subsidy. This proceeding will also re-examine the local competition and wireless number portability frameworks in the territories of the small incumbent local exchange carriers. In addition, the Commission will re-examine the appropriateness of the existing forbearance framework for mobile wireless data services.
  The proceeding will include a public consultation, which will begin on 25 October 2010 and is expected to last approximately two weeks. Further details will be provided in a follow-up to this notice.
 

Introduction

1.

In Telecom Decisions 2007-51 and 2008-34, the Commission established action plans to review existing regulatory measures in light of the Governor in Council's Policy Direction (the Policy Direction).1 The action plans identified the obligation to provide telephone service (the obligation to serve) and the local service subsidy regime as matters to be reviewed.

2.

In Telecom Notice of Consultation 2009-575, the Commission sought comments regarding the identification, scope, and prioritization of issues related to the obligation to serve and the local service subsidy regime in the serving territories of the incumbent local exchange carriers (ILECs) and the small ILECs.2 Given certain interdependencies, the Commission also sought comments in regard to the basic service objective.

3.

The list of parties who made submissions in that proceeding is provided in Appendix 2.

4.

The record of the proceeding, which closed on 13 November 2009, is available on the Commission's website at www.crtc.gc.ca under "Public Proceedings" or by using the file numbers provided above.
 

Background

5.

In Telecom Decision 86-7, the Commission established the terms of service for the ILECs then under its jurisdiction. In subsequent decisions, the Commission approved generally similar terms of service for all ILECs that came under its jurisdiction and that had not been subject to Telecom Decision 86-7. These terms of service include, subject to certain conditions, an obligation to serve existing customers as well as new customers requesting service both where the ILEC has facilities and beyond the limits of the ILEC's facilities.

6.

The local service subsidy regime, along with the associated contribution regime, was set out in Decision 2000-745 and subsequent Commission decisions.3 Local service subsidy was established to maintain basic local residential service in rural and remote areas (i.e. high-cost areas) at an affordable rate where the cost of providing service exceeds that rate. Revenues collected from telecommunications service providers (TSPs) are used to fund the local service subsidy regime.
7. In Telecom Decision 99-16, the Commission established the basic service objective, setting out a target for the features to be provided as part of residential local service in Canada.4 In order to be eligible for local service subsidy, local exchange carriers must provide a service that is, at a minimum, equivalent to the basic service objective.
 

Scope of review
 

Obligation to serve

8.

Parties opposed to a review of the obligation to serve generally argued that the regulatory measure remains appropriate, as long as local service subsidy properly compensates the ILECs. Some parties also indicated that there is near ubiquitous coverage of basic telecommunications services in Canada and that the public interest is well served by the existing measure.

9.

Parties in favour of a review generally indicated that, because of technological and competitive developments, the obligation to serve should be modified or rescinded. Some parties submitted that the obligation to serve does not comply with certain provisions of the Policy Direction, notably those related to the asymmetrical application of the regulatory measure. Other parties submitted that the obligation to serve is not properly defined, and that timelines regarding the delivery of basic local service to rural areas must be established.
 

Local service subsidy

10.

Parties opposed to a review of local service subsidy submitted that the current regime remains appropriate because subsidy is necessary to the provision of affordable residential basic local service in high-cost areas.

11.

Parties in favour of a review generally argued that many assumptions underlying the local service subsidy regime are no longer valid and that the distribution of subsidy is not equitable. For example, certain parties submitted that the current rate band system does not reflect the competitive environment, the cost and revenue components of the local service subsidy calculation are flawed, and contribution-eligible revenues should be reconsidered.
 

Basic service objective

12.

Parties opposed to a review of the basic service objective generally submitted that the measure continues to be appropriate since it represents a minimum service standard. These parties also submitted that high-speed Internet access should not be included in the basic service objective, as Internet is not a basic service and its inclusion would raise serious funding issues.

13.

Parties in favour of a review generally submitted that the basic service objective is outdated due to significant competitive and technological developments. Some parties submitted that high-speed Internet service should be recognized as a basic service and funded through the contribution regime.
 

Commission's analysis and determinations

14.

The Commission considers that the obligation to serve, the local service subsidy regime, and the basic service objective are intricately related. The Commission also considers that, while support for a review of these regulatory measures was not unanimous, parties raised several important issues, including whether the associated regulatory measures meet the criteria set out in the Policy Direction, to justify a review of all the measures in the same proceeding.

15.

With respect to the issue of high-speed Internet access, the Commission notes that, while some parties proposed amending the contribution regime in order to fund high-speed Internet expansion, the regime has, to date, been limited to subsidizing residential basic local service rates in high-cost areas. Moreover, the Commission notes that there are a number of government-sponsored initiatives currently underway to fund the expansion of high-speed Internet access in Canada.

16.

Notwithstanding the above, the Commission considers that there is merit in examining issues and technical specifications of high-speed Internet access within the context of the basic service objective in order to assist the Commission in determining its role, if any, regarding access to high-speed Internet services.

17.

In light of the above, the Commission finds that issues associated with the obligation to serve, the basic service objective, and local service subsidy, including the associated contribution mechanism, should be included in the scope of the proceeding initiated by this notice. The specific issues to be examined in this proceeding are set out later in this notice.
 

Small ILEC local competition

18.

The Commission recently sought comments on the implementation plans for local competition and wireless number portability (WNP) in various territories served by the small ILECs in response to competitive requests.5

19.

Pursuant to the existing regulatory frameworks6, local competition and WNP are permitted in the territories of the small ILECs, contingent upon the small ILEC filing, and the Commission approving, an implementation plan.

20.

While competitors have argued that it would not be competitively neutral to deny competition in small ILEC markets, many small ILECs have indicated that their financial viability would be at risk if the Commission approved the implementation of local competition and/or WNP in their territories.
 

Commission's analysis and determinations

21.

The Commission notes that, pursuant to the existing regulatory frameworks, it has approved the implementation of local competition in certain territories served by the small ILECs.7 However, the Commission is concerned that the implementation of local competition and/or WNP under the current frameworks could affect the financial viability of certain small ILECs, thereby jeopardizing the accessibility of basic local service for certain subscribers. The Commission further considers that any changes to the local service subsidy regime could affect local competition in the small ILECs' territories.

22.

Therefore, the Commission finds it appropriate to re-examine the local competition and WNP frameworks in the territories of the small ILECs in the proceeding initiated by this notice.

23.

Consequently, the Commission suspends consideration of applications for approval of implementation plans for local competition and/or WNP in the small ILECs' territories until the current review is concluded.8
 

Forbearance from regulation of mobile wireless data services

24.

In a separate matter, the Commission, in Telecom Decision 96-14 and in follow-up decisions, forbore from regulating mobile wireless data services. However, the Commission recently indicated its intention to review the appropriateness of reapplying section 24 and subsection 27(2) of the Telecommunications Act (the Act) to these services.9

25.

The Commission notes that there is a link between issues regarding high-speed Internet service and mobile wireless data services, as well as the associated service providers. Accordingly, as part of the proceeding initiated by this notice, the Commission will review the appropriateness of the mobile wireless data services forbearance framework.
 

Call for comments

26.

The Commission hereby initiates a public proceeding to address issues associated with access to basic service, including the obligation to serve, local service subsidy, the basic service objective, and local competition and/or WNP in the territories of the small ILECs. In addition, the Commission intends to review the forbearance framework associated with mobile wireless data services. In their comments, parties should provide full supporting rationale and all evidence on which they rely, and structure their submissions according to the topics and questions identified in Appendix 4.

27.

The Commission notes that its review in this proceeding will be done in light of the telecommunications policy objectives set out in section 7 of the Act and the Policy Direction.

28.

The Commission notes that the outcome of this proceeding may result in changes to various regulatory regimes, including the national contribution collection mechanism, applicable to some or all TSPs.
 

Procedure

29.

Bell Aliant Regional Communications, Limited Partnership (Bell Aliant); Bell Canada; Bragg Communications Inc.; Cogeco Cable Inc. (Cogeco); MTS Allstream Inc. (MTS Allstream); Northwestel Inc. (Northwestel); Rogers Communications Inc.; Saskatchewan Telecommunications (SaskTel); Shaw Telecom Inc.; TELUS Communications Company (TCC); Télébec, Limited Partnership; Videotron Ltd.; and the small ILECs are made parties to this proceeding.

30.

The record regarding the introduction of local competition in the small ILECs' territories (file number 8663-C12-200909658) is made part of the record of this proceeding.

31.

Other parties interested in participating in this proceeding (including receiving copies of all submissions) must notify the Commission of their intention to do so by filling out the online form; or by writing to the Secretary General, CRTC, Ottawa, Ontario, K1A 0N2; or by faxing to: 819-994-0218 by 25 February 2010 (the registration date). Parties are to provide their email addresses, where available. If parties do not have access to the Internet, they are to indicate when they notify the Commission whether they wish to receive disk versions of hard-copy filings.

32.

As soon as possible after the registration date, the Commission will post on its website a complete list of interested parties, their mailing addresses, and, if available, their email addresses, identifying those parties who wish to receive disk versions.

33.

Any person who wishes merely to file written comments in this proceeding, without receiving copies of the various submissions, may do so by writing to the Commission by 12 November 2010 at the address or fax number noted above, or by filling out the online form.

34.

To facilitate further dialogue among Canadians, the Commission will be conducting an online consultation on the issues discussed in this proceeding. This online consultation will allow the public to engage in discussion on issues and questions relating to this notice. Further details will be provided in a follow-up to this notice.

35.

Each party set out in paragraph 29 is to file, and other parties may file, evidence on matters within the scope of this proceeding. Each party's evidence must include an executive summary no longer than 10 pages. Parties filing evidence are to do so with the Commission, serving copies on all parties, by 12 April 2010.

36.

The Commission and the parties may address interrogatories to any party who has filed evidence pursuant to paragraph 35. Any such interrogatories must be filed with the Commission and served on the relevant party or parties by 6 May 2010.

37.

Responses to interrogatories are to be filed with the Commission and served on all parties by 1 June 2010.

38.

Requests by parties for further responses to their interrogatories, specifying in each case why a further response is both relevant and necessary, and requests for public disclosure of information for which confidentiality has been claimed, setting out in each case the reasons for disclosure, must be filed with the Commission and served on the relevant party or parties by 8 June 2010.

39.

Written responses to requests for further responses to interrogatories and for public disclosure must be filed with the Commission and served on the party or parties making the request by 15 June 2010.

40.

Determinations will be issued regarding requests for further information and public disclosure as soon as possible. Any information to be provided pursuant to such determinations must be filed with the Commission and served on all interested parties by 29 June 2010.

41.

Parties may address additional interrogatories to any party who filed evidence pursuant to paragraph 35. Any such interrogatories must be filed with the Commission and served on the relevant party or parties by 6 July 2010.

42.

Responses to interrogatories addressed pursuant to paragraph 41 are to be filed with the Commission and served on all parties by 20 July 2010.

43.

Requests by parties for further responses to their interrogatories, specifying in each case why a further response is both relevant and necessary, and requests for public disclosure of information for which confidentiality has been claimed, setting out in each case the reasons for disclosure, must be filed with the Commission and served on the relevant party or parties by 27 July 2010.

44.

Written responses to requests for further responses to interrogatories and for public disclosure must be filed with the Commission and served on the party or parties making the request by 3 August 2010.

45.

A determination will be issued with respect to requests for further information and public disclosure as soon as possible. Any information to be provided pursuant to that determination will be filed with the Commission and served on all interested parties by 17 August 2010.

46.

An oral hearing will commence on 25 October 2010 and is expected to last approximately two weeks. Further details will be provided in a follow-up to this notice.

47.

All parties may file final argument with the Commission, serving copies on all other parties, by 12 November 2010. Final argument is to be limited to 15 pages with an executive summary no longer than 5 pages.

48.

The Commission expects to publish its determinations on issues raised in this notice of consultation within 120 days of the close of record.

49.

The Commission will not formally acknowledge comments. It will, however, fully consider all comments and they will form part of the public record of the proceeding.
 

Important notice

50.

Note that all information that you provide as part of this public process, except information granted confidentiality, whether sent by postal mail, facsimile, email, or through the Commission's website at www.crtc.gc.ca, becomes part of a publicly accessible file and will be posted on the Commission's website. This information includes your personal information, such as your full name, email address, postal/street address, telephone and facsimile number(s), and any other personal information you provide.

51.

The personal information you provide will be used and may be disclosed for the purpose for which the information was obtained or compiled by the Commission, or for a use consistent with that purpose.

52.

Documents received electronically or otherwise will be posted on the Commission's website in their entirety exactly as you send them, including any personal information contained therein, in the official language and format in which they are received. Documents not received electronically will be available in PDF format.

53.

Please note that the information you provide to the Commission as part of this public process is entered into an unsearchable database dedicated to this specific public process. This database is accessible only from the web page of this particular public process. As a result, a general search of our website with the help of either our own search engine or a third-party search engine will not link directly to the information that was provided as part of this public process.
 

Location of CRTC offices

54.

Submissions may be examined or will be made available promptly upon request at the Commission offices during normal business hours.
  Toll-free telephone: 1-877-249-2782
Toll-free TDD: 1-877-909-2782
  Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room 206
Gatineau, Quebec J8X 4B1
Tel.: 819-997-2429
Fax: 819-994-0218
 

Regional offices
  Metropolitan Place
99 Wyse Road, Suite 1410
Dartmouth, Nova Scotia B3A 4S5
Tel.: 902-426-7997
Fax: 902-426-2721
  205 Viger Avenue West, Suite 504
Montréal, Quebec H2Z 1G2
Tel.: 514-283-6607
  55 St. Clair Avenue East, Suite 624
Toronto, Ontario M4T 1M2
Tel.: 416-952-9096
  Kensington Building
275 Portage Avenue, Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel.: 204-983-6306
Fax: 204-983-6317
  2220 – 12th Avenue, Suite 620
Regina, Saskatchewan S4P 0M8
Tel.: 306-780-3422
  10405 Jasper Avenue, Suite 520
Edmonton, Alberta T5J 3N4
Tel.: 780-495-3224
  580 Hornby Street, Suite 530
Vancouver, British Columbia V6C 3B6
Tel.: 604-666-2111
Fax: 604-666-8322
  Secretary General
 

Related documents
 
  • Review of the Internet traffic management practices of Internet service providers, Telecom Regulatory Policy CRTC 2009-657, 21 October 2009
 
  • Call for comments – Identification, scope, and prioritization of issues regarding obligation to serve, basic service objective, and local service subsidy regime, Telecom Notice of Consultation CRTC 2009-575, 11 September 2009
 
  • Regulatory framework for the implementation of wireless number portability within the serving territories of the small incumbent local exchange carriers, Telecom Decision CRTC 2008-122, 18 December 2008
 
  • People's Tel Limited Partnership – Implementation of local competition with Execulink Telecom Inc., Telecom Decision CRTC 2008-93, 29 September 2008
 
  • Action plan for reviewing social and other non-economic regulatory measures in light of Order in Council P.C. 2006-1534, Telecom Decision CRTC 2008-34, 17 April 2008
 
  • Implementation of local competition in NorthernTel, Limited Partnership's serving territory – ExaTEL Inc. and Ontera, Telecom Decision CRTC 2007-93, 28 September 2007, as amended by Telecom Decision CRTC 2007-93-1, 1 November 2007
 
  • Implementation of local competition in TBayTel's serving territory – ExaTEL Inc. and Shaw Communications Inc., Telecom Decision CRTC 2007-78, 31 August 2007
 
  • Action plan for the review of Commission regulatory measures in light of Order in Council P.C. 2006-1534, Telecom Decision CRTC 2007-51, 11 July 2007
 
  • The Canadian revenue-based contribution regime, Telecom Circular CRTC 2007-15, 8 June 2007
 
  • Revised regulatory framework for the small incumbent local exchange carriers, Telecom Decision CRTC 2006-14, 29 March 2006
 
  • Changes to the contribution regime, Decision CRTC 2000-745, 30 November 2000
 
  • Telephone service to high-cost serving areas, Telecom Decision CRTC 99-16, 19 October 1999
 
  • Regulation of mobile wireless telecommunications services, Telecom Decision CRTC 96-14, 23 December 1996
 
  • Review of the general regulations of the federally regulated terrestrial telecommunications common carriers, Telecom Decision CRTC 86-7, 26 March 1986
  This document is available in alternative format upon request, and may also be examined in PDF format or in HTML at the following Internet site: http://www.crtc.gc.ca.
  Footnotes:

1   Order Issuing a Direction to the CRTC on Implementing the Canadian Telecommunications Policy Objectives, P.C. 2006‑1534, 14 December 2006

2   The small ILECs are listed in Appendix 1.

3   The current subsidy regime is consolidated and summarized in Telecom Circular 2007-15.

4   The basic service objective currently includes the following: individual line local Touch‑Tone service; access to low‑speed Internet at local rates; access to the long distance network and to operator/directory assistance services; enhanced calling features, including access to emergency services, voice message relay service, and privacy protection features; and a copy of the current local telephone directory.

5   See file number 8663-C12-200909658.

6   The regulatory frameworks for local competition and WNP in small ILEC territories are set out in Telecom Decisions 2006-14 and 2008-122, respectively.

7   The Commission approved the implementation plans filed by NorthernTel, Limited Partnership, People's Tel Limited Partnership, and TBayTel in Telecom Decisions 2007-93, 2008-93, and 2007-78, respectively.

8   The Commission has received 13 implementation plans from small ILECs for which determinations have not yet been made. A list of these applications is provided in Appendix 3.

9   Pursuant to Telecom Regulatory Policy 2009-657
 

Appendix 1
 

Small ILECs by province
 

British Columbia

 CityWest Telephone Corporation
 

Ontario

Amtelecom Limited Partnership
Brooke Telecom Co-operative Ltd.
Bruce Telecom
Cochrane Telecom Services
Dryden Municipal Telephone System
Execulink Telecom Inc.
Gosfield North Communications Co-operative Limited
Hay Communications Co-operative Limited
Huron Telecommunications Co-operative Limited
KMTS
Lansdowne Rural Telephone Co. Ltd.
Mornington Communications Co-operative Limited (Mornington)
Nexicom Telecommunications Inc.
Nexicom Telephones Inc.
North Frontenac Telephone Corporation Ltd.
NorthernTel, Limited Partnership
NRTC Communications
Ontera
People's Tel Limited Partnership
Quadro Communications Co-operative Inc.
Roxborough Telephone Company Limited
TBayTel
Tuckersmith Communications Co-operative Limited (Tuckersmith)
Wightman Telecom Ltd.
WTC Communications
 

Quebec

CoopTel
La Cie de Téléphone de Courcelles Inc.
La Compagnie de Téléphone de Lambton Inc. (Lambton)
La Compagnie de Téléphone de St-Victor (St-Victor)
La Compagnie de Téléphone Upton Inc. (Upton)
La Compagnie de Téléphone de Warwick
Le Téléphone de St-Éphrem inc. (St-Éphrem)
Sogetel inc. (Sogetel)
Téléphone Guèvremont inc. (Guèvremont)
Téléphone Milot inc. (Milot)
 

Appendix 2
 

List of parties from Telecom Notice of Consultation 2009-575
 
  • Alberta Association of Municipal Districts and Counties
  • ARCH Disability Law Centre
  • BCBA Broadband Association of British Columbia
  • Bell Aliant and Bell Canada
  • Canadian Association of the Deaf
  • Canadian Independent Telephone Company Joint Task Force
  • Coalition of Internet Service Providers Inc.
  • Communications, Energy and Paperworkers Union of Canada
  • Federation of Canadian Municipalities
  • Government of the Northwest Territories
  • MTS Allstream
  • North Peace Economic Development Commission
  • Northwestel
  • Public Interest Advocacy Centre, on behalf of the Consumers' Association of Canada and Canada Without Poverty (formerly the National Anti-Poverty Organization)
  • Rogers Communications Inc.
  • SaskTel
  • TCC
 

Appendix 3
 

List of implementation plans filed with the Commission for local competition and/or WNP in the territories of the small ILECs for which determinations have not yet been made
  Date of proposal Type of application Requestor Small ILEC
  2009-06-25 Local Competition EastLink Tuckersmith
  2009-05-05 Local Competition EastLink Mornington
  2009-03-16 Local Competition EastLink Bruce Telecom
  2009-03-13 WNP Rogers Wireless Partnership KMTS
  2008-11-05 Local Competition TCC, on behalf of Cogeco Upton
  2008-11-05 Local Competition TCC, on behalf of Cogeco CoopTel
  2008-11-05 Local Competition TCC, on behalf of Cogeco Milot
  2008-11-05 Local Competition TCC, on behalf of Cogeco Sogetel
  2008-11-05 Local Competition TCC, on behalf of Cogeco Guèvremont
  2008-11-05 Local Competition TCC, on behalf of Cogeco Lambton
  2008-11-05 Local Competition TCC, on behalf of Cogeco St-Éphrem
  2008-11-05 Local Competition TCC, on behalf of Cogeco St-Victor
  2008-07-10 Local Competition Shaw Telecom G.P. KMTS
 

Appendix 4
 

Questions for discussion in this proceeding
  Parties are to take into consideration and address the relevant aspects of the telecommunications policy objectives set out in section 7 of the Act and the Policy Direction, as applicable, when submitting their responses to the questions below.
 

Obligation to serve

1.

In which market(s) (for example, forborne, non-forborne, high-cost) and to what extent, if any, is an obligation to serve necessary? Specify what type(s) of service(s), if any, should be subject to an obligation to serve. Explain whether the provision of service through alternate technologies, for example wireless service, should satisfy an obligation to serve regarding local voice service.

2.

Should any particular class of service provider (for example, ILECs, competitive local exchange carriers) be subject to an obligation to serve and, if so, how should they be selected?

3.

What legal considerations exist, for example the Bell Canada Act, which would prevent a modification or the removal of the obligation to serve?

4.

Should a service provider that has the obligation to serve be compensated and, if so, in which market(s)? What should be the criteria, for example the cost of service, for determining whether compensation is required? Specify the appropriate compensation mechanism.

5.

Should there be limits to the obligation to serve and, if so, what should those limits be? Indicate whether the current service extension charges and parameters (for example, distance from the network, amount paid by the customer and/or the service provider) remain appropriate. Should these charges and parameters be made generally consistent across relevant service providers?

6.

Should the obligation to serve be subject to service standards, for example specific time frames for service delivery? If so, specify the standards and circumstances.
 

Local service subsidy

7.

Should changes to the local service subsidy regime be made and, if so, to what extent?

8.

How should high-cost areas be defined and what should be the associated criteria, for example a banding structure based on loop length or density of network access service (NAS)? Should the existing banding structure be modified to include sub-bands?

9.

Identify the appropriate mechanism for distributing subsidy and whether the subsidy should be paid to the service provider based on revenues and costs or a competitive bidding process. If the mechanism continues to be based on revenues and costs, what should be included? Are the current implicit revenue contributions appropriate (i.e. $30 monthly rate target for primary exchange service and $5 for monthly optional services)?

10.

Which service providers should be eligible to receive subsidy and under what circumstances? Are there any circumstances in which wireless service providers should be eligible for subsidy? Should local service subsidy be tied to the obligation to serve or to the basic service objective?

11.

Should there be a subsidy in forborne and/or competitive markets? Should there be subsidized competition in high-cost areas, including small ILEC markets? In which markets and under what conditions, if any, should the subsidy be portable?

12.

Which TSPs should be required to contribute to the local service subsidy fund? What revenues should be contribution-eligible? Should Internet revenues be contribution-eligible? Are any other changes to the contribution collection mechanism necessary?

13.

Should the small ILECs and/or Northwestel be subject to any special considerations or modifications?
 

Basic service objective

14.

Is the basic service objective still necessary and, if so, what should it comprise? Specify the services/obligations as well as the appropriate technical specifications (e.g. high-speed Internet access at a minimum speed of 1 megabit per second) to be included in the basic service objective.

15.

Specify whether alternatives to wireline local service, for example wireless service, should be considered to satisfy the basic service objective. Specify which service providers should be subject to the basic service objective.

16.

What should be the Commission's role, if any, in regard to advancing high-speed Internet access? Given that the contribution regime is generally limited to subsidizing basic local service rates in high-cost areas, should the Commission reconsider its approach and use the regime to subsidize high-speed Internet access?
 

Local competition and WNP in the territories of the small ILECs

17.

What are the major costs associated with implementing local competition in small ILEC markets? Indicate which service provider(s) should incur the costs of implementing local competition in small ILEC markets and, if appropriate, how those costs could be reasonably recovered. Provide, where available, cost estimates for implementing local competition in each small ILEC territory.

18.

Should local competition continue to be introduced in small ILEC markets and, if so, should there be criteria for approval? Assuming small ILECs continue to be subject to the obligation to serve, will local competition jeopardize a small ILEC's ability to fulfil its obligation to serve throughout its incumbent serving territory?

19.

If local competition continues to be introduced in small ILEC markets, should the requirement that small ILECs implement local number portability (LNP) be maintained?

20.

If local competition continues to be permitted in certain small ILEC markets, with or without LNP, should the requirement that small ILECs implement WNP be maintained? Should WNP be required if local competition is not permitted in certain small ILEC markets and, if so, should it be restricted to supporting wireless-to-wireless number portability?

21.

Would it be appropriate to permit local competition in small ILEC markets without a portable subsidy regime and without the requirement to implement LNP/WNP?
 

Mobile wireless data services

22.

Should the Commission change the scope of forbearance with respect to mobile wireless data services, and if so, to what extent?

Date modified: