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Ottawa, 30 June 2011

Our file:  8643-C12-201105297

BY E-MAIL

To Distribution List

Re: Proceeding to review network interconnection matters: Requests for information

Pursuant to the procedures set out in the proceeding to review network interconnection matters, attached are requests for information associated with this proceeding.

Responses to these requests for information are to be filed with the Commission, and served on all parties to this proceeding, by 12 August 2011.  Responses are to be received, and not merely sent, by this date.

Yours sincerely,

Original signed by

John Macri
Director, Telecommunications Policy

Attachments

Regulatory@sjrb.ca;  david.watt@rci.rogers.com;  regulatory.affairs@telus.com;  sdesy@actq.qc.ca;  bell.regulatory@bell.ca ;  cedwards@ccsa.cable.ca;  iworkstation@mtsallstream.com;  jonathan.holmes@ota.on.ca;  regaffairs@quebecor.com;  document.control@sasktel.sk.ca;  regulatory@globility.ca;  lisagoetz@globalive.com;  regulatory@ssimicro.com;  reglementa@telebec.com;  telecom.regulatory@cogeco.com;  regulatory@cnoc.ca;  piac@piac.ca;  Jamie.greenberg@publicmobile.ca;  regulatory@distributel.ca;  Regulatory.Matters@corp.eastlink.ca;  regulatory@fibernetics.ca;  awood@windmobile.ca;  gary.wong@mobilicity.ca;  regulatory@bellaliant.ca; 

Attachment 1 Request for information from Bell Aliant Regional Communications, Limited Partnership; Bell Canada and Télébec, Société en commandite (the Bell companies)

Attachment 2 Request for information from MTS Allstream Inc. (MTS Allstream)

Attachment 3 Request for information from Saskatchewan Telecommunications (SaskTel)

Attachment 4 Request for information from TELUS Communications Company (TCC)

Attachment 5 Request for information from Bragg Communications Inc., carrying on business as EastLink (EastLink)

Attachment 6 Request for information from Cogeco Cable Inc. (Cogeco)

Attachment 7  Request for information from Quebecor Media Inc. (QMI), on behalf of Videotron G.P. (Videotron)

Attachment 8 Request for information from Rogers Communications Partnership (Rogers)

Attachment 9 Request for information from Shaw Communications Inc. (Shaw)

Attachment 10  Request for information from Distributel Communications Limited (Distributel)

Attachment 11  Request for information from Fibernetics Corporation (Fibernetics)

Attachment 12  Request for information from Globility Communications Corporation (Globility)

Attachment 13 Request for information from Yak Communications (Canada) Corp. (Yak)

Attachment 14 Request for information from Data & Audio-Visual Enterprises Wireless Inc., carrying on business as Mobilicity (Mobilicity) and Globalive Wireless Management Corp., carrying on business as WIND Mobile (WIND Mobile)

Attachment 15 Request for information from Public Mobile Inc. (Public Mobile)

Attachment 16 Request for information from the Canadian Independent Telephone Company Joint Task Force (the JTF)

Attachment 17 Request for information from the Canadian Network Operators Consortium Inc. (CNOC)

 

Request for information from the Bell companies

1. Provide the following information by company with respect to wireless interconnection services offered by your companies:

a) total wireless interconnection services revenues, by company for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, by company for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide an estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over each of the companies’ networks using Internet Protocol (IP) technology.

5. Do any of the companies currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, the names of the companies and the other carriers with which they connect.  Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

7. Describe the steps that would be involved in rolling-out an IP-IP interconnection service for the exchange of voice traffic.  Provide estimated timeframes associated with each step.

8. At paragraph 20 of its 2 June 2011 intervention, Fibernetics proposed that the ILEC connect at the digital signal (DS)-3 or higher level, where trunking quantities justify.  At paragraph 18 of its 2 June 2011 intervention, Yak stated that it is unnecessary to charge to de-multiplex traffic into DS-1s since local tandem and toll access tandem switches used for interconnection are fully capable of interfacing with CLECs and IXCs at the DS-3 level.

a) Identify whether any of your companies’ switches used for interconnection services support interface speeds of DS-3 or higher.  If yes, for each company specify the percentage of these switches that are equipped with interfaces that support DS-3 or higher speeds, by available speed.

b) If in your response to part a) some or all of your switches support DS-3 or higher speeds, provide your view with respect to providing interconnection services at DS-3 or higher speeds, with supporting rationale. Discuss and quantify, with supporting rationale, the impact on each company and its network interconnection services (for example with respect to operations, costs and revenues).

Request for information from MTS Allstream

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, provide your view, with supporting rationale, on whether the wireless carriers should be required to provide equal access.  Should any of the other CLEC obligations be mandated?  In your response, include a discussion as to how your view would be consistent with the Policy Direction, as well as any benefits or harm to consumers.

5. Indicate, with supporting rationale, whether any technical and/or financial barriers exist for wireless carriers to support equal access.  Your response should include, as applicable, economic, financial, technical and/or costing evidence to support your views. 

6. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

7. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

8. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

9. Describe the steps that would be involved in rolling-out an IP-IP interconnection service for the exchange of voice traffic.  Provide estimated timeframes associated with each step.

10. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

11. At paragraph 20 of its 2 June 2011 intervention, Fibernetics proposed that the ILEC connect at the digital signal (DS)-3 or higher level, where trunking quantities justify.  At paragraph 18 of its 2 June 2011 intervention, Yak stated that it is unnecessary to charge to de-multiplex traffic into DS-1s since local tandem and toll access tandem switches used for interconnection are fully capable of interfacing with CLECs and IXCs at the DS-3 level.


a) Identify whether any of your switches used for interconnection services support interface speeds of DS-3 or higher.  If yes, specify the percentage of these switches that are equipped with interfaces that support DS-3 or higher speeds, by available speed.

b) If in your response to part a) some or all of your switches support DS-3 or higher speeds, provide your view with respect to providing interconnection services at DS-3 or higher speeds, with supporting rationale. Discuss and quantify, with supporting rationale, the impact on your company and its network interconnection services (for example with respect to operations, costs and revenues).

Request for information from SaskTel

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

7. Describe the steps that would be involved in rolling-out an IP-IP interconnection service for the exchange of voice traffic.  Provide estimated timeframes associated with each step.

8. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

9. At paragraph 20 of its 2 June 2011 intervention, Fibernetics proposed that the ILEC connect at the digital signal (DS)-3 or higher level, where trunking quantities justify.  At paragraph 18 of its 2 June 2011 intervention, Yak stated that it is unnecessary to charge to de-multiplex traffic into DS-1s since local tandem and toll access tandem switches used for interconnection are fully capable of interfacing with CLECs and IXCs at the DS-3 level.

a) Identify whether any of your switches used for interconnection services support interface speeds of DS-3 or higher.  If yes, specify the percentage of these switches that are equipped with interfaces that support DS-3 or higher speeds, by available speed.

b) If in your response to part a) some or all of your switches support DS-3 or higher speeds, provide your view with respect to providing interconnection services at DS-3 or higher speeds, with supporting rationale. Discuss and quantify, with supporting rationale, the impact on your company and its network interconnection services (for example with respect to operations, costs and revenues).

Request for information from TCC

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. Describe the steps that would be involved in rolling-out an IP-IP interconnection service for the exchange of voice traffic.  Provide estimated timeframes associated with each step.

8. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

9. At paragraph 38 of the company’s 2 June 2011 intervention, TCC stated that it was unsure whether any standard timeframes could be applied in a meaningful way to the process of peer interconnection, given the variation in the work involved in different projects.  For both circuit-switched and IP-based arrangements:

a) Identify and describe the steps required to complete the process of implementing network interconnection.

b) For each of the steps in a), identify the length of time that would typically be experienced.

10. At paragraph 20 of its 2 June 2011 intervention, Fibernetics proposed that the ILEC connect at the digital signal (DS)-3 or higher level, where trunking quantities justify.  At paragraph 18 of its 2 June 2011 intervention, Yak stated that it is unnecessary to charge to de-multiplex traffic into DS-1s since local tandem and toll access tandem switches used for interconnection are fully capable of interfacing with CLECs and IXCs at the DS-3 level.

a) Identify whether any of your switches used for interconnection services support interface speeds of DS-3 or higher.  If yes, specify the percentage of these switches that are equipped with interfaces that support DS-3 or higher speeds, by available speed.

b) If in your response to part a) some or all of your switches support DS-3 or higher speeds, provide your view with respect to providing interconnection services at DS-3 or higher speeds, with supporting rationale. Discuss and quantify, with supporting rationale, the impact on your company and its network interconnection services (for example with respect to operations, costs and revenues).

Request for information from EastLink

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

8. In the company’s 2 June 2011 intervention, EastLink stated that IP-based trunks are less than half the per trunk cost of even the most efficient TDM-based trunks.  Provide economic, financial and/or costing evidence to support this statement.

Request for information from Cogeco

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

Request for information from QMI

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

8. At paragraph 32, of the company’s 2 June 2011 intervention, QMI proposed that the Commission modify the current compensation mechanism in case of traffic imbalance between two local exchange carriers (LECs) so that the compensation to be paid reflects the incremental cost associated with the portion of traffic that causes the imbalance, and not the overall quantity of traffic exchanged.  Provide an illustrative example to clearly explain both the current situation and how the company’s proposal would differ.  The example should, at a minimum, identify differences in inputs and revenue impacts.

Request for information from Rogers

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

b) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

c) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

8. At paragraph 20 of the company’s 2 June 2011 intervention, Rogers proposed that the Commission permit CLECs to route local and toll traffic destined to small ILECs over local transit trunks.  Indicate, with supporting rationale, why one ILEC should be mandated to make a local transit service available to CLECs as an alternative to direct interconnection with a second ILEC outside of the first ILEC’s operating territory.  In your response include, as applicable, economic, financial and/or costing evidence to support your position.

Request for information from Shaw

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, provide your view, with supporting rationale, on whether the wireless carriers should be required to provide equal access.  Should any of the other CLEC obligations be mandated?  In your response, include a discussion as to how your view would be consistent with the Policy Direction, as well as any benefits or harm to consumers.

5. Indicate, with supporting rationale, whether any technical and/or financial barriers exist for wireless carriers to support equal access.  Your response should include, as applicable, economic, financial, technical and/or costing evidence to support your views. 

6. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

7. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

8. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c)Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d)Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

9. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

Request for information from Distributel

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

8. At paragraph 14 of the company’s 2 June 2011 intervention, Distributel stated that a 60-day window from the date the CLEC trunk forecast is accepted would be an appropriate time frame for interconnection.

a) Provide supporting rationale as to why 60 days would be reasonable.

b) Should there be any intermediate milestones?  If so, what should they be?

Request for information from Fibernetics

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

8. At paragraph 36 of the company’s 2 June 2011 intervention, Fibernetics stated that 90 days from the acceptance of a forecast was appropriate as the interval for a typical network interconnection barring extraordinary events.

a) Provide supporting rationale as to why 90 days would be reasonable.

b) Should there be any intermediate milestones?  If so, what should they be?

c) Provide examples of what would be considered an extraordinary event.

9. At paragraph 23 of the company’s 2 June 2011 intervention, Fibernetics stated that had asked an ILEC to allow the provisioning of IXC trunking over facilities built for local network interconnection.  Fibernetics also stated that it had offered to pay tariffed rates similar to how it might compensate the ILEC for ‘optional’ services such as 9-1-1, Local Transit, etc., so as to negate the need to have to order separate facilities for these trunks.  Specify the tariff(s) Fibernetics proposes be used to compensate the ILEC, with supporting rationale.

Request for information from Globility

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established. d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

Request for information from Yak

1. Provide the following information with respect to wireless interconnection services offered by your company:

a) total wireless interconnection services revenues for each of the years 2005 to 2009; and 

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for incumbent local exchange carrier (ILEC)-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

5. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.


Request for information from Mobilicity and WIND Mobile

1. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, provide your view, with supporting rationale, on whether the wireless carriers should be required to provide equal access.  Should any of the other CLEC obligations be mandated?  In your response, include a discussion as to how your view would be consistent with the Policy Direction, as well as any benefits or harm to consumers.

2. Indicate, with supporting rationale, whether any technical and/or financial barriers exist for your companies to support equal access.  Your response should include, as applicable, economic, financial, technical and/or costing evidence to support your views. 

3. Provide your best estimates of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your companies’ networks using Internet Protocol (IP) technology.

4. Do your companies currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

5. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

6. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.


Request for information from Public Mobile

1. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, provide your view, with supporting rationale, on whether the wireless carriers should be required to provide equal access.  Should any of the other CLEC obligations be mandated?  In your response, include a discussion as to how your view would be consistent with the Policy Direction, as well as any benefits or harm to consumers.

2. Indicate, with supporting rationale, whether any technical and/or financial barriers exist for your company to support equal access.  Your response should include, as applicable, economic, financial, technical and/or costing evidence to support your views. 

3. Provide the company’s best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over your company’s network using Internet Protocol (IP) technology.

4. Does your company currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of these carriers. Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

5. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

6. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.


Request for information from the JTF

1. Provide the following information by company with respect to wireless interconnection services offered by the small incumbent local exchange carriers (small ILECs):

a) total wireless interconnection services revenues, by small ILEC for each of the years 2005 to 2009; and

b) total wireless interconnection services revenues broken down by the wireless carrier subscribing to these services, listing the names of all such carriers, by small ILEC for the year 2010.

2. If the Commission were to establish a shared-cost interconnection regime for ILEC-to-wireless carrier interconnection, explain, with supporting rationale, whether such a regime should apply to competitive local exchange carrier (CLEC)-to-wireless carrier interconnection as well.

3. If the Commission were to establish a shared-cost interconnection regime for non-CLEC wireless carriers, indicate whether there would be any costs (for example stranded investments, implementation costs, etc.) that would result from establishing such a regime.  Your response should include, as applicable, economic, financial and/or costing evidence.  Describe the steps that would be involved in implementing such a regime.  Provide estimated timeframes associated with each step.

4. For each small ILEC, provide the best estimate of the percentage of total retail voice traffic (including local, toll and wireless) that is currently being transported and/or provisioned over their respective networks using Internet Protocol (IP) technology.

5. Do any of the small ILECs currently interconnect with any other carriers’ networks on an IP-to-IP basis for the purpose of exchanging voice traffic?  If so, provide the names of the small ILECs and the other carriers with which they connect.  Indicate what compensation mechanism is used to exchange this traffic (i.e. whether it is bill and keep or another arrangement) and whether costs are shared for interconnection facilities.

6. In its 2 June 2011 intervention, Rogers proposed that the Commission establish basic default rules for voice IP-to-IP interconnection. The proposal, summarized in paragraph 2 of Rogers’ intervention, is as follows:

a) Provide your views on Rogers’ proposed default rules and include any proposed modifications as appropriate, with supporting rationale.

b) Indicate, with supporting rationale, whether an IP interconnection framework, as proposed by Rogers, should also apply to LEC-to-wireless carrier interconnection and LEC-to-interexchange carrier (IXC) interconnection.

c) Indicate, with supporting rationale, whether it would be appropriate to allow carriers to negotiate separate arrangements (for example with respect to compensation, cost sharing or geographic coverage) apart from any basic rules or principles that might be established.

d) Comment on the costs and benefits that would result from establishing an IP-based interconnection framework such as the one proposed by Rogers.  In your response include, as applicable, economic, financial and/or costing evidence for the following:

i. costs and/or benefits associated with changes to network configuration (for example in terms of the number of points of interconnection (POIs) that would be required under IP interconnection versus the number of POIs that are currently needed);

ii. costs and/or benefits associated with changes to network efficiency (for example in terms of an increase or decrease in trunking costs);

iii. costs and/or benefits associated with the conversion of IP-based voice traffic to circuit-switched voice traffic, or vice versa (for example in terms of equipment requirements); and

iv. any other relevant costs or benefits.

7. Describe the steps that would be involved in rolling-out an IP-IP interconnection service for the exchange of voice traffic.  Provide estimated timeframes associated with each step.

8. At paragraph 23 of their 2 June 2011 intervention, the Bell companies stated that ILECs should cease being the default interconnection provider with the obligation to provide extended area service (EAS) and transit services, if IP-based interconnection was to be mandated.  If the Commission were to establish an IP-based interconnection regime, would there be a continued need for the ILECs to provide EAS and transit services?  If not, explain why not.

9. At paragraph 7 of your 2 June 2011 intervention, under proposed principle #2, the JTF stated that, at a minimum, all telecommunications service providers (TSPs) should be required to interconnect in a small ILEC’s operating territory if they wish to originate or terminate telecommunications traffic in that small ILEC’s territory.  Indicate, with supporting rationale, whether the JTF’s proposed requirement that TSPs interconnect in a small ILEC’s operating territory would apply to a TSP that is simply delivering traffic for termination to the small ILEC.

10. At paragraph 7 of the your 2 June 2011 intervention, under proposed principle #2, the JTF also stated that as an alternative TSPs could transit traffic to a small ILEC through another carrier that had a recognized service-specific interconnection arrangement in place with the small ILEC.

a) Confirm whether it is the JTF’s view that both the TSP and small ILEC must be in agreement to make use of any available transit arrangements, or whether one party should be able to dictate the use of any such arrangements.

b) Indicate, with supporting rationale, what would constitute a recognized service-specific interconnection arrangement that a TSP could use as an alternative to direct network interconnection with a small ILEC.

c) Confirm whether there are any such recognized interconnection arrangements currently available to TSPs and, if so, provide details as to where and for which small ILECs, for what services, and through which third party carrier(s).

Request for information from CNOC

1. At paragraph 10 of your 2 June 2011 intervention, CNOC proposed that the routing of toll traffic should be permitted on shared-cost facilities that are employed for local network interconnection (LNI).

a) Identify whether CNOC is proposing that the incumbent local exchange carrier (ILEC) be compensated for the use of its portion of the shared-cost facility to carry toll traffic.

b) If yes, specify the tariff(s) that CNOC proposes be used to compensate the ILEC, with supporting rationale.  If not, explain why not.


*** End of Document ***

Proceeding to review network interconnection matters, Telecom Notice of Consultation CRTC 2011-206, 23 March 2011, as amended by Telecom Notice of Consultation CRTC 2011-206-1, 3 May 2011

Date modified: