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Ottawa, 25 February 2011
Our Ref.: 8622-G44-201015438
Ms. Andrea Wood
Chief Legal Officer
WIND Mobile
207 Queen Quay West
Toronto, Ontario M5J 1A7
awood@windmobile.ca
Ms. Dawn Hunt
Vice President Regulatory
Rogers Wireless Partnership
1 Mount Pleasant Road
Toronto, Ontario M4Y 2Y5
Rwi_gr@rci.rogers.com
Dear Madam:
Re: Part VII application by Globalive Wireless Management Corp. – Seamless transition when moving out of zone
On 12 October 2010, Globalive Wireless Management Corp., operating as WIND Mobile (WIND), filed a Part VII application requesting that the Commission find that Rogers Wireless Partnership (Rogers) is conferring an undue preference upon itself and direct Rogers to provide seamless call transition of voice and data calls between Rogers’ and WIND’s networks.
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, Rogers and WIND are to respond to the attached interrogatories by
8 March 2011, serving copies on all other parties.
Parties are reminded that 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
Director, Competition Implementation and Technology
Telecommunications
Attachment 1: Interrogatories to Rogers
Attachment 2: Interrogatories to WIND
cc: pconlin@ogilvyrenault.com; Bell.regulatory@bell.ca; ted.woodhead@telus.com; jesslyn.mullaney@crtc.gc.ca
Attachment 1
Interrogatories to Rogers
Staff notes that seamless communication for in-progress calls, requested by WIND, is distinct from accidental roaming. Seamless communication ensures that an in-progress call of a WIND customer is not dropped when the customer enters or leaves Rogers’ network and the call is charged at roaming rates. In contrast, accidental roaming ensures that a customer of one wireless provider is redirected to his/her home network and is not inappropriately charged roaming rates when accidentally picked-up by the network of another wireless provider. These interrogatories are in relation to seamless communication for in-progress calls.
101. Describe the network resources required to provide seamless communication for
in-progress calls when a Rogers customer moves from the coverage area of a cell site to the coverage area of another cell site, where each of the cell sites is served by separate switches.
102. Rogers offers WIND roaming services in areas within Canada that are outside WIND’s wireless network footprint. The current roaming arrangement does not provide seamless communication for in-progress calls, when a WIND customer moves outside of WIND’s network coverage area into Rogers’ network coverage area.
a. Identify any network changes that would need to be implemented in Rogers’ network to accommodate seamless communication for in-progress calls of WIND customers, when they move outside of WIND’s network coverage area into Rogers’ network coverage area?
b. For each network change identified in response to part a. above:
i. Identify and provide a detailed description of the activities and resources required, with supporting rationale.
ii. Provide an estimate of the cost to implement seamless roaming capability for WIND.
iii. Provide an estimate of the timeframe to implement seamless roaming capability for WIND.
c. Propose, with rationale, a pricing approach to recover the costs estimated in b. iii. above.
d. Discuss resource differences between seamless roaming scenario contemplated in 102 a. and b. and the scenario in 101.
Attachment 2
Interrogatories to WIND
201. WIND in its application stated that, “WIND is injured economically. Rogers’ conduct subjects WIND to an undue and unreasonable disadvantage by undermining potential WIND subscribers’ confidence in their ability to access reliable telecommunications of high quality while subscribed to WIND.”
a. Identify the nature of this disadvantage and provide evidence of such disadvantage.
202. Rogers offers WIND roaming services in areas within Canada that are outside WIND’s wireless network footprint. The current roaming arrangement does not provide seamless communication for in-progress calls, when a WIND customer moves outside of WIND’s network coverage area into Rogers’ network coverage area.
a. Identify any network changes that would need to be implemented in WIND’s network to accommodate seamless communication for in-progress calls of WIND customers, when they move outside of WIND’s network coverage area into Rogers’ network coverage area?
b. For each network change identified in response to part a. above:
i. Identify and provide a detailed description of the activities and resources required, with supporting rationale.
ii. Provide an estimate of the cost to implement seamless roaming capability for WIND.
Iii. Provide an estimate of the timeframe to implement seamless roaming capability for WIND.
c. Propose, with rationale, a pricing approach that is acceptable to WIND, for Rogers to recover the costs it incurs to implement seamless roaming for WIND.
203. In the event that seamless roaming is mandated, for each geographic area where seamless communication is required, for each of 2011, 2012, and 2013, estimate:
a. The total number of roaming minutes
b. The size of the communication links to Rogers’ network (expressed as number of DS0s)
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