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Our File:  8622-P8-201015925

Ottawa, 15 March 2011

BY E-MAIL

Natalie MacDonald
Bragg Communications Inc.
Vice President, Regulatory Matters
regulatory.matters@corp.eastlink.ca

William Sandiford
Canadian Network Operators Consortium Inc.
Chair of the Board and Presidentv

regulatory@cnoc.ca

Re: Application by the Consumer Groups regarding wholesale high-speed access services

The Commission received an application from the Public Interest Advocacy Centre on behalf of itself and Canada Without Poverty (collectively, the Consumer Groups), dated 25 October 2010.  The Consumer Groups, among other things, requested that the Commission apply the directives it issued in Telecom Regulatory Policy CRTC 2010-632[1] regarding the deployment of wholesale high speed access services to Bragg Communications Inc., operating as EastLink (EastLink).  

The Commission received comments on the Consumer Groups’ application from EastLink and Canadian Network Operators Consortium Inc. (CNOC), both dated 24 November 2010, and the Consumer Groups’ reply dated 6 December 2010.

In order to assist the Commission in making its determinations in this matter, attached are questions to EastLink and CNOC.

Responses to these questions are to be filed with the Commission, by 5 April 2011.

Parties may file comments with the Commission regarding the responses to the above-referenced questions, serving copies on all other parties, by 12 April 2011.

All parties may file reply comments with the Commission, serving copies on all other parties, by 19 April 2011.

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

Sincerely,

Original signed by:

John Macri
Director, Telecommunications Policy

cc :  John Lawford, the Consumer Groups jlawford@piac.ca
Bob Martin, CRTC robert.martin@crtc.gc.ca
Adam Mills, CRTC adam.mills@crtc.gc.ca

Attachment

Questions addressed to EastLink

1. At paragraph 4 of its 24 November 2010 comments, CNOC stated that there is at least one CNOC member that is seeking entry into EastLink’s operating territory at the present time.

Confirm whether CNOC, or one of its members, has approached EastLink directly to request that a wholesale third party Internet access (TPIA) service be made available by the company. If so, (i) confirm the identity of the organization that made the request, the date and details of the request, and (ii) provide EastLink’s response to the request.

2. At paragraph 7 of EastLink’s 24 November 2010 comments, the company stated that the markets where EastLink’s services are available are presently being served by multiple high-speed Internet service providers (ISPs) at speeds anywhere from 15Mbps up to 100Mbps, or more.  The company also stated that independent high-speed ISPs offer services in competition with both EastLink and the incumbent telephone company through resale arrangements. 

a) Provide evidence to support the statement concerning high-speed access services being available from multiple ISPs. The evidence should include but not be limited to any market data with regard to the independent ISPs operating in your territories, locations and/or coverage areas, available access speeds, price, market share, and technology.

b) Provide details related to the resale arrangements made available by EastLink to competitive ISPs, including a list of these ISPs and associated number of end-customers served.

3. Provide the company’s views as to whether the Commission should require EastLink to provide wholesale TPIA service, pursuant to its determinations in Telecom Regulatory Policy 2010-632, in any, or all, of the company’s operating territories in Atlantic Canada.

4. Assume that the Commission requires EastLink to provide wholesale TPIA service, pursuant to its determinations in Telecom Regulatory Policy 2010-632, in any, or all, of the company’s operating territories in Atlantic Canada. 

a) Provide details of what would be the proposed technology solution(s), including any technical diagram(s) depicting how wholesale high-speed Internet access services would be provided to an independent ISP.

b) Provide an estimate of the service development and start-up costs, with any supporting assumptions, to implement such a service.

Attachment

Questions addressed to CNOC

1. At paragraph 4 of its 24 November 2010 comments, CNOC stated that there is at least one of its members is seeking entry into EastLink’s territory at the present time.

a) Confirm the identity of the organization that made the request, the date and details of the request, and provide EastLink’s response to the request.

b) If a direct request has not yet been made, explain why not.

2. At paragraph 5 of its 24 November 2010 comments, CNOC stated that there are virtually no independent ISPs of any significant size based in Atlantic Canada. However, at paragraph 7 of its 24 November 2010 comments EastLink stated that the markets where its services are available are presently being served by multiple high-speed ISPs.

Provide evidence to support your company’s statement.

[1] Wholesale high-speed access services proceeding, Telecom Regulatory Policy CRTC 2010-632, 30 August 2010

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