ARCHIVED - Letter

Ottawa, 6 October 2011

Our references: 8663-B7-200905052
8620-B7-200905599
8663-H3-200917503
8663-M5-200907199
8663-T7-200909640
8663-W36-200910225

BY E-MAIL

To:  Distribution List

RE:  Small incumbent local exchange carriers’ competition and wireless number portability implementation plans

Dear Sir or Madam:

The Commission received local competition implementation plans from Bruce Telecom, Hay Communications Co-operative Limited (Hay), Mornington Communications Co-operative Limited (Mornington), Tuckersmith Communications Co-operative Ltd. (Tuckersmith), and Wightman Telecom Ltd. (Wightman) [collectively, the small incumbent local exchange carriers, or small ILECs], dated between 20 and 25 July 2011, in response to requests by Bragg Communications Inc., carrying on business as EastLink (EastLink).  

The Commission also received a wireless number portability (WNP) implementation plan from Bruce Telecom, dated 22 July, in response to a request by Rogers Communications, on behalf of Rogers Wireless operating as a wireless service provider (Rogers).

Section 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information, particulars or documents where needed.

The small ILECs are requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 12 October 2011. 

EastLink, Rogers, and any interested person may file comments on the additional information filed in response to the interrogatories, serving those comments on the small ILEC, by 18 October 2011.  The small ILEC may file a reply by 20 October 2011.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277.

Yours sincerely, 

‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manager, Tariffs
Telecommunications

Attach.

cc:  Nathalie MacDonald, EastLink, regulatory.matters@corp.eastlink.ca
Simon-Pierre Olivier, Rogers, rwi_gr@rci.rogers.com
Laurie Ventura, CRTC, 819-997-4589, laurie.ventura@crtc.gc.ca
Martin Brazeau, CRTC, 819-997-3498, martin.brazeau@crtc.gc.ca
Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca

Distibution List
Faye Hughes, regulatory@brucetelecom.com
Angela M. Schneider, a.schneider@hay.net
Richard Banks, rbanks@mornington.ca
Robert Van Aaken, robtcc@tcc.on.ca
Tom Sullivan, tsullivan@wightman.ca

Request for information – Implementation plans for local competition

1.  Small incumbent local exchange carriers (ILECs) that are registered as competitive local exchange carriers (CLECs) are required to provide local number portability. Commission staff notes that Bruce Telecom, Hay, Mornington, Tuckersmith, and Wightman are already registered as CLECs.

1.1  Given this, explain why these companies are claiming start-up and ongoing costs (such as subscription to Neustar) for LNP.

1.2  Where the above-named companies already have the necessary equipment for LNP, list the extra expenses by major item (such as in the submitted studies) that are necessary beyond what is in place today.

2.  All large incumbent local exchange carriers (ILECs) transferred the responsibility for inside wiring to the customers at the beginning of local competition in their serving areas. However, in their local competition implementation plans and related submissions,

• some small ILECs did not address inside wire repair and maintenance issues,
• others proposed that the CLEC take responsibility of the small ILEC’s inside wire when it begins to provide local services to the end-customer; and
• others proposed to transfer responsibility to the end-customer.

2.1  Assume that the small ILEC were to maintain responsibility for the inside wiring:

a)  describe how repair and maintenance of the inside wiring will be managed when the CLEC provides local services to the customer

b)  if this scenario requires an agreement between the small ILEC and the CLEC,

i.  provide rationale, with justification, for requiring such an agreement; and

ii.  provide the terms and conditions of the proposed agreement

2.2  Assume that the small ILEC were to transfer responsibility of the inside wiring to the CLEC that will be providing local services to the customer:

a)  describe how repair and maintenance of the inside wiring will be managed for the CLEC’s customers

b)  if this scenario requires an agreement between the small ILEC and the CLEC,

i.  provide rationale, with justification, for requiring such an agreement; and

ii.  provide the terms and conditions of the proposed agreement.

2.3  Assume that the small ILEC were to transfer the responsibility for inside wiring to the customers, describe how repair and maintenance of inside wiring will be managed when the customer is provided local services:

a)  by the small ILEC; and

b)  by the CLEC

2.4  If, in your local competition implementation plan, you have not proposed to transfer the responsibility for inside wiring to your customers, provide rationale with justification for your position.

Questions specific to Wightman Telecom Ltd

1.  In its 15 September 2011 submission, EastLink provided comments on Wightman’s 12 September 2011 proposal to install a pedestal at the meet point with a 4-wire circuit (T1). Specifically, EastLink submitted that Wightman appeared to be proposing an arrangement that cannot be considered a standard DS1 signal until a repeater circuit reconstitutes the signal to DS1 levels.  EastLink also submitted that Wightman should deliver a copper connection, based on a DS1 standard, to the meet point.

Confirm if the company’s 12 September 2011 proposal would provide EastLink with a copper connection, based on a DS1 standard, to the meet point. If not, using the format of the response to question 6 b) of the company’s 8 September 2011 submission, provide revised costs to deliver a copper connection, based on a DS1 standard, to the meet point.  The response should include the same level of detail reflected in its 8 September 2011 submission, including all assumptions.

2.  With reference to the ongoing costs for LNP in Wightman’s revised Attachment 1,

2.1  Describe the functionality and activities associated with each of the following:

a)  Access to the LNP database

b)  Other expenses

2.2  Provide the details of the unit costs, drivers, and assumptions used to estimate the line item “Access to the LNP database.” Further explain, with supporting rationale, the reason for the changes in the line item “Access to the LNP database” between the company’s 25 July 2011 submission and its 8 September 2011 submission.

2.3  Explain, with supporting rationale, the reason for the changes in the line item “Membership Neustar” between the company’s 25 July 2011 submission and its 8 September 2011 submission.

2.4  Provide the details of the unit costs, drivers, and assumptions used to estimate the line item “Other expenses.”

Date modified:

2011-10-06