ARCHIVED - Letter

Ottawa, 1 March 2010

Our Reference: 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

Dear Madams, Sirs:

Pursuant to the procedures specified at paragraph 16 of Telecom Notice of Consultation CRTC 2009-261-7, 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 22 March 2010.

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 (ILECs), cable carriers and competitors (including competitors that have made submissions and ILECs and cable carriers operating outside of their territories).

Yours sincerely,

Original signed by

Paul Godin
Director General
Competition, Costing and Tariffs
Telecommunications

Appendix 1

Distribution List

regulatoryaffairs@nwtel.ca; bell.regulatory@bell.ca; 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; regulatory.affairs@telus.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; Rocky@TekSavvy.com ; dmckeown@viewcom.ca; David.Wilkie@tbaytel.com; regulatory@fibernetics.ca; jfmezei@vaxination.ca; stephen.scofich@tbaytel.com; regulatory@bcba.ca; crtcmail@gmail.com; telecom@gov.bc.ca;

Appendix 2

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)

100 Series:

Interrogatories to All ILECs

101. With respect to the company’s technologies deployed to provision broadband network infrastructure including high speed Internet access infrastructure, provide the following:

a) For each of the major network technologies associated with the broadband network infrastructure, identify retail services (Internet, IPTV, etc.) provided and the upstream and downstream bandwidth requirement for each service.

b) For each of the years 2000 to 2009, provide the total capital expenditures associated with broadband network infrastructure, and further provide a breakdown of these capital expenditures into those that are attributable to high speed Internet access infrastructure (excluding Ethernet access infrastructure), and other service infrastructures, specifying and describing each infrastructure.

c) With reference to part b) above, provide an estimate of capital expenditures that stem from public funding over 2000 to 2009, identifying whether the funding is municipal, provincial or federal. Further specify if the funding is one time or ongoing.

d) Provide the impact that the Commission’s regulatory obligations associated with high speed Internet access have had on the company’s historical capital expenditures in broadband network infrastructure, with supporting evidence. Further, comment on the impact that the proceedings to review the regulatory status of wholesale Internet access since the issuance of Telecom Decision 2008-17 have had on the company’s broadband infrastructure capital expenditures since that time, with supporting evidence. The response should further identify the impacts that these regulatory obligations may have had on capital expenditures in markets of different sizes, with supporting rationale.

102. With respect to the company’s technologies planned to be deployed to provision broadband network infrastructure from 2010 to 2012, assuming that the ILECs are not required to provide wholesale Internet access speeds that match retail Internet speeds other than those that are already provided:

a) Identify the major technologies and/or technology upgrades planned to be deployed to provision broadband network infrastructure including high speed Internet access infrastructure. Describe how each of these technologies will impact the high speed Internet upstream and downstream bandwidth capability per end-user; if the bandwidth is shared by a community of end-users, specify the average number of end-users per community.

b) For the technologies identified in response to part a) above, identify other services planned to be offered over these technologies and the associated upstream and downstream bandwidth requirements. To the extent that TV distribution services are to be offered, indicate whether the services will be delivered as unicast, multicast, or broadcast.

c) In the event that the company deploys FTTH in a neighbourhood, indicate whether the company will continue to provide retail and/or wholesale services over the existing copper based access infrastructure (including FTTN) in that neighbourhood with supporting rationale. If yes, provide the company’s plans to deliver services on both technologies.

d) For each technology identified in response to part a) above, provide schematic diagrams and identify the major components used. Further provide a description of each major component including its functions.

e) For each of the major technologies and technology upgrades identified in response to part a) above, for each of the years 2010 to 2012, provide the company’s forecast capital expenditures in broadband network infrastructure, and further provide a breakdown of these capital expenditures into those that are attributable to high speed Internet access infrastructure, and other service infrastructures, specifying and describing each infrastructure.

f) For each technology identified in response to part a) above, provide the forecast number of homes passed (i.e. high speed Internet capable homes) in 2012. Further, for each of these technologies, for each of existing and new neighbourhoods, provide the company’s estimate of the average capital expenditure required to add such capability for a home, with supporting assumptions.

g) For each technology identified in response to part a) above, identify the criteria used to assess whether or not to implement the technology in the market, including provisioning guidelines, construction costs, services, revenues, competitive threat, and take-rate considerations. Explain whether and how the above criteria will be different for markets of different sizes.

h) Comment on the impact that the Commission’s regulatory obligations may have on the company’s planned capital expenditures with supporting rationale, under each of the following changes in assumptions:

i. The Commission mandates wholesale aggregated ADSL matching speeds; and

ii. The Commission mandates a wholesale universal CO-based high speed access service that excludes broadcast capability, is offered at the maximum speed that the technology can support, and is available to competitors including DSL ISPs using self or 3rd-party co-location arrangements.

103. For each of the years 2007 to 2009, for each of the retail single-line business and residence Internet services offered by the company, provide the following information:

a) The average number of subscribers by service speed.

b) The total revenues by service speed, where the revenues include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service. In addition to the revenues as defined above, separately identify the applicable usage charges associated with the service for the year in question.

104. For each of the years 2007 to 2009, for each of retail single-line business and residence Internet services, provide the average speed and average revenue per subscriber, averaged over all speeds.

105. For each of the years 2010 to 2012, for each of retail single-line business and residence Internet services:

a) Provide the company’s total demand and revenue* forecast of its high speed retail Internet services assuming that the ILECs are not required to provide wholesale Internet access speeds that match retail Internet speeds other than those that are already provided.

b) Provide the company’s total demand and revenue* forecast of its high speed retail Internet services under each of the following change in assumptions:

i. The Commission mandates wholesale aggregated ADSL matching speeds; and
ii. The Commission mandates a wholesale universal CO-based high speed access service that excludes broadcast capability, is offered at the maximum speed that the technology can support, and is available to competitors including DSL ISPs using self or 3rd-party co-location arrangements.

The response should identify any additional assumptions the company has made in providing their demand and revenue forecasts.

*Revenues are to include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service.

106. Assume that the Commission mandates a universal CO-based ADSL access service. Provide your views on whether and to what extent the aggregate ADSL access service should be phased-out and, if so, identify with supporting rationale what the criteria should be for phasing-out the service in markets of different sizes.

107. See ILEC-specific Question 107 for the Bell Companies and MTS Allstream.

108. See ILEC-specific Question 108 for SaskTel and TELUS.

109. See ILEC-specific Question 109 for TELUS.

110. See ILEC-specific Question 110 for the Bell Companies.

111. See ILEC-specific Question 111 for the Bell Companies.

Interrogatories for the Bell Companies

107. (This question to be answered by Bell Canada and Bell Aliant separately). Distributel cited an announcement by Bell Aliant and Bell Canada identifying plans to implement FTTH infrastructure for certain communities in New Brunswick and Quebec City:

a) In the communities identified above, is the last mile fibre-facility being newly installed by the company or is the company interconnecting to existing fibre access facilities, and to what extent. Provide details.

b) Identify the major factors that led to the company choosing these communities for FTTH installations, including any specific competitive threat.

c) Identify the specific end-customer service benefits, separately, for IPTV, high-speed Internet and telephony service that FTTH offers over FTTN, that would allow the company to address the competitive threat identified in b) above.

d) Further to the response in b) above, describe whether these factors currently exist in other markets and to what extent.

110. In Bell Canada(Distributel)17Jul09-5 TNC 2009-261 Supplemental, the company presented the results of an NPV study regarding its proposed investment in FTTN facilities in Ottawa, modified to assume that the company provided both Internet and telephony services to end users:

a) Indicate whether the ten year NPV results presented in scenarios one and two of part b) of the response to this interrogatory include revenues from all services provided over the FTTN facilities (including IPTV services) and provide an explanation for any exclusions. Further, identify any cross-effects associated with other company services that were included in the study.

b) i. Provide the ten year NPV analysis applicable to scenario 1and scenario 2 as described in paragraphs 91 to paragraph 94 of the company’s 22 June 2009 submission, including the costs and revenues associated with all services provided over the FTTN facilities;

ii. Identify the complete set of services provided over the FTTN facilities;

iii. Provide the forecasts of demand and revenue for each retail and wholesale service provided on the FTTN facility in each of the alternate and reference plans for scenario 1 and scenario 2; and

iv. Detail all demand and revenue assumptions used in the analysis specific to each scenario, with supporting rationale, specifically identifying the assumptions made in the alternate and reference plans regarding the loss and/or retention of customers to competitive alternatives, the stimulation of demand and in scenario 2, the assumed effect of regulatory obligations on the ability to sell service bundles.

111. In Bell Canada’s 22 June 2009 submission, the company indicated that a decision to mandate access to next generation network facilities (either under a matching speed requirement or a new mandated ADSL CO service) would cause the company to review its roll out plans for FTTN facilities in Ottawa-Gatineau, Québec City, Hamilton, Kingston, Kitchener, London, the Niagara region, Sherbrooke and Windsor:

a) For each of these localities, provide a summary of the current status of the company’s FTTN roll-out program relative to the program’s objectives for that locality. Further, for each of these localities identify the expected coverage of the planned program as of September 2010.

b) Provide the criteria that were used to select each of these communities for the roll out of the FTTN network, with supporting rationale.

c) Identify the anticipated level of investment that would occur in these communities under the following scenarios:

i. The Commission determines that it is appropriate to implement a matching speed requirement on wholesale aggregated ADSL service or to implement a universal CO-based ADSL access service;

ii. The Commission determines that neither a matching speed requirement on wholesale aggregated ADSL service nor a mandated universal CO-based ADSL access service is appropriate;

iii. Further, provide the company’s rationale for the differences in the investment level in each scenario

d) For each of the services provided over the FTTN facility, identify the expected penetration and revenue levels that would occur in these communities under the scenarios identified in c).

Interrogatories for MTS Allstream

107. MTS Allstream submitted that it had recently launched an advanced FTTH network in Waverly West, a new neighbourhood in Winnipeg:

a) Identify the major factors that led to the company choosing this neighbourhood for FTTH installations, including any specific competitive threat.

b) Identify the specific end-customer service benefits, separately, for IPTV, high-speed Internet and telephony service that FTTH offers over FTTN, that would allow the company to address the competitive threat identified in a) above.

c) Further to the response in a) above, describe whether these factors currently exist in other markets and to what extent.

Interrogatories for TELUS

108. At paragraph 23 of the company’s 8 February 2010 submission, it is stated that a matching speed requirement creates “an environment that diminishes ILECs’ incentives to invest and upgrade these [hybrid fibre] networks because their risky investments will generate insufficient returns.”:

a) Provide any analysis the company has undertaken to demonstrate the impact that a matching speed requirement has on the business case for investing in next generation networks.

b) Provide all assumptions used in the analysis provided in part a).

109. At paragraph 25 of TELUS’s 8 February 2010 submission it is stated that:
Mandatory unbundling deprives, by regulatory rule, the network provider of the ability to generate the full suite of anticipated service revenues, meaning that more risky rural investments will not be made.

Further, at page 19 of the company’s 2009 Q4 Management’s review of operations (released 12 February 2010), it is stated that:

The wireline broadband network for ADSL2+ is expected to be completed in 2010 with coverage approaching 90% of the top 48 incumbent markets in Alberta and B.C. In addition, the Company began in the second half of 2009 a program to reach the top 48 communities with VDSL2 by the end of 2011.

a) Identify the 48 communities referenced in the management review of operations and provide the criteria that were used to select each of these communities for the roll out of the FTTN network, with supporting rationale.

b) Further, identify, with supporting rationale, which of the company’s top 48 communities would be regarded as “rural” or would have substantial (in terms of population) “rural” segments. Of these “rural” communities, identify, with supporting rationale, those communities where risky investments would not be made if the Commission were to require mandatory unbundling of FTTN facilities.

c) Provide, with supporting rationale, the levels of investment in these 48 communities that would occur under each of the following scenarios:

i. The Commission determines that it is appropriate to implement a matching speed requirement on wholesale aggregated ADSL service or to implement a universal CO-based ADSL access service; and

ii. The Commission determines that neither a matching speed requirement on wholesale aggregated ADSL service nor a mandated universal CO-based ADSL access service is appropriate.

d)

i. Reconcile the information quoted in the 12 February 2010 management review cited above with respect to the coverage of FTTN facilities with the information provided in confidence in TELUS_ILECs(CRTC)17July09-1 h);

ii. For each of the 48 communities cited in the management review, provide a summary of the current status of the company’s FTTN roll-out program relative to the program’s objectives for that locality;

iii. Further, for each of these communities, identify the expected coverage of the planned program as of September 2010.

Interrogatories for SaskTel

108. At paragraph 35 of SaskTel’s 8 February 2010 submission the company stated:

A positive business case supporting network deployment depends on a company’s assumptions regarding take rate and revenues per user. Risks include the take rate being lower than anticipated, revenue per user being lower than anticipated and cost of construction being higher than anticipated. A regulatory framework which mandates that competitors be allowed to use the network at essential prices threatens the assumptions of take rate and revenue per user as well as adding several new risks.

a) Provide any analysis that the company has undertaken to demonstrate the impact that a matching speed requirement has on the business case for investing in next generation networks.

b) Provide all assumptions used in the analysis provided in part a).

c) Provide the company’s view of the impact that mandating a matching speed requirement might have on the business case for investing in next generation networks if the pricing of any new wholesale services arising from the requirement were based on non-essential services pricing principles.

200 series:

Interrogatories to All ILECs

201. Identify access technologies other than DSL and mobile wireless that the company uses to provide retail high-speed Internet access services. For each technology identified, specify:

a) The service characteristics of the retail service that is being marketed and the geographic area where the service is currently available.

b) The retail price(s) for the service, by speed.

c) The demand for the service, by speed.

d) Whether, with rationale, the service is a substitute for wireline access services (i.e. provides subscribers comparable value and user experience to wireline access services).

202. The incumbents generally submitted that inter-modal competition from (1) mobile wireless technology and (2) fixed wireless technology would provide a basis for retail Internet service competition. Provide the following information, separately for each type of wireless high-speed Internet service (mobile and fixed), with respect to the future provision of such services:

a) The company’s views on (a) the geographic areas where such services will be offered and timeframes (where the time frame is either (a) short term - less than 2 years (b) medium - more than 2 years and less than 5 years and (c) long-term, more than 5 years).

b) The service’s capabilities (e.g. upload and download speeds) and restrictions.

203. To the extent that the companies that provide, or will provide, wireless retail Internet services are affiliates of the company, provide with reasons the company’s views on the extent to which competition between wireless and wireline services would be sufficient to protect the interests of users.

204. See ILEC-specific Question 204 for the Bell Companies and TELUS.

 

Interrogatories to the Bell Companies and TELUS

204. The Bell Companies, TELUS and Rogers submitted that wireless broadband networks represent an alternative to wireline high-speed access services that are the subject of this proceeding.

a) Describe the access speeds available to end-user’s and capacity available per cell on the company’s mobile wireless broadband networks.

b) Total number of end-users that can be simultaneously served off a cell such that the end-users receive comparable experience to wireline 5 Mbps high-speed access service.

c) Identify the monthly downstream and upstream usage (in gigabytes) on average used by a wireline high-speed Internet end-user.

d) If 10% of wireline high-speed customers across the company’s wireline territory of incumbency migrated to its mobile wireless broadband service, assuming the usage profile of an average user provided in response to c) above, describe the additional upgrades and associated costs to augment capacity on the company’s wireless network (use recent spectrum acquisition costs as a proxy for additional spectrum).

e) Provide a response to the question in d) above if 30% of wireline high-speed customers across the company’s wireline territory of incumbency migrated to its mobile wireless broadband service.

f) Using the average high-speed Internet users, user profile of 12.3 gigabytes per month (The 2008 Monitoring report estimated 9.1 gigabytes of downstream and 3.2 gigabytes of upstream usage per month), identify the price the company’s wireless subscriber would pay per month. Estimate the price they would pay using a comparable wireline high-speed access service offered by the company.

 

300 Series:

Interrogatories to All ILECs

301. With respect to the wholesale obligations for the company’s aggregated ADSL services and the major cable carrier’s TPIA service offered within the company’s operating territory:

a) Provide the company’s views, with supporting rationale regarding the equitability and/or competitive disadvantages of the wholesale obligations for the company’s aggregated ADSL service(s) in comparison with the major cable carrier’s TPIA service. The response should address all relevant factors including those listed below:

i. Service speeds (e.g. maximum line speed, speed matching with retail offerings);

ii. Competitor interconnection types (e.g ATM, GigE) and speeds;

iii. Level of aggregation of end-user traffic at competitor interconnection points: regional aggregation with a limited number of interconnection points to access all end-users, provincial aggregation with a single interconnection point to access all end-users within a province, capability to access all end-users from an interconnection point at any CO/head-end enabled for high-speed access; and

iv. Service limitations such as: prohibitions on multicast, support of LAN service, support of VPN services, availability of residential service only.

b) In addition, provide the company’s views on appropriate remedies for any wholesale obligations that are inequitable or represent a competitive disadvantage.

302. Assume that the Commission has mandated both a CO-based ADSL access service that provides access to all end users that the ILEC can serve from a CO, and a local head-end based cable access service utilizing shared upstream and shared downstream channels, that provides access to all end users that the cable carrier can serve from a head-end. Provide the company’s views, with supporting rationale, on the appropriate wholesale obligations for the CO-based ADSL access service and the local head-end based cable access service that ensure that such obligations are equitable and do not represent a competitive disadvantage to either service provider. The response should address all relevant factors including any applicable factors listed above for question 301.

303. Assume that cable carriers are mandated to provide a local head-end-based service with dedicated upstream and downstream channel service to competitors. Provide the company’s views, with rationale, on a corresponding ILEC wholesale service (existing or proposed) that would impose a wholesale obligation on the ILEC that would be equitable and not represent a competitive disadvantage.

 

400 Series:

Interrogatories to All ILECs

401. In response to ____(CRTC)6Nov09-2 The Bell Companies submitted that:

There would be major issues to resolve for two service providers to be able to provision and support their own services using the same customer premise device. Further, the wholesale ISP would no longer be able to provide and support the modem as it does today with wholesale aggregated ADSL service.

Assume that the Commission determines that end-customer modem, required for the provisioning of wholesale ADSL access service, must be provided and managed by the ILEC:

a) Indicate with rationale, why the ILEC could not provision a maximum speed CO-based ADSL access service, with IPTV restrictions similar to those that apply to its own retail customers.

b) If ILEC provisioning of the end-customer modem as described in a) above is acceptable to competitors, identify with rationale, whether the company is prevented from offering IPTV to retail end-customers who obtain their retail high-speed Internet service from these wholesale competitors using an ILEC provided and managed end-customer modem.

402. With respect to ILEC retail customers subscribing to IPTV (over wireline facilities) and retail high-speed Internet access service:

a) Identify under what circumstances the services will be provisioned over the same end-user copper-loop and under what circumstances the services will be provisioned on separate copper-loops.

b) Describe with rationale the service limitations that the retail customer would be advised of based on each provisioning method described in a) above.

c) When separate copper-loops are used to provision both services, would the two services share the same customer premise modem or would two separate modems be required.

403. The ILECs have generally submitted that they are offering or plan to offer IPTV service to end-customers over their FTTN and FTTH wireline networks. For each of the scenarios identified below, provide the IPTV demand for each of 2010, 2011, and 2012:

a) The CO-based ADSL access service and speed-matching requirement for aggregated ADSL access service are not mandated.

b) The services identified in a) above are mandated. Explain any difference in demand to that projected in a) above.

404.

a) Provide detailed rationale on how, if at all, the mandating of wholesale Internet access services would impede the company’s ability to offer retail bundles.

b) With regard to any impediments identified in a) above, describe how they differ from the case where end-users purchase retail high-speed Internet service from the ILEC and TV distribution service from the cable carrier, or vice-versa.
405. See ILEC-specific Question 405 for the Bell Companies.

Interrogatories to the Bell Companies

405. In TheCompanies(CRTC)17Jul09-1 Bell Canada provided in confidence information related to the volume of wholesale aggregated ADSL access lines currently served from DSLAM equipment located at an FTTN remote.

a) Confirm that these accesses are only provided at speeds that match those provided under the current tariffs for wholesale aggregated ADSL access services.

b) Can the company provide other services, such as retail IPTV, to the end customers that are provided Internet services with these wholesale aggregated ADSL services? Are those company-provided services available over the line used to provide the DSL service or are they provided on another line?

c) What incremental resources and costs would the company incur in order to provide these wholesale aggregated ADSL accesses at higher speeds than those speeds presently provided?

d) In the event that the Commission determines that no mandatory unbundling requirements should apply to FTTN facilities, would Bell Canada continue to provide wholesale aggregated ADSL services at legacy speeds on FTTN facilities?

e) At paragraph 111 of its 8 February 2010 submission, the companies stated:

However, a pro-investment ruling in this proceeding will not mean that competitors must build their own facilities in order to provide service. Competitors will still be able to have access to the facilities of ILECs as well as other service providers on commercially negotiated terms which will reflect the efficient working of market forces.

i. Would the impediments to offering IPTV services when a competitor provides ADSL services to the end customer still apply when the access is provided to competitors on negotiated terms?;

ii. Would the companies propose to limit the availability of wholesale ADSL access services, such as, for example, to make wholesale ADSL access services available only where the customer does not subscribe to IPTV services?

500 Series:

Interrogatories to All ILECs

501. In order to assist the Commission in ascertaining the extent to which protocol conversion from ATM to Ethernet needs to be supported for the CO-based ADSL access service, for the company’s territory of incumbency:

a) Identify the number of NAS that will be IPTV capable for each of the 2010, 2011, and 2012. Further express the percentage of IPTV capable NAS as a percentage of DSL capable NAS.

b) Identify whether IPTV service will be deployed over ATM DSLAMs and if so, to what extent as compared to Ethernet DSLAMs.

c) For new retail high-speed Internet demand provisioned over an IPTV capable NAS, where the customer only requests for high-speed Internet service, identify, with rationale, whether the service will be provisioned over an ATM DSLAM or Ethernet DSLAM.

502. See ILEC-specific Question 502 for TELUS.

Interrogatories to TELUS

502. Provide the cost per CO, to implement the ATM to Ethernet protocol conversion functionality at a CO that is not currently equipped with this capability.

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)

100 Series:

Interrogatories to All Cable Carriers

101. Refer to the capital investment by the cable industry to deploy network infrastructures and facilities to support advanced digital services provided in Chart 4 on page 22 of comments submitted by Bragg Communications Inc., Cogeco Cable Inc., Rogers Communications Inc., Shaw Communications Inc. and Quebecor Media Inc., on behalf of its affiliate Videotron Ltd. dated 8 February 2010. For each cable carrier:

a) Identify and describe the services (video on demand, Internet, etc.) that are included in the above-noted advanced digital services and the upstream and downstream bandwidth requirement for each service.

b) For each of the years 2000 to 2008 and for the additional year of 2009, provide the total capital expenditures associated with the above-noted advanced digital services, and further provide a breakdown of these capital expenditures into those that are attributable to high speed Internet access infrastructure (excluding Ethernet access infrastructure), and other service infrastructures, specifying and describing each infrastructure.

c) With reference to part b) above, provide an estimate of capital expenditures that stem from public funding over 2000 to 2009, identifying whether the funding is municipal, provincial or federal. Further specify if the funding is one time or ongoing.

d) Based on the company’s high speed Internet access infrastructure, provide the total number of high-speed Internet capable homes passed in the company’s territory.

e) Provide the impact that the Commission’s regulatory obligations associated with high speed Internet access have had on the company’s historical capital expenditures in its high speed Internet access infrastructure, with supporting evidence. Further, comment on the impact that the proceedings to review the regulatory status of wholesale Internet access since the issuance of Telecom Decision 2008-17 have had on the company’s high speed Internet access infrastructure investments, with supporting evidence. The response should further identify the impacts that these regulatory obligations may have had on investments in markets of different sizes, with supporting rationale.

102. For each cable carrier, with respect to the technologies planned to be deployed to provision network infrastructures and facilities to support advanced digital services from 2010 to 2012, assuming that the cable carriers are not required to provide matching speeds on their wholesale TPIA service other than those that are already provided to the competitors:

a) Identify the major technologies and/or technology upgrades planned to be deployed by the company to provision network infrastructures and facilities to support advanced digital services. Describe how each of these technologies will impact the high speed Internet upstream and downstream bandwidth capability per end-user; if the bandwidth is shared by a community of end-users, specify the average number of end-users per community.

b) For the technologies identified in response to part a) above, identify other services planned to be offered over these technologies and the associated upstream and downstream bandwidth requirements. To the extent that TV distribution services are to be offered, indicate whether the services will be delivered as unicast, multicast, or broadcast.

c) In the event that the company deploys FTTH in a neighbourhood, indicate whether the company will continue to provide retail and/or wholesale services over the existing HFC infrastructure in that neighbourhood with supporting rationale. If yes, provide the company’s plans to deliver services on both technologies.

d) For each technology identified in response to part a) above, provide schematic diagrams and identify the major components used. Further provide a description of each major component including its functions.

e) For each of the major technologies and technology upgrades identified in response to a) above, for each of the years 2010 to 2012, provide the company’s forecast capital expenditures in provisioning network infrastructures and facilities to support advanced digital services, and further provide a breakdown of these capital expenditures into those that are attributable to high speed Internet access infrastructure, and other service infrastructures, specifying and describing each infrastructure.

f) For each technology identified in response to part a) above, provide the forecast number of homes passed (i.e. high speed Internet capable homes) in 2012. Further, for each of these technologies, for each of existing and new neighbourhoods, provide the company’s estimate of the average capital expenditure required to add such a capability for a home, with supporting assumptions.

g) For each technology identified in response to part a) above, identify the criteria used to assess whether or not to implement the technology in the market, including provisioning guidelines, construction costs, services, revenues, competitive threat, and take-rate considerations. Explain whether and how the above criteria will be different for markets of different sizes.

h) Comment on the impact that the Commission’s regulatory obligations may have on the company’s planned capital expenditures with supporting rationale, under each of the following change in assumptions:

i. The Commission does not mandate wholesale TPIA matching speeds nor a local head-end-based high speed access service;

ii. The Commission mandates a wholesale local head-end-based high speed access service, excluding broadcast capability, using the same upstream and downstream channels as the cable company’s retail Internet customers; and

iii. The Commission mandates a wholesale local head-end-based high speed access service, using a dedicated upstream and downstream channel.

103. For each cable carrier, for each of the years 2007 to 2009, for each of the retail single-line business and residence Internet services offered by the company, provide the following information:

a) The average number of subscribers by service speed.

b) The total revenues by service speed, where the revenues include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service. In addition to the revenues as defined above, separately identify the applicable usage charges associated with the service for the year in question.

104. For each cable carrier, for each of the years 2007 to 2009, for each of retail single-line business and residence Internet services, provide the average speed and average revenue per subscriber, averaged over all speeds.

105. For each cable carrier, for each of the years 2010 to 2012, for each of retail single-line business and residence Internet services:

a) Provide the company’s total demand and revenue* forecast of its high speed retail Internet services assuming that the cable carriers are not required to provide matching speeds on their wholesale TPIA service other than those that are already provided to the competitors.

b) Provide the company’s total demand and revenue* forecast of its high speed retail Internet services under each of the following change in assumptions:

i. The Commission does not mandate wholesale TPIA matching speeds nor a local head-end-based high speed access service;

ii. The Commission mandates a wholesale local head-end-based high speed access service, excluding broadcast capability, using the same upstream and downstream channels as the cable company’s retail Internet customers;

iii. The Commission mandates a wholesale local head-end-based high speed access service, using a dedicated upstream and downstream channel; and

iv. The Commission mandates TPIA matching speeds, with a single designated POI in each province of its incumbency.

The response should identify any additional assumptions the company has made in providing their demand and revenue forecasts.

*Revenues are to include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service.

106. Assume that the Commission mandates a local head-end based high-speed access service. Provide your views on whether and to what extent the TPIA service should be phased-out and, if so, identify with supporting rationale what the criteria should be for phasing-out the service in markets of different sizes.

200 Series:

Interrogatories to All Cable Carriers

201. Identify access technologies other than HFC and mobile wireless that the company uses to provide retail high-speed Internet access services. For each technology identified, specify:

a) The service characteristics of the retail service that is being marketed and the geographic area where the service is currently available.

b) The retail price(s) for the service, by speed.

c) The demand for the service, by speed.

d) Whether, with rationale, the service is a substitute for wireline access services (i.e. provides subscribers comparable value and user experience to wireline access services).

202. The incumbents generally submitted that inter-modal competition from (1) mobile wireless technology and (2) fixed wireless technology would provide a basis for retail Internet service competition. Provide the following information, separately for each type of wireless high-speed Internet service (mobile and fixed), with respect to the future provision of such services:

a) The company’s views on (a) the geographic areas where such services will be offered and timeframes (where the time frame is either (a) short term - less than 2 years (b) medium - more than 2 years and less than 5 years and (c) long-term, more than 5 years); and

b) The service’s capabilities (e.g. upload and download speeds) and restrictions.

203. To the extent that the companies that provide, or will provide, wireless retail Internet services are affiliates of the company, provide with reasons the company’s views on the extent to which competition between wireless and wireline services would be sufficient to protect the interests of users.

204. See Cable Carrier-specific Question 204 for Rogers.

Interrogatories to Rogers

204. The Companies, TELUS and Rogers submitted that wireless broadband networks represent an alternative to wireline high-speed access services that are the subject of this proceeding.

a) Describe the access speeds available to end-user’s and capacity available per cell on the company’s mobile wireless broadband networks.

b) Total number of end-users that can be simultaneously served off a cell such that the end-users receive comparable experience to wireline 5 Mbps high-speed access service.

c) Identify the monthly downstream and upstream usage (in gigabytes) on average used by a wireline high-speed Internet end-user.

d) If 10% of wireline high-speed customers across the company’s wireline territory of incumbency migrated to its mobile wireless broadband service, assuming the usage profile of an average user provided in response to c) above, describe the additional upgrades and associated costs to augment capacity on the company’s wireless network (use recent spectrum acquisition costs as a proxy for additional spectrum).

e) Provide a response to the question in d) above if 30% of wireline high-speed customers across the company’s wireline territory of incumbency migrated to its mobile wireless broadband service.

f) Using the average high-speed Internet users, user profile of 12.3 gigabytes per month (The 2008 Monitoring report estimated 9.1 gigabytes of downstream and 3.2 gigabytes of upstream usage per month), identify the price the company’s wireless subscriber would pay per month. Estimate the price they would pay using a comparable wireline high-speed access service offered by the company.

300 Series:

Interrogatories to All Cable Carriers

301. With respect to the wholesale obligations for the company’s third party internet access (TPIA) services and the major ILEC’s aggregated ADSL service offered within the company’s operating territory:

a) Provide the company’s views, with supporting rationale regarding the equitability and/or competitive disadvantages of the wholesale obligations for the company’s TPIA service in comparison with the major ILEC’s aggregated ADSL service(s) offered within the company’s operating territory. The response should address all relevant factors including those listed below:

i. Service speeds (e.g. maximum line speed, speed matching with retail offerings);

ii. Competitor interconnection types (e.g ATM, GigE) and speeds;

iii. Level of aggregation of end-user traffic at competitor interconnection points: regional aggregation with a limited number of interconnection points to access all end-users, provincial aggregation with a single interconnection point to access all end-users within a province, capability to access all end-users from an interconnection point at any CO/head-end enabled for high-speed access; and

iv. Service limitations such as: prohibitions on multicast, support of LAN service, support of VPN services, availability of residential service only.

b) In addition, provide the company’s views on appropriate remedies for any obligations that are inequitable or represent a competitive disadvantage.

302. Assume that the Commission has mandated both a CO-based ADSL access service that provides access to all end users that the ILEC can serve from a CO, and a local head-end based cable access service utilizing shared upstream and shared downstream channels, that provides access to all end users that the cable carrier can serve from a head-end. Provide the company’s views, with supporting rationale, on the appropriate wholesale obligations for the CO-based ADSL access service and the local head-end based cable access service that ensure that such obligations are equitable and do not represent a competitive disadvantage to either service provider. The response should address all relevant factors including any applicable factors listed above for question 301.

303. Assume that cable carriers are mandated to provide a local head-end-based service with dedicated upstream and downstream channel service to competitors. Provide the company’s views, with rationale, on a corresponding ILEC wholesale service (existing or proposed) that would impose a wholesale obligation on the ILEC that would be equitable and not represent a competitive disadvantage.

304. The ILECs’ aggregated ADSL services support capability to access all ADSL-capable end-users from any ADSL-enabled CO. Describe, with rationale, any technical and economic challenges and any required network modifications in order for the company to provide a wholesale customer with an interconnection that enables access to all high-speed enabled end-users within the cable carriers operating territory from:

a) Any designated Point of Interconnection (POI) in each province of its incumbency.

b) Any head-end that supports high-speed access in each province of its incumbency.

400 Series:

Interrogatories to All Cable Carriers

401.

a) Provide detailed rationale on how, if at all, the mandating of wholesale Internet access services would impede the company’s ability to offer retail bundles.

b) With regard to any impediments identified in a) above, describe how they differ from the case where end-users purchase retail high-speed Internet service from the ILEC and TV distribution service from the cable carrier, or vice-versa.

Interrogatories to:

• Competitors that filed initial submissions (including those represented by CAIP, QCISP, and Open Source Solutions);
• To ILECs and cable carriers outside their territory of incumbency.
100 Series:

Interrogatories to All Competitors

101. With respect to the company’s current retail high speed Internet services:

a) For each of the years 2007 to 2009, provide the total capital expenditures the company has invested in facilities to provision its retail Internet services. Further provide an estimate of capital expenditures that stem from public funding over 2007 to 2009, identifying whether the funding is municipal, provincial or federal.

b) Further to the response to part a) above, provide the impact that the Commission’s regulatory obligations associated with high speed Internet access services have had on these historical capital expenditures, with supporting evidence.

c) For each of the forecast years 2010 to 2012, provide an estimate of the total capital expenditures that the company plans to invest to provision its retail Internet services, identifying and describing the major facilities, under each of the following assumptions*:

i. The ILECs and cable carriers are not required to provide matching speeds for their wholesale Internet access speeds other than those that are already provided to the competitors;

ii. The Commission mandates wholesale aggregated ADSL/TPIA matching speeds;

iii. The Commission mandates a wholesale CO-based/head-end-based Internet access service; and

iv. The Commission mandates a wholesale local head-end-based high speed access service, using a dedicated upstream and downstream channel.

*Assume that the ILEC wholesale service is available to competitors including DSL ISPs using self or 3rd-party co-location arrangements. The service is offered at maximum line speed and excludes broadcast capability.

102. For each of the years 2007 to 2009, for each of the retail single-line business and residence high speed Internet services offered by the company, provide the following information:

a) The average number of subscribers by service speed.

b) The total revenues by service speed, where the revenues include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service. In addition to the revenues as defined above, separately identify the applicable usage charges associated with the service for the year in question.

103. For each of the years 2007 to 2009, for each of retail single-line business and residence Internet services, provide the average speed and average revenue per subscriber, averaged over all speeds.

104. For each of the years 2010 to 2012, for each of retail single-line business and residence Internet services:

a) Provide the company’s total demand and revenue* forecast of its high speed retail Internet services and assuming that the ILECs and cable carriers are not required to provide their wholesale Internet access service speeds that match retail Internet speeds other than those that are already provided.

b) Further to the response to part a) above, provide the company’s demand forecast of retail Internet service end-users under each of the following change in assumptions:

i. The Commission mandates wholesale aggregated ADSL matching speeds;

ii. The Commission mandates wholesale aggregated ADSL matching speeds, and a TPIA service with a single designated POI per region for TPIA;

iii. The Commission mandates a wholesale universal CO-based ADSL access service** and local head-end based high speed access service. The local head-end based service is provisioned on the same upstream and downstream channels as the cable company’s retail Internet customers; and

iv. The Commission mandates wholesale universal CO-based ADSL access service ** and local head-end based high speed access service. Local head-end based service is provisioned on a dedicated upstream and downstream channel for competitors.

For each of the responses to parts iii) and iv) above, the company should specify its demand forecast for each of the wholesale universal CO-based ADSL access service** and the local head-end based high speed access service. Further, the response should identify any additional assumptions the company has made in providing its demand forecasts.

*Revenues are to include the recurring Internet service revenues, any applicable monthly equipment rental charges and any applicable usage charges that are associated with the service.

**The ILEC wholesale service is available to competitors including DSL ISPs using self or 3rd-party co-location arrangements. The service is offered at maximum line speed and excludes broadcast capability.

105. Assume that the Commission mandates a universal CO-based ADSL access service. Provide your views on whether and to what extent the aggregate ADSL access service should be phased-out and, if so, identify with supporting rationale what the criteria should be for phasing-out the service in markets of different sizes.

106. Assume that the Commission mandates a local head-end based high-speed access service. Provide your views on whether and to what extent the TPIA service should be phased-out and, if so, identify with supporting rationale what the criteria should be for phasing-out the service in markets of different sizes.

107. See Competitor-specific Question 107 for TekSavvy.

Interrogatories for TekSavvy

107. TekSavvy submitted that it was deploying FTTH, through one of its affiliates, in a couple of small communities in order to provide residents of those communities with new innovative services and service bundles.

a) Identify the number of homes passed in each of the communities where FTTH is being undertaken.

b) Identify whether these implementations are existing homes served by incumbents or new homes. If mixed identify the percentage in each category.

c) Provide detailed rationale for the company’s investment decision including costs and revenue projections for each of 2010, 2011 and 2012.

d) Provide a discussion on whether this investment model can be extended to other communities and to what extent.

e) Identify, separately, all facilities-based access infrastructure investments planned by the company or its affiliates for each of 2010, 2011 and 2012. Further identify the communities and the number of homes passed.

200 Series:

Interrogatories to All Competitors

201. Identify access technologies other than HFC, DSL and mobile wireless that the company uses to provide retail high-speed Internet access services. For each technology identified, specify:

a) The service characteristics of the retail service that is being marketed and the geographic area where the service is currently available.

b) The retail price(s) for the service, by speed.

c) The demand for the service, by speed.

d) Whether, with rationale, the service is a substitute for wireline access services (i.e. provides subscribers comparable value and user experience to wireline access services).

300 Series:

Interrogatories to All Competitors

301. With respect to the wholesale obligations for the major ILEC’s aggregated ADSL services and the major cable carrier’s TPIA service offered within the company’s operating territory:

a) Provide the company’s views, with supporting rationale regarding the equitability and/or competitive disadvantages of the wholesale obligations for the ILEC’s aggregated ADSL service(s) in comparison with the wholesale obligations for the major cable carrier’s TPIA service. The response should address all relevant factors including those listed below:

i. Service speeds (e.g. maximum line speed, speed matching with retail offerings).

ii. Competitor interconnection types (e.g ATM, GigE) and speeds;

iii. Level of aggregation of end-user traffic at competitor interconnection points: regional aggregation with a limited number of interconnection points to access all end-users, provincial aggregation with a single interconnection point to access all end-users within a province, capability to access all end-users from an interconnection point at any CO/head-end enabled for high-speed access; and

iv. Service limitations such as: prohibitions on multicast, support of LAN service, support of VPN services, availability of residential service only.

b) In addition, provide the company’s views on appropriate remedies for any obligations that are inequitable or represent a competitive disadvantage.

302. Assume that the Commission has mandated both a CO-based ADSL access service that provides access to all end users that the ILEC can serve from a CO, and a local head-end based cable access service utilizing shared upstream and shared downstream channels, that provides access to all end users that the cable carrier can serve from a head-end. Provide the company’s views, with supporting rationale, on the appropriate wholesale obligations for the CO-based ADSL access service and the local head-end based cable access service that ensure that such obligations are equitable and do not represent a competitive disadvantage to either service provider. The response should address all relevant factors including any applicable factors listed above for question 301.

303. Assume that cable carriers are mandated to provide a local head end-based service with dedicated upstream and downstream channel service to competitors. Provide the company’s views, with rationale, on a corresponding ILEC wholesale service (existing or proposed) that would impose a wholesale obligation on the ILEC that would be equitable and not represent a competitive disadvantage.

500 Series:

Interrogatories to All Competitors

501. Identify separately for the residential and business market, the revenue contribution from ILEC copper-loop based high-speed Internet services (including aggregated ADSL access and self-supplied DSLAMs) as a percentage of total revenues from telecommunication and data services.

Date modified:

2010-03-18