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Re: Telecom Notice of Consultation CRTC 2013-80 – Review of outstanding wholesale high-speed access service issues related to optional upstream speed rates and modem certification requirements - Interrogatories

Dear Madam/Sirs,

In Notice of Consultation 2013-80, the Commission called for comments on issues related to, among other things, optional upstream speed rates for all incumbents’ wholesale high-speed access services, and modem certification requirements for the large telephone companies’ wholesale HSA services.

In order to assist the Commission in making a determination on these issues, parties to the proceeding are requested to respond to the interrogatories included in the attachment to this letter. The attachment specifies which parties should respond to which interrogatories.
Responses to the interrogatories are to be filed with the Commission and served on all interested parties by 08 May 2013. Disclosure of information in the responses should be consistent with the guidelines established in Telecom Regulatory Policy CRTC 2012-592, Confidentiality of information used to establish wholesale service rates.
All parties may file additional written comments with the Commission solely in relation to the subject matter of the interrogatories, serving copies on all other parties by 15 May 2013.
All parties may file reply comments with the Commission solely in relation to the subject matter of the interrogatories, serving copies on all other parties, by 22 May 2013.
Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Parties may file their submissions electronically or on paper. Submissions longer than five pages should include a summary.

Electronic submissions should be in HTML format. As an alternative, those making submissions may use Microsoft Word for text and Microsoft Excel for spreadsheets.

Each paragraph of all submissions should be numbered. In addition, the line ***End of document*** should be entered following the last paragraph. This will help the Commission verify that the document has not been damaged during electronic transmission.
Yours sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications

Distribution List:

Mr. Denis E. Henry
Vice-President, Regulatory
Government Affairs and Public Law
Bell Aliant
160 Elgin Street, Floor 19
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca

Mr. Philippe Gauvin
Bell Canada
Counsel ,Regulatory Law and Policy
160 Elgin Street, Floor 19
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca

Mr. William Sandiford
Chair of the Board and President
Canadian Network Operators
Consortium Inc.
107-85 Curlew Drive
Toronto, Ontario M3A 2P8
regulatory@cnoc.ca

Mr. Yves Mayrand
Vice President
Corporate Affairs Cogeco Cable Inc.
5 Place Ville Marie, bureau 1700
Montreal, Quebec H3B 0B3
telecom.regulatory@cogeco.com

Ms. Teresa Griffin-Muir
Vice President, Regulatory Affairs
MTS Allstream
45 O’Connor Street, Suite 1400
Ottawa, Ontario K1P 1A4
iworkstation@mtsallstream.ca

Mr. Dennis Béland
Sr. Director, Regulatory Affairs, Telecom
Quebecor Media Inc.
612 St-Jacques St. 15th floor, South Tower
Montreal, Quebec H3C 4M8
regaffairs@quebecor.com

Mr. Kenneth Engelhart
Senior Vice President
Regulatory Rogers Communications
333 Bloor Street East
Toronto, Ontario M4W 1G9
ken.engelhart@rci.rogers.com

Mr. Robert Hersche
Director Regulatory Affairs
Saskatchewan Telecommunications
2121 Saskatchewan Drive
Regina, Saskatchewan S4P 3Y2
document.control@sasktel.com

Mr. Jean Brazeau
Senior Vice President
Corporate & Regulatory Affairs
Shaw Communications Inc.
40 Elgin Street, Suite 1400
Ottawa, Ontario K1P 5K6
regulatory@sjrb.ca

Mr. Ted Woodhead
Senior Vice President
Federal Government & Regulatory Affairs
TELUS Communications Company
215 Slater Street, Floor 8
Ottawa, Ontario K1P 0A6
regulatory.affairs@telus.com

c.c.: Chris Seidl, CRTC, chris.seidl@crtc.gc.ca
Lynne Fancy, CRTC, lynne.fancy@crtc.gc.ca
Renée Doiron, CRTC, renee.doiron@crtc.gc.ca
Ramin Adim, CRTC, ramin.adim@crtc.gc.ca

Interested Parties to Telecom Notice of Consultation 2013-80

michelle.dupuis@telus.com; david.watt@rci.rogers.com; bianca.sgambetterra@cogeco.com; suzanne.giroux@mtsallstream.com; beverley.wells@bell.ca; ocrosby@scs.carleton.ca; GreyBeatle111@hotmail.com; jfmezei@vaxination.ca; brian.riquelme@hotmail.com; regulatory@primustel.ca; ted.woodhead@telus.com; regulatory.aff@fidomobile.ca; ctacit@tacitlaw.com; dennis.beland@quebecor.com; piac@piac.ca; regulatory.matters@corp.eastlink.ca; regulatory@bcba.ca; resa1983@hotmail.com; regulatory.aff@fidomobile.ca; jrestrepousa@yahoo.com.

Attach. (1)

Telecom Notice of Consultation CRTC 2013-80 – Review of outstanding wholesale high-speed access service issues related to interface rates, optional upstream speed rates, and modem certification requirements - Interrogatories

The Bell companies

1. For each month of the years 2011, 2012, 2013, where data are available, provide the following information:

a. the total number of residential end-users by speed tier associated with the company’s wholesale high-speed access services;
b. the total number of wholesale residential end-users subscribing to the optional upstream speeds of 7 Mbps or 10 Mbps.

2. For each month of the years 2011, 2012, 2013, where data are available, provide the following information:

a. the total number of business end-users by speed tier associated with the company’s wholesale high-speed access services;
b. the total number of wholesale business end-users subscribing to the optional upstream speeds of 7 Mbps or 10 Mbps;
c. the total number of wholesale business end-users by speed tier associated with those ISPs who receive a 10 percent reduction on their monthly business rate access charges;
d. the total number of wholesale business end-users subscribing to the optional upstream speeds of 7 Mbps or 10 Mbps associated with those ISPs who receive a 10 percent reduction on their monthly business rate access charges.

3. For each of the years 2014 and 2015, provide the following forecasts:

a. the total number of residential end-users by speed tier associated with the company’s wholesale high-speed access services;
b. the total number of wholesale residential end-users subscribing to the optional upstream speeds of 7 Mbps or 10 Mbps.
c. the total number of business end-users by speed tier associated with the company’s wholesale high-speed access services;
d. the total number of wholesale business end-users subscribing to the optional upstream speeds of 7 Mbps or 10 Mbps.

4. Complete the following table with regard to the Sagemcom 2864 VDSL modem:

Current supplier price in Canadian dollars CDN/US exchange rate if applicable Supplier discount % Sales Tax % Warehouse & Distribution Factor % Cost including tax and Warehousing and Distribution
A B C D E = A*(1-B)*(1+C)*(1+D)

5. Refer to the Bell companies’ comments regarding Telecom Notice of Consultation 2013-80 dated 27 March 2013. In paragraph 9 it was submitted that modem interoperability on the Companies’ network is limited because Alcatel Lucent Stinger digital subscriber line access multiplexer (DSLAM) equipment in the Companies’ network. Provide the following information pertaining to DSLAMs in the Bell companies’ network:

a. the current total number of VDSL2-capable DSLAMs that are Alcatel Lucent Stingers in the Bell companies’ network;
b. the current total number of VDSL2-capable DSLAMs that are not Alcatel Lucent Stingers in the Bell companies’ network;
c. the average remaining life expectancy of the Alcatel Lucent Stinger DSLAMs identified in a.

6. Refer to the Bell companies’ reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 5 it was submitted that independent service providers have the option to buy modems directly from the same modem manufacturer with rates and features they will have mutually agreed upon. Are any independent service providers currently sourcing VDSL2 modems directly from the manufacturer for use on the Bell companies’ network? If so, identify the independent service provider(s).

7. Refer to the Bell companies’ reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 14 it was submitted that if the independent service providers supply their own modems, the Companies will not be updating the firmware for those modems. Indicate whether the Bell companies would need to test and certify firmware supplied by independent service providers in the case where an independent service provider self-supplies modems for use on the Bell companies’ network.

Saskatchewan Telecommunications (SaskTel)

1. Refer to SaskTel’s comments regarding Telecom Notice of Consultation 2013-80 dated 25 March 2013. In paragraph 5 it was submitted that only one modem currently works with SaskTel’s VDSL network in all configurations. Identify the make and model of this modem and complete the following table with regard to this modem:

Current supplier price in Canadian dollars CDN/US exchange rate if applicable Supplier discount % Sales Tax % Warehouse & Distribution Factor % Cost including tax and Warehousing and Distribution
A B C D E = A*(1-B)*(1+C)*(1+D)

2. Refer to SaskTel’s reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 5 it was submitted that SaskTel’s network was largely deployed at a time before VDSL2 standards had stabilized. Provide the following information pertaining to SaskTel’s network:

a. identify the different makes and models of VDSL2-capable DSLAMs used in SaskTel’s network;
b. identify which type of VDSL2-capable DSLAM is currently known to have compatibility issues with off-the-shelf VDSL2 modems;
c. the current total number of VDSL2-capable DSLAMs in SaskTel’s network;
d. the current total number of VDSL2-capable DSLAMs identified in b.;
e. the average remaining life expectancy of the VDSL2-capable DSLAMs identified in b.

Canadian Network Operators Consortium (CNOC)

1. Refer to CNOC’s reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 30 it was submitted that the Sagemcom 2864 modem is sole-sourced from the Bell companies at a higher price than other modems on the market. Identify three VDSL2 modems that compare functionally to the Sagemcom 2864 and provide the estimated wholesale price of each alternative. Indicate whether the price includes taxes and other costs.

2. Refer to the Bell companies’ reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 9 the Bell companies described a “complete problem resolution protocol” that must be followed by the Bell companies and the independent service provider prior to the dispatch of a technician to an independent service provider’s end-user premise. Provide CNOC’s view, with supporting rationale, as to whether this protocol allows for the isolation of known modem-related support issues in order to limit unnecessary technician dispatches.

MTS Allstream

1. Does MTS Allstream require modems on its network to be CS-03 certified?

2. Refer to MTS Allstream comments regarding Telecom Notice of Consultation 2013-80 dated 25 March 2013. In paragraph 8 it was submitted that MTS Allstream’s current tariff simply requires independent service providers to use VDSL2 G.993.2 high-speed modems that are compatible with MTS Allstream DSLAM equipment.

a. Identify the make(s) and model(s) of the VDSL modem(s) MTS Allstream provides its wholesale and retail customers and complete the following table in regards to this modem(s):

Current supplier price in Canadian dollars CDN/US exchange rate if applicable Supplier discount % Sales Tax % Warehouse & Distribution Factor % Cost including tax and Warehousing and Distribution
A B C D E = A*(1-B)*(1+C)*(1+D)

b. Are any independent service providers currently offering self-supplied VDSL modems to their end users that are compatible with MTS Allstream’s network?

c. To date, has MTS Allstream encountered any compatibility issues between off-the-shelf VDSL modems and DSLAMs in their network? If yes, elaborate.

TELUS Communications Company (TCC)

1. Does TCC require modems on its network to be CS-03 certified?

2. Provide the following terms and conditions, with supporting rationale, associated with the certification of VDSL modems by TCC:

a. the rate TCC charges independent service providers to certify new VDSL modems;
b. the total time it takes to complete the VDSL modem certification process;
c. whether TCC certifies firmware if the modems are supplied by the independent service provider; and,
d. any other terms and conditions, not yet provided in response to this question, associated with the certification of VDSL modems by TCC for use on their network.

Cogeco Cable Inc., Quebecor Media Inc., Rogers Communications, Shaw Communications Inc.

1. Refer to CNOC reply comments regarding Telecom Notice of Consultation 2013-80 dated 11 April 2013. In paragraph 56 it was submitted that now that the DOCSIS3.0 specification is mature, it may make sense to eliminate the second-level modem requirement for any modem that is compatible with DOCSIS 3.0 or lower level DOCSIS specification. Indicate whether or not the cable companies agree with this view and provide the rationale in support of your position.

Date modified:

2013-04-29