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Ottawa, 6 January 2014

Our reference: 8661-A117-201314145

BY EMAIL

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

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

Re: Allstream Inc. - Part 1 Application requesting the application of the Commission’s Decision 2013-480 ruling to Bell legacy HSA service - Interrogatories

Dear Sirs:

In an application dated 25 October 2013, Allstream Inc. (Allstream) requested that the Commission revise the current monthly access rates of Bell Aliant Regional Communications, Limited Partnership operating in Ontario and Quebec and Bell Canada (collectively, the Bell companies) legacy dedicated High-Speed Access (legacy HSA)^{Footnote 1} service so that the same rate applies to that service and legacy Gateway Access Service (GAS). In Allstream’s view, this change would be consistent with the approach taken for the Bell companies’ fibre to the node (FTTN) GAS^{Footnote 2} and HSA^{Footnote 3} services. Allstream requested that the revised rate for legacy HSA should be made effective 30 days after the date of the Commission’s decision.

On 27 November 2013, the Canadian Network Operators Consortium Inc. filed comments in support of Allstream’s 25 October 2013 application.
On 27 November 2013, the Bell companies filed their response to Allstream’s Part 1 application. In their submission, the Bell companies indicated that although conceptually they understand that Allstream’s request would see the HSA access rates lowered to match the rates for GAS, in practice the Bell companies do not apply and are not presently capable of applying Capacity Based Billing (CBB) on their HSA services, whereas they do on GAS. In their view, the correct matching of “lower” HSA rates therefore should be against what the GAS rates would be if the HSA rate included a usage component. The Bell companies noted that there are no usage-inclusive GAS rates for their services.

In their response, the Bell companies indicated there could be two possible options for resolving Allstream’s application. The first option would be to introduce CBB on legacy HSA through several potential technical approaches. The second option, which the Bell companies propose, would be to establish a usage-inclusive access rate for legacy HSA.

On 9 December 2013, Allstream submitted in reply that it is not opposed to the Bell companies’ proposal to file a revised rate for legacy HSA that incorporates a flat rate usage charge, subject to the caveat that Allstream reserves the right to comment on the Bell companies’ supporting cost study. Allstream also requested that the Commission make the Bell companies’ legacy HSA rates interim effective immediately based on the grounds that the current rates are not just and reasonable.

Commission staff has reviewed the information on the record and has determined there is a need for further information in order to properly assess the Bell companies’ options. Consequently, the Bell companies are requested to respond to the attached interrogatories and serve copies to on all interested parties by 25 February 2014.
All parties may file written comments with the Commission, serving copies on all other parties by 11 March 2014.

The Bell companies may file reply comments by 25 March 2014.
Commission staff notes that the Bell companies have not had an opportunity to respond to Allstream’s request that the rate for legacy HSA be made interim at $14.11. Accordingly, the Bell companies may provide their comments regarding whether the legacy HSA rates should be made interim by 17 January 2014.

Parties are reminded that 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. Copies of the documents should also be sent to ramin.adim@crtc.gc.ca and doug.thurston@crtc.gc.ca

Yours sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing
Telecommunications

c.c.: William Sandiford, Canadian Network Operators Consortium Inc., regulatory@cnoc.ca
Teresa Griffin-Muir, Allstream, iworkstation@mtsallstream.ca

Attachment (1)

Attachment

Provide responses to the following requests for information. Note the cost study report should include the additional costing information identified in the Commission staff’s letter Information to be provided in support of wholesale service tariff applications, dated 12 July 2013.

1 a) The Bell companies indicated that it may be technically feasible to logically associate individual GAS and HSA VLANs at the Ethernet Switch, so that independent service providers can manage their GAS and HSA traffic together and CBB increments can be ordered on both GAS and HSA together, on a per Aggregated High Speed Service Provider Interface (AHSSPI) basis.

i. For this scenario provide a cost study. The cost study should include the 2014 vintage costs associated with the access component of the legacy HSA service.
ii. Provide a detailed diagram showing the solution with the demarcation point of each component and each rate element.
iii. Identify and provide an explanation for the purpose and functionality of any new hardware or new software components required to provision this option.

b) The Bell companies indicated that it may be feasible to allow port-based traffic management capability at the AHSSPI port on the Ethernet switch (so that GAS and HSA traffic can be managed together and CBB increments can be ordered for both services together).

i. For this scenario provide a cost study. The cost study should include the 2014 vintage costs associated with the access component of the legacy HSA service.
ii. Provide a detailed diagram showing the solution with the demarcation point of each component and each rate element.
iii. Identify and provide an explanation for the purpose and functionality of any new hardware or new software components required to provision this option.

c) The Bell companies indicated that it may be feasible to apply a port-based policy on a Network Interface Device (NID) external to the Ethernet switch which would allow an independent service provider to terminate HSA and GAS service traffic on one port while provisioning Ethernet services on an additional non-limited port, if required.

i. For this scenario provide a cost study. The cost study should include 2014 vintage costs associated with the access component of the legacy HSA service.
ii. Provide a detailed diagram showing the solution with the demarcation point of each component and each rate element.
iii. Identify and provide an explanation for the purpose and functionality of any new hardware or new software components required to provision this option.

2. In its 27 November response, the Bell companies proposed to maintain legacy HSA on the flat rate billing model which would be comprised of an access and a usage component. The Bell companies proposed to adjust the legacy HSA monthly access rates to the level of current legacy GAS monthly access rates ($14.11) and to add a new usage cost component (plus a 30% mark-up) so that a flat rate costing structure can be maintained. The Bell companies submitted that this approach would be much less disruptive than introducing CBB and easier to implement as it requires absolutely no development work.

i. Provide a cost study in support of this scenario. The cost study should reflect updated access cost information and new usage cost information. The cost study should include 2104 vintage costs for the access and usage components.
ii. Provide a detailed diagram showing the solution with the demarcation point of each component and each rate element.
iii. Identify and provide an explanation for the purpose and functionality of any new hardware or new software components required to provision this option.