ARCHIVED - Letter

Our Reference No.: 8622-T66-201100213

BY E-MAIL

Distribution

RE: TELUS Communications Company – Application for clarification and expedited relief concerning the manner in which Bell Canada intends to implement Telecom Decision 2010-908

Dear Sir/Madam:

Commission staff considers there is a need for additional information in order for the Commission to make determinations on the matters raised by parties in the above-noted proceeding.  Therefore, parties are to respond to the attached interrogatories by
4 March 2011, serving copies on all other parties included in the distribution list.

Parties are reminded that where a document is to be filed or served by a specific date, the document must be actually received, and not merely sent, by that date.

Sincerely,

Original signed by

Mario Bertrand
Director, Competition Implementation and Technology
Telecommunications

Revised Interrogatories for Rogers, QMI, JTF

101. At paragraph 21 of its 26 January 2011 reply comments, TELUS Communications Company (TCC) proposed two alternatives for consideration, as follows:

“a) Rather than blocking calls, Bell may be able to use the system supporting the blocking mechanism to generate reports of calls that would have been blocked based on the calling number.  The reports could also be investigated to see the extent of calls that would have been blocked, and if it is a low volume, whether the calls could be regarded as wireless roaming or VoIP calls.  If the volume of calls that would have been blocked is high, the data in the reports could then be examined to whether there are particular parties that are sending toll traffic over local termination trunks, and these parties could be made to pay any toll contribution that was avoided.

b) The toll contribution currently paid to SILECs for every long-distance call could be converted to an amount paid on every incoming call, local and
long-distance.  The new rate would be revenue-neutral to the SILEC and would be applied to local transit trunks as well as toll trunks.  It would shift to some degree the contribution burden from IXCs to LECs and WSPs, but this distortion would be less significant than the distortion caused by a requirement for all CLECs to route all their local traffic for toll termination.”

Provide comments, with supporting rationale, on the feasibility and appropriateness of implementing either of the proposed alternatives.

102. In its 24 January 2011 comments, Bell Canada argued that in previous decisions (specifically, Telecom Decisions 2005-28, 2006-28 and 2007-23), the Commission has ruled that calls made utilizing access-independent VoIP services and those made by wireless subscribers roaming in exchanges other than the exchange associated with their telephone number are toll calls.  Provide comments, with supporting rationale, on the validity of Bell Canada’s arguments in this regard.

103. In its 24 January 2011 comments, Bell Canada submitted:

“(T)he number of calls made utilizing access-independent VoIP services and wireless handsets with telephone numbers assigned to distant exchanges is insignificant and does not warrant the costs required to institute measures to ensure such traffic is not blocked.”

Provide comments, with supporting rationale, on Bell Canada’s arguments to this effect.

Interrogatory for TCC, Rogers and QMI

201. In its 24 January 2011 comments, Bell Canada submitted:

“The costs of identifying the physical location of callers making calls over Bell’s Local Transit services would be significant and would outweigh any benefit of doing so.”

Are your operational systems capable of identifying the physical point of origin of callers making calls over a local interconnection service?  If not, discuss what would be involved in modifying the operational system to achieve this capability, and provide a cost estimate, along with supporting cost methodology and assumptions.

Interrogatories for Bell Canada

301. At paragraph 21 of its 26 January 2011 reply comments, TELUS Communications Company (TCC) proposed two alternatives for consideration, as follows:

“a) Rather than blocking calls, Bell may be able to use the system supporting the blocking mechanism to generate reports of calls that would have been blocked based on the calling number.  The reports could also be investigated to see the extent of calls that would have been blocked, and if it is a low volume, whether the calls could be regarded as wireless roaming or VoIP calls.  If the volume of calls that would have been blocked is high, the data in the reports could then be examined to whether there are particular parties that are sending toll traffic over local termination trunks, and these parties could be made to pay any toll contribution that was avoided.

b) The toll contribution currently paid to SILECs for every long-distance call could be converted to an amount paid on every incoming call, local and
long-distance.  The new rate would be revenue-neutral to the SILEC and would be applied to local transit trunks as well as toll trunks. It would shift to some degree the contribution burden from IXCs to LECs and WSPs, but this distortion would be less significant than the distortion caused by a requirement for all CLECs to route all their local traffic for toll termination.”

Provide comments, with supporting rationale, on the feasibility and appropriateness of implementing either of the proposed alternatives.

302. In its 24 January 2011 comments, Bell Canada submitted:

“The costs of identifying the physical location of callers making calls over Bell’s Local Transit services would be significant and would outweigh any benefit of doing so.”

Discuss what would be involved in modifying Bell Canada’s operational systems to enable it to identify the physical point of origin of calls over its Local Transit services, and provide a cost estimate, along with supporting cost methodology and assumptions.

303. In its 26 January 2011 reply comments, TCC submitted:

“In addition, Bell has stated that for Bell Mobility, it does not use local transit service, but Bell’s Wireless Access Service (“WAS”), and that ‘other wireless carriers may terminate calls to the PSTN utilizing Bell’s WAS’.  Therefore, TCC wonders why wireless roaming calls should be subject to blocking in the first place, if Bell’s suggested solution to avoid blocking is to utilize Bell’s WAS service, where no toll contribution would be payable.  It appears to TELUS that all wireless roaming should not be subject to toll contribution, and it should not matter whether the WSP chooses to lease Bell’s WAS service or another LEC’s WAS service.”

Comment on TCC’s arguments in this regard.

Distribution list:

andrew@isptelecom.net; bell.regulatory@bell.ca; regaffairs@quebecor.com; regulatory.affairs@telus.com; gcordeau@maskatel.qc.ca; documents@accesscomm.ca; Regulatory.Matters@corp.eastlink.ca; jboutros@globility.ca; steve@wtccommunications.ca; grubb@hurontel.on.ca; rbanks@mornington.ca; brenda.stevens@rci.rogers.com; sachuter@tcc.on.ca; regulatory@telnetcommunications.com; regulatory@execulink.com; cedric.tardif@derytelecom.ca; s.cloutier@axion.ca; iworkstation@mtsallstream.com; bazilewichr@westmancom.com; Regulatory@sjrb.ca; regulatory.aff@fidomobile.ca; tracy.cant@ontera.ca; reglementation@xittel.net; pallard@cooptel.qc.ca; alain.duhaime@sogetel.com; lisagoetz@globalive.com; donna.robertson@novusnow.ca; regulatory@fibernetics.ca; rishi.patel@flexity.ca; clayton@mnsi.net; mark.halwa@nanofibre.ca; michel.messier@cogeco.com; jdowns@nexicomgroup.net; regulatory@brucetelecom.com; denis@michaud.qc.ca; regulatory@terago.ca; crtc@les.net; lisa.marogna@cwct.ca; tsullivan@wightman.ca; sbishay@iristel.com; regulatory@distributel.ca; ataylor@personainc.ca; Regulatory.Matters@corp.eastlink.ca; perron@ccapcable.com; mbontje@sourcecable.ca; info@mountaincable.net; regulatory@vianet.ca; pwightman@wightman.ca; a.schneider@hay.net; alain.duhaime@sogetel.com; paul.frappier@telmilot.com; j-fmathieu@telupton.qc.ca; telstep@telstep.net; nfrontenac@kw.igs.net; nantel@tellambton.net; rroy@telwarwick.qc.ca; jpatry@telcourcelles.qc.ca; telvic@telvic.net; scoffey@dryden.ca; m.baron@brktel.on.ca; sachuter@tcc.on.ca; roxboro@ontarioeast.net; steve@wtccommunications.ca; nicolet@puc.net; jdowns@nexicomgroup.net; rbanks@mornington.ca; dave.baxter@quadro.net; gosfield@gosfieldtel.com; sgander@kmts.biz; wagrier@1000island.net; regulatoryaffairs@nwtel.ca; pdowns@nexicom.net; lisa.marogna@cwct.ca; rob.olenick@tbaytel.com; reglementa@telebec.com; pallard@cooptel.qc.ca; jonathan.holmes@ota.on.ca; sdesy@actq.qc.ca

Date modified:

2011-02-18