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Ottawa, 21 November 2012

Rogers Communications Partnership – Introduction of 10 Gigabit Ethernet Interconnecting Option – Third party Internet access service

File Number: Tariff Notices 23 and 23A

1. The Commission received an application by Rogers Communications Partnership (RCP), dated 18 May 2012 and amended on 3 July 2012, in which the company proposed to introduce a 10 Gigabit Ethernet (GigE)1 interconnecting circuit option to its third party Internet access (TPIA) service. RCP indicated that under its proposal, TPIA customers, at the point of interconnection (POI),2 would have the following high-speed interconnecting options: 1 GigE, 10 GigE, or another mutually agreed on high-speed telecommunications facility.

2. RCP proposed the following two service conditions associated with the 10 GigE interconnecting circuit option: (i) the TPIA customer must place a speed order equal to or greater than 3 Gigabits per second (Gbps) on each 10 GigE interconnecting facility, and (ii) the TPIA customer must maintain a speed order of at least 3 Gbps on each 10 GigE interconnecting facility.

3. The Commission received comments from the Canadian Network Operators Consortium Inc.. The public record of this proceeding, which closed on 3 July 2012, is available on the Commission’s website at www.crtc.gc.ca under “Public Proceedings” or by using the file number provided above.

4. CNOC welcomed the new capability, but objected to the two service conditions proposed by RCP. CNOC submitted that an independent Internet service provider (ISP) should be able to manage its business and network as it sees fit, and further, the conditions would severely limit the usefulness of this interconnection option and create significant uncertainty for the independent ISP.

5. CNOC noted that in Telecom Regulatory Policy 2011-703, the Commission made independent ISPs responsible for planning and managing the network capacity they need in 100 Megabits per second increments. CNOC submitted that the service conditions associated with the 10 GigE interconnecting circuit option diminish its responsibility and that it is not appropriate, or consistent with Telecom Regulatory Policy 2011-703, for independent ISPs to be forced to guarantee that they will order a minimum amount of capacity in order to obtain the 10 GigE interconnecting circuit option. CNOC also submitted that since there are no restrictions when ordering a 1 GigE interconnecting circuit, it follows that there should be no restrictions for the 10 GigE interconnecting circuit.

6. With regard to CNOC’s argument that there should be no restrictions for the 10 GigE interconnecting circuit option because there are no restrictions for the 1 GigE interconnecting circuit option, RCP submitted that the interfaces are not comparable in terms of the unit costs, technology, and consumption of the router’s shared common resources.

7. RCP submitted that its router that interconnects with the independent ISPs at an aggregated POI location is a shared resource, and that the number of 10 GigE ports available on that router is limited when it is configured with a mix of 1 GigE and 10 GigE ports. RCP further submitted that it would not be an efficient use of resources to allow the 10 GigE ports to be consumed by independent ISPs that do not require this level of capacitybased billing (CBB) capacity. In addition, RCP submitted that it believed that the requirement to maintain a CBB capacity order of at least 3 Gbps on each 10 GigE interconnecting circuit is the minimum level required to permit the use of the 10 GigE option.

8. With regard to CNOC’s argument that the requirement to order a minimum CBB amount on each 10 GigE interconnecting circuit option is inconsistent with Telecom Regulatory Policy 2011-703, RCP noted that Telecom Regulatory Policy 2011-703 did not address the matter of 10 GigE interfaces as an interconnection option or any specifics regarding such an option.

Commission’s analysis and determinations

9. In Telecom Regulatory Policy 2010-632, the Commission concluded that the carriers should make GigE interconnection for their TPIA service available to competitors, and that higher speed interconnections should be made available as they become industry standards and are implemented by the incumbents. The Commission therefore considers that the introduction of a 10 GigE interconnecting circuit option for TPIA customers is appropriate.

10. The Commission notes that at the aggregated POI, the number of 10 GigE circuits available on the POI router is limited and that the capacity of each 10 GigE circuit provided to an ISP would be entirely dedicated to that ISP. The Commission considers that a reasonable balance between an ISP’s need to manage its network and an efficient use of router capacity must be struck. In the circumstances, the Commission considers it appropriate to make the provision of the 10 GigE interconnecting circuit option conditional on a minimum amount of provisioned traffic.

11. In light of the above, the Commission approves on a final basis RCP’s application to introduce the 10 GigE interconnecting circuit option subject to the following modifications:

Secretary General

Related documents



Footnotes:

[1] GigE is a standard that supports transmission of Ethernet protocol frames at a rate of one gigabit per second.

[2] A POI is a location at which an independent Internet service provider (ISP)connects its network to a cable carrier’s network in order to gain access to its own retail customers through high-speed access paths on the cable carrier’s network. A  POI allows an ISP to support retail customers within an authorized serving area.

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