ARCHIVED - Letter
This page has been archived on the Web
Information identified as archived on the Web is for reference, research or recordkeeping purposes. Archived Decisions, Notices and Orders (DNOs) remain in effect except to the extent they are amended or reversed by the Commission, a court, or the government. The text of archived information has not been altered or updated after the date of archiving. Changes to DNOs are published as “dashes” to the original DNO number. Web pages that are archived on the Web are not subject to the Government of Canada Web Standards. As per the Communications Policy of the Government of Canada, you can request alternate formats by contacting us.
Our reference: 8661-A117-201314145
BY EMAIL
Mr. Denis E. Henry
Vice-President – Regulatory
Government Affairs and Public Law
Bell Aliant Regional Communications, Limited Partnership
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
regulatory@bell.aliant.ca
Mr. Philippe Gauvin
Senior Counsel
Regulatory Law and Policy
Bell Canada
160 Elgin Street, 19th Floor
Ottawa, Ontario K2P 2C4
bell.regulatory@bell.ca
Mr. Russ Friesen
Vice President, Regulatory Affairs
Allstream Inc.
P.O Box 6666
MP 20B - 333 Main Street
Winnipeg, Manitoba
R3C 3V6
iworkstation@mtsallstream.ca
RE: Allstream Inc. – Part 1 application requesting the application of the Commission’s ruling in Telecom Decision 2013-480[1] to the Bell companies’ legacy high-speed access services – Commission decision on interim rates and Commission staff requests for information
Dear Madam/Sirs:
The Commission received an application from Allstream Inc. (Allstream), dated
25 October 2013, in which the company requested that the Commission review the rates for the dedicated legacy high-speed access (HSA)[2] services of Bell Aliant Regional Communications, Limited Partnership in its territory in Ontario and Quebec, and Bell Canada (collectively, the Bell companies). Specifically, Allstream requested that the Commission apply the same rate principles it used in Telecom Decision 2013-480[3], and revise the current monthly access rates for the Bell companies’ respective dedicated legacy HSA services so that the same rate applies to their dedicated legacy HSA services and their legacy gateway access services (GAS), as is the case with the Bell companies’ fibre to the node (FTTN)-GAS and FTTN-HSA[4] services.
On 27 November 2013, the Commission received an intervention from the
Bell companies, in which the companies submitted that the application of the Commission’s ruling in Telecom Decision 2013-480 to the Bell companies’ dedicated legacy HSA services would lead to significant expenses and may cause service disruptions to independent service providers and their end-users. The Bell companies outlined two possible options for addressing Allstream’s application:
1. Maintain a flat-rate costing structure for their dedicated legacy HSA services, in which the rate comprises an access component plus a usage charge per end-user.
2. Create a new costing structure for their dedicated legacy HSA services using capacity-based billing (CBB). The Bell companies proposed three possible solutions to implement this structure, and indicated that each of the three proposed solutions would entail significant costs and time to implement.
Commission staff issued an interrogatory letter to the Bell companies, dated 6 January 2014, in which cost studies were requested in order to assess the Bell companies’ proposed flat-rate and CBB options.
On 17 January 2014, the Commission received a submission from the Bell companies in which they stated that conducting the requested cost studies would be resource intensive and time consuming. The Bell companies also reiterated that their three proposed solutions under the CBB option are impractical, since any of these solutions may take as long as nine months and cost upwards of $1 million to implement.
The Bell companies submitted that there was no need to perform a cost study for the flat-rate option, since the Commission just recently reaffirmed the access rate of $14.11 per month per end-user in Telecom Decision 2013-480, and that, therefore, this rate is appropriate. Regarding the usage charge component of the flat-rate option, the Bell companies developed a measured charge of $3.89, which, when combined with the access rate of $14.11, totals $18 per month per end-user. As a result of this proposed solution, the Bell companies requested a Commission ruling on the following:
1. to not respond to Commission staff’s interrogatory letter dated 6 January 2014; and
2. to apply a flat-rate costing structure (as opposed to CBB) for their dedicated legacy HSA services at a rate of $18 per end-user per month on a final basis, effective 15 February 2014.
On 21 January 2014, the Commission received a submission from Allstream, in which the company supported the Bell companies’ proposed flat-rate billing solution.
The Commission has considered the Bell companies’ and Allstream’s submissions and determines that it requires the costing information requested by Commission staff to properly evaluate the Bell companies’ proposed options before making a final decision on the matter. The Commission notes that requiring the Bell companies to respond to the interrogatories in no way precludes the Commission from approving the Bell companies’ requested approach for dedicated legacy HSA services.
In order to reduce any administrative burden associated with producing cost studies for all three proposed CBB solutions, the Commission determines that the Bell companies may, in the alternative, submit a cost study in respect of only the CBB solution that the Bell companies consider to be the most efficient, taking into account such factors as cost, timeliness of deployment, and disruption to ISP networks and subscribers. In respect of the proposed flat-rate costing structure, the Commission requires the information as requested in the Commission staff letter.
In addition, the Commission determines that the rates for the Bell companies’ respective dedicated legacy HSA services should be made interim at the rates agreed to by the parties. The Commission considers that this would provide competitors with relief in the short term, while giving the Commission the flexibility to adjust these rates retroactively, if appropriate, once the Commission has rendered a final decision based on the complete record of the proceeding.
In light of the above, the Commission directs the Bell companies to respond to Commission staff’s interrogatory letter dated 6 January 2014, in accordance with the instructions contained in this letter, effective 45 days from the date of this decision. As well, the Commission approves on an interim basis the rate of $18 per month per end-user based on the existing flat rate costing structure for the Bell companies’ respective dedicated legacy HSA services.
Sincerely,
Original signed by
John Traversy
Secretary General
c.c.: William Sandiford, CNOC, regulatory@cnoc.ca
Ramin Adim, CRTC, 819-997-4298, ramin.adim@crtc.gc.ca
Martin Brazeau, CRTC, 819 997-1028, martin.brazeau@crtc.gc.ca.
[1] Review of rate principles for legacy business wholesale high-speed access services, Telecom Decision CRTC 2013-480, 11 September 2013
[2] Bell Aliant General Tariff CRTC 21560 and Bell Canada General Tariff CRTC 6716, item 5420 – High Speed Access Service.
[3] In this decision, the Commission determined that the access rate for the Bell companies’ legacy business gateway access service (GAS) should be set equal to the access rate for their legacy residential GAS (i.e. $14.11 per month per end-user).
[4] General Tariff item 5440 – Gateway Access Service – Fibre to the Node
- Date modified: