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Our Reference:  8660-B54-200913865

Ottawa, 10 February 2010



Mr. Mirko Bibic

Senior Vice-President

Regulatory & Government Affairs

Bell Canada

160 Elgin Street, 19th Floor

Ottawa, Ontario  K2P 2C4

Mr. Denis E. Henry


Regulatory & Governmental Affairs

Bell Aliant

160 Elgin Street, 19th Floor

Ottawa, Ontario  K2P 2C4

Dear Mr. Bibic and Mr. Henry:

Re:  Part VII Application by Bell Aliant Regional Communications LP and Bell Canada – Concerning the Appropriate Competitor Quality of Service Standards for the Provisioning of Competitor DS-1 Digital Network Services

On 14 October 2009, the Commission received the above-noted application from Bell Aliant Regional Communications, Limited Partnership and Bell Canada (collectively, the Bell Companies).  In order to have a full record, additional information is required.  

The Bell Companies are required to file responses to the attached questions by 24 February 2010.

Parties to this proceeding may file comments on the responses by 3 March 2010.  The Bell Companies may file reply comments by 8 March 2010.

All documents filed with the Commission shall be served upon all other parties by the filing date.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Yours sincerely,

Original signed by

Mario Bertrand


Competition Implementation and Technology


Attachment (1)

c.c.:  Parties listed in the Commission staff letter dated April 27, 2009

Bell Aliant
Bell Canada
MTS Allstream

Eastlink Regulatory.Matters@corp.eastlink.



Question 1

The provisioning of a CDN DS-1 facility as described in scenarios 1 and 2 (described at paragraphs 19 and 20 of the application) is similar to the provisioning of unbundled loops not requiring any conditioning activity and which are provisioned in 5 days.  Explain in detail why a longer service provisioning interval is required for a CDN DS-1 facility as compared to unbundled loops not requiring any conditioning activity.  Identify the additional provisioning steps, if any, which would justify a service interval of 8 days for a CDN DS-1 rather than 5 days for unbundled loops.

Question 2

In their application, the Bell Companies have proposed several scenarios for service intervals based on loop lengths.  For the purpose of the following question, assume a scenario that is not based on loop length.  What service interval would the Bell Companies propose in order to provision a CDN DS-1 service, regardless of loop length, if a line card or line cards has/have to be installed in:  (a) a central office only; (b) a central office and/or end-customer premise; and (c) a central office and/or remote and/or end-customer premise?

Question 3

In scenario 3 (described at paragraph 21 of the application), the Bell Companies propose a service interval of 13 days when there is a theoretical db loss exceeding 15.  Justify this service interval given that this provisioning scenario does not require any installation activities.

Question 4

In scenarios 1 and 2 (described at paragraphs 19 and 20 of the application), the Bell Companies propose different service intervals with respect to channelized and unchannelized circuits.  Explain why there is no such distinction in scenarios 3, 4, and 5 (described at paragraphs 21, 22 and 23 of the application)?

Question 5

At paragraph 21 of the Bell Companies proposal, the Bell Companies refer to db loss testing.  What steps are required to “balance” the db loss between the start and end-points of a circuit?  What is the amount of time required to complete these steps?

Question 6

Under the current CDN service intervals, the service interval for a CDN DS-3 is 13 days.  Justify why a DS-1 requires 13 to 19 days under the Bell Companies’ proposal when a CDN DS-3 requires 13 days.  Specifically, justify:  (i) why a CDN DS-1 would require the same interval as that for a CDN DS-3, given that the provisioning of CDN DS-1 can be assumed to be less complicated than a CDN DS-3; and (ii) why a CDN DS-1 service interval should be longer than for a CDN DS-3.  Explain in detail the different provisioning steps involved.

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