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Our Reference: 8740-T66-201209099
Mr. John Maksimow
Tariffs Manager, Regulatory Affairs
333 Main Street,
Winnipeg, Manitoba R3C 3V6
Re: Tariff Notices # 438 / 644 / 4357 from TELUS Communications Company
The Commission received applications from TELUS Communications Company (TELUS). These applications relate to changes to Carrier Access Tariffs for which TELUS is proposing to add a 2.5 Gbps interconnecting carrier to interconnecting carrier (IC-to-IC) cross-interconnection link. To further assist the Commission in its consideration of the above-noted tariff notices, MTS Allstream Inc. is requested to provide response to the enclosed interrogatory provided in the attachment by 26 October 2012.
Copies of the documents should also be sent to firstname.lastname@example.org and email@example.com.
Original signed by
Director, Costing and Competitive Services
1. Refer to MTS Allstream’s comments dated 27 August 2012 in response to TELUS’ Tariff Notices 438, 644 and 4357 to introduce an interconnecting carrier –to – interconnecting carrier (IC-to-IC) link with a capacity of 2.5 Gbps. In its comments MTS Allstream stated that the only reason to limit the capacity of the IC-to-IC link is to interfere with the operation of market forces, since limiting the capacity gives the TELUS an undue advantage for the provision of transport services to co-located companies.
Also refer to TELUS’ reply comments dated 6 September 2012, where TELUS stated that limiting the capacity is necessary for an enforceable and effective co-location rule. If the capacity of the IC-to-IC link is unlimited, as MTS Allstream proposes, then interconnecting carriers will not be able to demonstrate compliance as the Commission directed, nor will TELUS be able to verify the capacity of the IC-to-IC link.
Under MTS Allstream’s proposal, explain with supporting rationale how a co-located company can assure the ILEC that it is in compliance with the co-location rules.
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