ARCHIVED - Letter

Ottawa, 29 April 2011

Our Reference: 8661-C12-201102350

BY E-MAIL

To Distribution List

Re: Request for information – Telecom Notice of Consultation CRTC 2011-77, Review of billing practices for wholesale residential high-speed access services (NoC 2011-77), as amended by NoC 2011-77-1 and NoC 2011-77-2

Dear Madam or Sir:

Pursuant to the process specified in paragraph 22 of NoC 2011-77-2, attached are Commission interrogatories associated with this proceeding.

The following parties are requested to provide responses to the attached interrogatories: Bell Aliant Regional Communications, Limited Partnership and Bell Canada (together, the Bell companies); MTS Allstream Inc.; TELUS Communications Company; Cogeco Cable Inc., Quebecor Media Inc. on behalf of its affiliate Videotron Ltd., Rogers Communications Inc., (collectively, the cable carriers); Shaw Communications Inc.; and the Canadian Network Operators Consortium (CNOC).

Pursuant to the process set out in paragraph 23 of NoC 2011-77-1, parties are to file their responses with the Commission, serving copies on all other parties, by 24 May 2011.  These responses are to be received, and not merely sent, by this date.

Copies of the documents should also be sent to Tom Vilmansen (tom.vilmansen@crtc.gc.ca), Richard Pagé (richard.page@crtc.gc.ca), and Mohammed Omar (mohammed.omar@crtc.gc.ca).

Yours sincerely,

Lynne Fancy
Director General
Competition, Costing and Tariffs
Telecommunications

DISTRIBUTION LIST:

pkgdonovan2@gmail.com;  regulatory@vianet.ca; lefebvre@rogers.com; constanlly@rogers.com; lainwired@gmail.com; jim-johnston@cogeco.ca; tracy.cant@ontera.ca; linda_maljan@gov.nt.ca; kevanst.john@gmail.com; Regulatory@sjrb.ca; tom.copeland@caip.ca ; lisagoetz@globalive.com; vince.valentini@tdsecurities.com; crtcubb@douville.org; douglas216@shaw.ca; cataylor@cyberus.ca; jkolyn@ikano.com; angusoliver320@gmail.com; bcampbell@skywaywest.com; martina.emard@lethbridgecollege.ca; babramson@mccarthy.ca; regulatory@cnoc.ca; bell.regulatory@bell.ca; regulatory@bell.aliant.ca; deschec@ircm.qc.ca; regulatory@execulink.com; jcarter@surenet.net; mike.manvell@switchworks.com; rtwanow@gmail.com; ghariton@sympatico.ca; ctacit@tacitlaw.com; crtcmail@gmail.com; scott@beamdog.com; mmallani@yahoo.ca; charles.lalumiere@globaledgenetwork.net; d.olafson@shaw.ca; wally@ciaccess.com; jared.mcateer@istockphoto.com; thepga@gmail.com; dirkalgera@gmail.com; tfarrelly@bryston.ca; al@purepages.ca; rubenstein.mark@gmail.com; jamiea@storm.ca; glenrfarrell@gmail.com; farmboy69@pppoe.ca; dr.wilson@wilson-research.ca; catrace@xplornet.com; jacqueslee917@gmail.com; spaesani@gmail.com; catherine.middleton@ryerson.ca; apilon@acninc.com; jebouchard@phdvideo.com;  ian_fraser@gozoom.ca; scottandkai@rogers.com; dmckeown@viewcom.ca; peterdasilva@yahoo.ca; abriggs@cogeco.ca; fonestarrunner@gmail.com; rwadsworth@sandvine.com; document.control@sasktel.sk.ca; sidneirohr@hotmail.com; ivan@vibrantprints.ca; jae@c-art.com; rem00126@hotmail.com; cmich@rogers.com; tzaritsa1000@hotmail.com; chad.cunningham@cwct.ca; renaonlinenow@gmail.com; tisrael@cippic.ca; jfleger@jflegerlaw.com; andyb@teksavvy.com; samsonmi@tlb.sympatico.ca; andre.labrie@mcccf.gouv.qc.ca; regulatory@primustel.ca; amanevich@heenan.ca; brian@colenet.ca; Regulatory.Matters@corp.eastlink.ca; adena.dinn@calliougroup.com; anlakenews@gmail.com; regulatory@bcba.ca; satkepa@rogers.com; erik.waddell@ic.gc.ca; lukejwohlgemut@hotmail.com; scott@moseley.ca; Smartyjones@sympatico.ca; ricka@zing-net.ca; kirsten.embree@fmc-law.com; hemond@consommateur.qc.ca; grayden@graydenlaing.com; john.temprile@vivosonic.com; yuandme@gmail.com; broxx@shaw.ca; syscool77@hotmail.com; dougheale@yahoo.ca; duarte@aetoronto.ca; eric.leclerc@iaah.ca; jroots@cad.ca; jonathan.holmes@ota.on.ca; mike@mikeaudet.com; mena_samuel@hotmail.com; iworkstation@mtsallstream.com; dennis@iplink.net; rob.olenick@tbaytel.com; shannonbgroves@yahoo.com; t_wardman@hotmail.com; jfmezei@vaxination.ca; scott@zip.ca; ml.auer@sympatico.ca; cbachalo@juniper.net; mdrobac@netflix.com; andrewoca@gmail.com; hannon@rogers.com; hijbji@gmail.com; blackwell@giganomics.ca; david.watt@rci.rogers.com; regulatory.affairs@telus.com;  Andreea.Todoran@ic.gc.ca; cjprudham@barrettxplore.com; regulatory@teksavvy.com; regulatoryaffairs@nwtel.ca; reglementa@telebec.com; marcel.mercia@cybersurf.com; reglementation@xittel.net; regulatory@distributel.ca; telecom.regulatory@cogeco.com; regaffairs@quebecor.com; ken.engelhart@rci.rogers.com; crtc@mhgoldberg.com; eric@rothschildco.com; gfletcher@incentre.net; berzins@nucleus.com; slavalevin@ethnicchannels.com; crtc@les.net; LBC_Consulting@live.ca; bob.Allen@abccomm.com; bruce@brucebuchanan.net; chris.allen@abccomm.com; piac@piac.ca; jhpratt@msn.com; crtc@paul.ca; regulatory@lya.com; David.Wilkie@tbaytel.com; regulatory@fibernetics.ca; stephen.scofich@tbaytel.com; telecom@gov.bc.ca; regulatory@telnetcommunications.com; jp@electronicbox.net; pris@pris.ca; michelle.duguay@telus.com

Interrogatories to Bell Aliant Regional Communications, Limited Partnership and Bell Canada (together, the Bell companies)

1. In their intervention dated 28 March 2011, the Bell companies proposed the introduction of Aggregated Volume Pricing (AVP) for their residential Gateway Access Services (GAS - both legacy and FTTN).  Under the AVP proposal, a wholesale customer of GAS would be billed for the monthly aggregated usage of its end-users.

a. Explain in detail how the Bell companies would measure the monthly aggregated volumes for each wholesale customer of GAS under their AVP proposal.

b. Describe to what degree measurement can be duplicated by the wholesale customer of GAS to facilitate billing reconciliation.

c. Provide the Bell companies’ justification for their proposed markups for the AVP component of  their proposal.

2. If the proposed AVP model was implemented,

a. describe how the proposed AVP model will address the problem of network congestion during peak periods;

b. specify the effect of the proposed AVP model on end-user usage.  The response should provide five-year forecasts starting at 2011 for i) average monthly per end-user usage by year for residential GAS service under the existing rate structure ii) average monthly per end-user usage by year under the proposed AVP model;

c. if the proposed AVP model was modified so that wholesale customers of GAS paid for total volume generated in a month at a rate of $.195 per GB, provide a five-year forecast starting at 2011 for average monthly per end-user usage by year for residential GAS service under the modified model;

d. explain how the proposed rates for the AVP model accommodate the impact of ongoing changes in end-user behaviour (e.g. increased monthly traffic volumes, increased traffic during peak periods, changes in the ratio of total traffic volume to peak traffic ).  The response should address any requirements for ongoing adjustments to rates, with supporting rationale.

3. In their proposed AVP model, the Bell companies proposed that each wholesale customer of GAS be given an aggregated traffic volume credit in proportion to their legacy usage, in recognition that usage was included in the access costs associated with legacy GAS services, specifically those costs submitted in the cost study filed on 16 July 2009 in Bell Canada TN 7181 and Bell Aliant TN 242
(as adjusted by the Commission in Decision 2010-255).

a. Provide the Bell companies’ views, with supporting rationale, on an AVP model in which the access rates for the legacy residential GAS services would be based on costs excluding usage-driven costs (i.e. the same model as that proposed for FTTN-based GAS ).

b. For the Bell companies 16 July 2009 cost study referenced above, using the format of tables 1 to 5, provide a breakdown of the legacy residential GAS services costs into (i) access excluding usage-driven costs and (ii) usage-driven costs, with supporting assumptions and rationale.

4. Where certain speed tiers of GAS can be provided by either legacy technology or FTTN technology, comment on the feasibility of a harmonized rate for these speed tiers.

5. In its intervention dated 28 March 2011, CNOC proposed a pricing model where usage would be aggregated and charged on a per wholesale customer basis and submitted that wholesale customers would have to pay for any peak traffic that their users cause in the aggregate on incumbent networks.  CNOC further submitted that measurement of a wholesale customer’s monthly use of the network should be done on a 95th percentile basis.

Assuming that the Bell companies were to offer their residential GAS services based on CNOC's proposed pricing model,

a. describe how and where in the network the Bell companies would measure, for billing purposes, the monthly peak traffic caused by the end-users of each wholesale customer.

b. specify how much elapsed time would be required to implement CNOC’s model.  The response should identify the additional activities that the Bell companies would have to undertake and the time required for each activity.

c. specify whether the Bell companies use the 95th percentile measurement approach in determination of peak traffic in any of its services or in any of their provisioning practices.  If yes, identify the services and describe the provisioning practices.  If no, describe the approach the Bell companies use for measuring peak traffic in their networks that support high-speed access services.

6. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided Chart B3 entitled “Internet Usage by Time of Day – North America 2010”.  The chart provided i) the level of traffic per end-user as a percentage of the maximum level of traffic per end-user by time of day and ii) the number of end-users that are connected as a percentage of the maximum number of end-users that are connected by time of day.

Indicate whether this chart is representative of the daily Internet usage of the Bell companies’ end-users.  If not, provide an equivalent chart for the Internet usage by time of day for the Bell companies’ end-users.  The response should specify whether the provided information is for retail end-users only or for both retail and wholesale end-users combined.

7. In their intervention dated 28 March 2011, the Bell companies provided in confidence, an estimate of the projected 2011 investment required to reduce congestion to acceptable levels (i.e. network capacity relief) in their networks supporting high-speed access.  Explain how the Bell companies determined their estimate of this projected 2011 investment.  The response should identify the network components included and the methodology and assumptions used, with supporting rationale.

8. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network congestion of the ISP operators’ networks.  In this proceeding, parties have also commented on the need to demonstrate the existence of congestion within the networks.  As such, questions a), b), and c) below are substantially the same as those posed in PN 2008-19.

a) How does the company define congestion in the networks it uses to provide broadband Internet services?  What criteria and measurements are used to determine that there is congestion in the company’s networks?

b) Have the company’s congestion criteria changed between 2008 and 2011?  If so, explain how they have changed.

c) Describe which components (e.g. network elements or links) of the company’s networks, used to provide broadband Internet services, are provisioned based on Internet traffic volumes.  The discussion should include a general description of the architecture of the company’s networks.

d) If congestion is currently present in the company’s network, provide quantitative evidence of such congestion.  Using the components identified in the response to part c) above, specify when this congestion occurs, how many components by type are affected, what proportion of the total components by type are affected, as well as how often congestion is being experienced (i.e. what % of the time elements are experiencing congestion).

9. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network provisioning of the ISP operator’s networks.  As such, questions a) and b) and c) below explore the same subject matter

a) For each component identified above in question 8 c), describe the practices that the company employs to provision its networks.  The answer should include a description of the conditions under which the company would augment its network capacities to address congestion.  Describe in detail the process used to identify when and where additional network capacity is required and how the additional capacity requirements are determined.

b) For each component identified in question 8 c), specify the amount of time required to increase capacity of the component in the company’s network, taking into account the time that elapses between identification of a need to add capacity for the component and the subsequent ordering, provisioning, installation, testing and activation of the additional capacity.

c) Describe any major changes to the company’s provisioning practices for the years 2008 to 2011.  The response should include details on any changes in provisioning assumptions.

d) With respect to other company services being offered using a common network (e.g. managed services such as IPTV services over xDSL networks),

i. describe the differences between the company’s managed services and Internet services that have led the company to separate them.  Clearly define the parameters used to distinguish its managed services from its Internet services,

ii. explain how the company separates its managed services from its Internet services,

iii. explain how such services are planned and provisioned for in a common manner.  Explanations should include a description with diagrams identifying which elements of the networks share common capacity, as well as identifying elements of the network where capacity is provisioned in a separate manner. For elements of the networks that share capacity specify how much capacity is allocated to managed services and how much capacity is allocated to Internet services.

e) With reference to the responses provided in question 8 d) and question 9 d), explain why other services which are provisioned over the same network elements do or do not contribute to network congestion, as well as how the company determines whether to allocate additional capacity to either the Internet services or the other services sharing the capacity.

 

Interrogatories to MTS Allstream Inc.

1. Refer to MTS Allstream’s proposed Tariff Page for ‘Item 5830, Very High-Speed Digital Subscriber Line (VDSL) Data Access Service’, where the company provided proposed monthly rates for 100 Mbps, 400 Mbps, and 1 Gbps Very High-Speed Aggregated High-Speed Service Provider Interfaces (V-AHSSPI).  Under this service proposal a wholesale customer would interconnect at the V-AHSSPI to exchange traffic with its end-customers, and would pre-purchase network traffic capacity (increments of 100 Mbps, 400 Mbps, or 1Gbps) on a monthly basis.  Provide responses to the following :

a. Explain whether the company measures each competitor’s traffic over its network that supports wholesale high-speed access.  If yes, describe how the measurement is done, identifying the points in the network where the traffic is measured .
b. If a competitor’s end-users generate more traffic in aggregate than the level of traffic purchased by the competitor under the proposed tariff for the
V-AHSSPI, explain whether the company would control or limit this traffic .

i. If the company controls or limits this traffic, explain how and at what points in the network it controls the competitor’s traffic flow.

ii. If the company does not control or limit the competitor’s traffic, explain what impact the additional traffic would have on the company’s network performance.

2. In its intervention dated 28 March 2011, CNOC proposed a pricing model where usage would be aggregated and charged on a per wholesale customer basis and submitted that wholesale customers would have to pay for any peak traffic that their users cause in the aggregate on incumbent networks.  CNOC further submitted that measurement of a wholesale customer’s monthly use of the network should be done on a 95th percentile basis.

a. Describe how the current model proposed by the company that charges wholesale customers based on a pre-purchased level of aggregate monthly traffic could be adapted to CNOC’s proposed model.  The response should outline the major cost differences between the company’s current model and a model based on CNOC’s proposed model along with changes in costing assumptions, with rationale;

b. If the company was to offer its residential wholesale high-speed access service based on CNOC's proposed model,

i. describe how and where in the network the company would measure, for billing purposes, the monthly peak traffic caused by the end-users of each wholesale customer.  The response should indicate where measurements would take place and what additional equipment or software would be required to support the ongoing monthly measurement; further, the response should provide an estimate of the additional development costs (PWAC and MEC per end-user) the company expects to incur to implement CNOC’s model, along with supporting costing assumptions and rationale.

ii. specify how much elapsed time would be required to implement CNOC’s model.  The response should identify the additional activities that the company would have to undertake and the time required for each activity,

iii. specify whether the company uses the 95th percentile measurement approach in determination of peak traffic in any of its services or in any of its provisioning practices.  If yes, identify the services and describe the provisioning practices.  If no, describe the approach the company uses for measuring peak traffic in their networks that support high-speed access services.

3. In their intervention dated 28 March 2011, the Bell companies provided in confidence, an estimate of the projected 2011 investments required to reduce congestion to acceptable levels (i.e. network capacity relief) in their network supporting high-speed access, the revenues generated in 2010 from their residential GAS customers and an estimate of their residential GAS revenues that would be required to be spent for their proportion of congestion relief.  Provide the following information:

a) the company’s projected 2011 investments required to reduce congestion in the network supporting high-speed access.  Explain how the company determined its estimate of this projected investment.  The response should identify the network components included and the methodology and assumptions used, with supporting rationale;

b) the revenues generated in 2010 for the company’s wholesale aggregated ADSL access service

c) the estimated proportion of revenues in response to b) that would be spent for congestion relief

4. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided Chart B3 entitled “Internet Usage by Time of Day – North America 2010”.  The chart provided i) the level of traffic per end-user as a percentage of the maximum level of traffic per end-user by time of day  and ii) the number of end-users that are connected as a percentage of the maximum number of end-users that are connected by time of day.

Indicate whether this chart is representative of the daily Internet usage of the company’s end-users.  If not, provide an equivalent chart for the Internet usage by time of day for the company’s end-users.  The response should specify whether the provided information is for retail end-users only or for both retail and wholesale end-users combined.

5. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network congestion of the ISP operators’ networks.  In this proceeding, parties have also commented on the need to demonstrate the existence of congestion within the networks.  As such, questions a), b), and c) below are substantially the same as those posed in PN 2008-19.

a) How does the company define congestion in the networks it uses to provide broadband Internet services?  What criteria and measurements are used to determine that there is congestion in the company’s networks?

b) Have the company’s congestion criteria changed between 2008 and 2011?  If so, explain how they have changed.

c) Describe which components (e.g. network elements or links) of the company’s networks, used to provide broadband Internet services, are provisioned based on Internet traffic volumes.  The discussion should include a general description of the architecture of the company’s networks.

d) If congestion is currently present in the company’s network, provide quantitative evidence of such congestion.  Using the components identified in the response to part c) above, specify when this congestion occurs, how many components by type are affected, what proportion of the total components by type are affected, as well as how often congestion is being experienced (i.e. what % of the time elements are experiencing congestion).

6. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network provisioning of the ISP operator’s networks.  As such, questions a) and b) and c) below explore the same subject matter

a) For each component identified above in question 5 c), describe the practices that the company employs to provision its networks.  The answer should include a description of the conditions under which the company would augment its network capacities to address congestion.  Describe in detail the process used to identify when and where additional network capacity is required and how the additional capacity requirements are determined.

b) For each component identified in question 5 c), specify the amount of time required to increase capacity of the component in the company’s network, taking into account the time that elapses between identification of a need to add capacity for the component and the subsequent ordering, provisioning, installation, testing and activation of the additional capacity.

c) Describe any major changes to the company’s provisioning practices for the years 2008 to 2011.  The response should include details on any changes in provisioning assumptions.

d) With respect to other company services being offered using a common network (e.g. managed services such as IPTV services over xDSL networks),

i. describe the differences between the company’s managed services and Internet services that have led the company to separate them.  Clearly define the parameters used to distinguish its managed services from its Internet services,

ii. explain how the company separates its managed services from its Internet services,

iii. explain how such services are planned and provisioned for in a common manner.  Explanations should include a description with diagrams identifying which elements of the networks share common capacity, as well as identifying elements of the network where capacity is provisioned in a separate manner. For elements of the networks that share capacity specify how much capacity is allocated to managed services and how much capacity is allocated to Internet services.

e) With reference to the responses provided in question 5 d) and question 6 d), explain why other services which are provisioned over the same network elements do or do not contribute to network congestion, as well as how the company determines whether to allocate additional capacity to either the Internet services or the other services sharing the capacity.

Interrogatories to TELUS Communications Company

1. In their intervention dated 28 March 2011, the Bell companies provided, in confidence, an estimate of the projected 2011 investments required to reduce congestion to acceptable levels (i.e. network capacity relief) in their networks supporting high-speed access, the revenues generated in 2010 from their residential GAS customers and an estimate of their residential GAS revenues that would be required to be spent for their proportion of congestion relief.  Provide the following information:

a) the company’s projected 2011 investment required to reduce congestion in the network supporting high-speed access.  Explain how the company determined its estimate of this projected investment.  The response should identify the network components included and the methodology and assumptions used, with supporting rationale;

b) the revenues generated in 2010 for the company’s wholesale aggregated ADSL access service;

c) the estimated proportion of revenues in response to b) that will be spent for congestion relief

2. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided Chart B3 entitled “Internet Usage by Time of Day – North America 2010”.  The chart provided i) the level of traffic per end-user as a percentage of the maximum level of traffic per end-user by time of day and ii) the number of end-users that are connected as a percentage of the maximum number of end-users that are connected by time of day.

Indicate whether this chart is representative of the daily Internet usage of the company’s end-users.  If not, provide an equivalent chart for the Internet usage by time of day for the company’s end-users.  The response should specify whether the provided information is for retail end-users only or for both retail and wholesale end-users combined.

3. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network congestion of the ISP operators’ networks.  In this proceeding, parties have also commented on the need to demonstrate the existence of congestion within the networks. As such, Questions a), b), and c) below are substantially the same as those posed in PN 2008-19.

a) How does the company define congestion in the networks it uses to provide broadband Internet services?  What criteria and measurements are used to determine that there is congestion in the company’s networks?

b) Have the company’s congestion criteria changed between 2008 and 2011? If so, explain how they have changed.

c) Describe which components (e.g. network elements or links) of the company’s networks, used to provide broadband Internet services, are provisioned based on Internet traffic volumes.  The discussion should include a general description of the architecture of the company’s networks.

d) If congestion is currently present in the company’s network, provide quantitative evidence of such congestion.  Using the components identified in the response to part c) above, specify when this congestion occurs, how many components by type are affected, what proportion of the total components by type are affected, as well as how often congestion is being experienced (i.e. what % of the time elements are experiencing congestion).

4. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network provisioning of the ISP operator’s networks.  As such, questions a) and b) and c) below explore the same subject matter

a) For each component identified above in question 3 c), describe the practices that the company employs to provision its networks.  The answer should include a description of the conditions under which the company would augment its network capacities to address congestion.  Describe in detail the process used to identify when and where additional network capacity is required and how the additional capacity requirements are determined.

b) For each component identified in question 3 c), specify the amount of time required to increase capacity of the component in the company’s network, taking into account the time that elapses between identification of a need to add capacity for the component and the subsequent ordering, provisioning, installation, testing and activation of the additional capacity.

c) Describe any major changes to the company’s provisioning practices for the years 2008 to 2011.  The response should include details on any changes in provisioning assumptions.

d) With respect to other company services being offered using a common network (e.g. managed services such as IPTV services over xDSL networks),

i. describe the differences between the company’s managed services and Internet services that have led the company to separate them.  Clearly define the parameters used to distinguish its managed services from its Internet services,

ii. explain how the company separates its managed services from its Internet services,

iii. explain how such services are planned and provisioned for in a common manner.  Explanations should include a description with diagrams identifying which elements of the networks share common capacity, as well as identifying elements of the network where capacity is provisioned in a separate manner. For elements of the networks that share capacity specify how much capacity is allocated to managed services and how much capacity is allocated to Internet services.

e) With reference to the responses provided in question 3 d) and question 4 d), explain why other services which are provisioned over the same network elements do or do not contribute to network congestion, as well as how the company determines whether to allocate additional capacity to either the Internet services or the other services sharing the capacity.

Interrogatories to Cogeco Cable Inc., Quebecor Media Inc., on behalf of its affiliate Videotron Ltd., Rogers Communications Inc. (collectively the cable carriers)

Each cable carrier is to provide responses to the interrogatories

1. In their intervention dated 28 March 2011, the Bell companies provided in confidence, an estimate of the projected 2011 investments required to reduce congestion to acceptable levels (i.e. network capacity relief) in their network supporting high-speed access, the revenues generated in 2010 from their residential GAS customers and an estimate of their residential GAS revenues that would be required to be spent for their proportion of congestion relief.  Provide the following information:

a. the company’s projected 2011 investments required to reduce congestion in the network supporting the company’s TPIA service.  Explain how the company determined its estimate of this projected investment.  The response should identify the network components included and the methodology and assumptions used, with supporting rationale;

b. the revenues generated in 2010 for the company’s TPIA service;

c. the estimated proportion of revenues in response to b) that would be spent for congestion relief;

2. In their intervention dated 28 March 2011, the cable carriers proposed a model with aggregated usage-based billing on a per wholesale TPIA customer basis for their third party Internet access (TPIA) services

a. Explain in detail how the company would measure the monthly aggregated volumes for a wholesale TPIA customer under this proposal.

b. Describe to what degree measurement can be duplicated by the wholesale TPIA customer to facilitate billing reconciliation.

c. Specify how much elapsed time would be required for the company to implement the proposed model.  The response should identify the additional activities that the company would have to undertake and the time required for each activity.

d. Provide the company’s justification for its proposed rates for overage charges.

3. If the cable carriers’ proposed aggregated usage model was implemented for the TPIA service

a. Describe how the proposed aggregated usage model addresses the problem of network congestion during peak periods

b. Specify the effect of the proposed aggregated usage model on the monthly usage of end-users of the company’s TPIA service.  The response should provide five-year forecasts starting at 2011 for i) the average monthly per end-user usage by year for TPIA service under the existing rate structure ii) the average monthly per end-user usage by year under the proposed aggregated usage model.

c. explain how the proposed rates for the aggregated usage model take into account the impact of ongoing changes in end-user behaviour (e.g. increased monthly traffic volumes, increased traffic during peak periods, changes in the ratio of total traffic volume to peak traffic).  The response should address any requirements for ongoing adjustments to rates, with supporting rationale.

4. In its intervention dated 28 March 2011, CNOC proposed a pricing model where usage would be aggregated and charged on a per wholesale customer basis and submitted that wholesale customers would have to pay for any peak traffic that their users cause in the aggregate on incumbent networks. CNOC further submitted that measurement of an ISP’s monthly use of the network should be done on a 95th percentile basis.

Assuming that the company was to offer its residential TPIA service based on CNOC's proposed pricing model,

a. describe how and where in the network the company would measure, for billing purposes, the monthly peak traffic caused by the end-users of each wholesale TPIA customer;

b. specify how much elapsed time would be required to implement CNOC’s proposed model.  The response should identify the additional activities that the company would have to undertake and the time required for each activity;

c. specify whether the company uses the 95th percentile measurement approach in determination of peak traffic in any of its services or in any of its provisioning practices.  If yes, identify the services and describe the provisioning practices.  If no, describe the approach the company uses for measuring peak traffic in its networks that support high-speed access services.

5. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network congestion of the ISP operators’ networks.  In this proceeding, parties have also commented on the need to demonstrate the existence of congestion within the networks. As such, questions a), b), and c) below are substantially the same as those posed in PN 2008-19.

a. How does the company define congestion in the networks it uses to provide broadband Internet services?  What criteria and measurements are used to determine that there is congestion in the company’s networks?

b. Have the company’s congestion criteria changed between 2008 and 2011?  If so, explain how they have changed.

c. Describe which components (e.g. network elements or links) of the company’s networks, used to provide broadband Internet services, are provisioned based on Internet traffic volumes.  The discussion should include a general description of the architecture of the company’s networks.

d. If congestion is currently present in the company’s network, provide quantitative evidence of such congestion.  Using the components identified in the response to part c) above, specify when this congestion occurs, how many components by type are affected, what proportion of the total components by type are affected, as well as how often congestion is being experienced (i.e. what % of the time elements are experiencing congestion).

6. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network provisioning of the ISP operator’s networks. As such, questions a) and b) and c) below explore the same subject matter

a) For each component identified above in question 5 c), describe the practices that the company employs to provision its networks.  The answer should include a description of the conditions under which the company would augment its network capacities to address congestion.  Describe in detail the process used to identify when and where additional network capacity is required and how the additional capacity requirements are determined.

b) For each component identified in question 5 c), specify the amount of time required to increase capacity of the component in the company’s network, taking into account the time that elapses between identification of a need to add capacity for the component and the subsequent ordering, provisioning, installation, testing and activation of the additional capacity.

c) Describe any major changes to the company’s provisioning practices for the years 2008 to 2011.  The response should include details on any changes in provisioning assumptions.

d) With respect to other company services being offered using a common network (e.g. managed services and cable television services over HFC networks),

i. describe the differences between the company’s managed services and Internet services that have led the company to separate them. Clearly define the parameters used to distinguish its managed services from its Internet services,

ii. explain how the company separates its managed services from its Internet services,

iii. explain how such services are planned and provisioned for in a common manner.  Explanations should include a description with diagrams identifying which elements of the networks share common capacity, as well as identifying elements of the network where capacity is provisioned in a separate manner. For elements of the networks that share capacity specify how much capacity is allocated to managed services and how much capacity is allocated to Internet services.

e) With reference to the responses provided in question 5 d) and question 6 d), explain why other services which are provisioned over the same network elements do or do not contribute to network congestion, as well as how the company determines whether to allocate additional capacity to either the Internet services or the other services sharing the capacity.

Interrogatories to Shaw Communications Inc.

1. In its intervention dated 28 March 2011, the Bell companies provided in confidence, an estimate of the projected 2011 investments required to reduce congestion to acceptable levels (i.e. network capacity relief) in their network supporting high-speed access, the revenues generated in 2010 from their residential GAS customers and an estimate of their residential GAS revenues that would be required to be spent for their proportion of congestion relief.  Provide the following information:

a. the company’s projected 2011 investments required to reduce congestion in the network supporting the company’s TPIA service.  Explain how the company determined its estimate of this projected investment.  The response should identify the network components included and the methodology and assumptions used, with supporting rationale;

b. the revenues generated in 2010 for the company’s TPIA service;

c. the estimated proportion of revenues in response to b) that would be spent for congestion relief

7. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided Chart B3 entitled “Internet Usage by Time of Day – North America 2010”.  The chart provided i) the level of traffic per end-user as a percentage of the maximum level of traffic per end-user by time of day  and ii) the number of end-users that are connected as a percentage of the maximum number of end-users that are connected by time of day.

Indicate whether this chart is representative of the daily Internet usage of the company’s end-users.  If not, provide an equivalent chart for the Internet usage by time of day for the company’s end-users.  The response should specify whether the provided information is for retail end-users only or for both retail and wholesale end-users combined.

2. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network congestion of the ISP operators’ networks.  In this proceeding, parties have also commented on the need to demonstrate the existence of congestion within the networks. As such, questions a), b), and c) below are substantially the same as those posed in PN 2008-19.

a) How does the company define congestion in the networks it uses to provide broadband Internet services?  What criteria and measurements are used to determine that there is congestion in the company’s networks?

b) Have the company’s congestion criteria changed between 2008 and 2011?  If so, explain how they have changed.

c) Describe which components (e.g. network elements or links) of the company’s networks, used to provide broadband Internet services, are provisioned based on Internet traffic volumes.  The discussion should include a general description of the architecture of the company’s networks.

d) If congestion is currently present in the company’s network, provide quantitative evidence of such congestion.  Using the components identified in the response to part c) above, specify when this congestion occurs, how many components by type are affected, what proportion of the total components by type are affected, as well as how often congestion is being experienced (i.e. what % of the time elements are experiencing congestion).

3. In Public Notice 2008-19 - Review of the Internet traffic management practices of Internet service providers, the Commission posed a series of questions related to network provisioning of the ISP operator’s networks.  As such, questions a) and b) and c) below explore the same subject matter.

a) For each component identified above in question 2 c), describe the practices that the company employs to provision its networks.  The answer should include a description of the conditions under which the company would augment its network capacities to address congestion.  Describe in detail the process used to identify when and where additional network capacity is required and how the additional capacity requirements are determined.

b) For each component identified in question 2 c), specify the amount of time required to increase capacity of the component in the company’s network, taking into account the time that elapses between identification of a need to add capacity for the component and the subsequent ordering, provisioning, installation, testing and activation of the additional capacity.

c) Describe any major changes to the company’s provisioning practices for the years 2008 to 2011.  The response should include details on any changes in provisioning assumptions.

d) With respect to other company services being offered using a common network (e.g Cable television services over HFC networks),

i. describe the differences between the company’s managed services and Internet services that have led the company to separate them. Clearly define the parameters used to distinguish its managed services from its Internet services,

ii. explain how the company separates its managed services from its Internet services,

iii. explain how such services are planned and provisioned for in a common manner.  Explanations should include a description with diagrams identifying which elements of the networks share common capacity, as well as identifying elements of the network where capacity is provisioned in a separate manner. For elements of the networks that share capacity specify how much capacity is allocated to managed services and how much capacity is allocated to Internet services.

e) With reference to the responses provided in question 2 d) and question 3 d), explain why other services which are provisioned over the same network elements do or do not contribute to network congestion, as well as how the company determines whether to allocate additional capacity to either the Internet services or the other services sharing the capacity.

Interrogatories to the Canadian Network Operators Consortium (CNOC)

1. Refer to CNOC’s intervention dated 28 March 2011, regarding its proposed restructured pricing model for aggregated ADSL access and third party Internet access (TPIA) services.  Provide details on how a service provider that is a member of CNOC would measure, for billing purposes, the total monthly peak traffic that its users cause i) on an ILEC’s network, ii) on a cable carrier’s network.  The response should indicate where the measurement takes place and what additional equipment or software would be required to support the ongoing monthly measurement.  

2. If  CNOC’s proposed restructured pricing model was implemented for aggregated ADSL access and TPIA services,

a. describe how CNOC’s proposed model will address the problem of network congestion during peak periods;

b. specify the effect of CNOC’s proposed model on end-user usage.  The response should provide five year forecasts starting at 2011 for i) average monthly per end-user usage for services provided by CNOC’s members using the current pricing models for aggregated ADSL access services and TPIA services ii) average monthly per end-user usage under CNOC’s proposed model;

c. explain how CNOC’s proposed model takes into account the impact of ongoing changes in end-user behaviour (e.g. increased monthly traffic volumes, increased traffic during peak periods, changes in the ratio of total traffic volume to peak traffic). The response should address any requirements for ongoing adjustments to rates, with supporting rationale.

3. Refer to the Bell companies’ intervention dated 28 March 2011, where they proposed the introduction of Aggregated Volume Pricing (AVP) for their residential Gateway Access service.  If the AVP proposal was implemented,

a. explain how a wholesale customer of GAS that is a member of CNOC would measure the aggregated monthly volume that its end-users cause on the Bell companies’ network,

b. explain how a wholesale customer of GAS that is a member of CNOC would determine its monthly traffic volume requirement that it would pre-purchase from the Bell companies,

c. describe to what degree the measurement of the aggregated monthly volume can be duplicated by the Bell companies to facilitate billing reconciliation.

4. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided Chart B3 entitled “Internet Usage by Time of Day – North America 2010”.  The chart provided i) the level of traffic per end-user as a percentage of the maximum level of traffic per end-user by time of day  and ii) the number of end-users that are connected as a percentage of the maximum number of end-users that are connected by time of day.

Indicate whether this chart is representative of the daily Internet usage of end-users served by members of CNOC.  If it is not, provide equivalent charts for the Internet usage by time of day for end-users served by members of CNOC.

5. Refer to paragraph 39 of CNOC’s intervention dated 28 March 2011, where CNOC stated that

“Under this approach there should also be no concern that ordinary consumers served by Independent ISPs would fund the bandwidth used by the heaviest retail IS consumers”

Explain how the implementation of CNOC’s proposed model for aggregated ADSL access services and TPIA services would ensure that the above statement would be valid.

Date modified:

2011-04-29