ARCHIVED - Telecom Commission Letter Addressed to the Distribution List

Ottawa, 28 April 2015

Our reference: 8660-C182-201313113

BY EMAIL

Distribution list

RE: Follow up to Canadian Network Operators Consortium Inc. - Application to improve the quality of wholesale high-speed access services provided by cable carriers to independent Internet service providers, Telecom Decision CRTC 2015-40, 12 February 2015

Dear Sirs:

The Commission received an application from the Canadian Network Operators Consortium Inc. (CNOC), dated 27 September 2013, in which CNOC requested changes to the wholesale high-speed access (HSA) services provided by Cogeco Cable Inc. (Cogeco), Rogers Communications Partnership (RCP), Shaw Cablesystems G.P. (Shaw), and Videotron G.P. (Videotron) [collectively, the Cable carriers]. In Telecom Decision CRTC 2015-40 the Commission issued its determinations on CNOC’s application.Replace it with ^{Footnote 1} The Commission found that there was insufficient information on the record of the proceeding to determine if a regulatory response is necessary for certain items. Commission staff is now collecting additional information to determine what, if any, action is required to address these items.

Attached to this letter are requests for information issued to CNOC and the Cable carriers.

Responses to these requests for information are to be filed with the Commission by 28 May 2015.

As set out in section 39 of the Telecommunications Act, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure.

Sincerely

Original signed by

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunications Sector

c.c: Tom Vilmansen, tom.vilmansen@crtc.gc.ca
Greg Milosek, gregory.milosek@crtc.gc.ca

Distribution List

CNOC, regulatory@cnoc.ca
Cogeco Cable Inc., michel.messier@cogeco.com
Rogers Communications Partnership, david.watt@rci.rogers.com
Shaw Cablesystems G.P., Regulatory@sjrb.ca
Videotron G.P., regaffairs@quebecor.com

Requests for Information

To CNOC and the Cable carriers:

1. Refer to End-user Service Initiation Process (HSRE003), dated 11 April 2001, which sets out a standard service process and procedure to complete an order for TPIA service to an ISP's end-user.
   1. Explain how the actual TPIA end-user service initiation procedures and timelines differ from those described in each of the five procedural steps of HSRE003.
   2. Would there be any benefit in reviewing the procedures and timelines described in HSRE003, given that Cable carriers and TPIA customers have gained considerable experience with the process since the consensus report was approved by the Commission?
   3. What changes should be made to the end-user service initiation process described in HSRE003 to make it more efficient?
2. HSRE003 does not address how a Cable carrier (or one of its technicians) changes an installation or repair window. What are the Cable carriers’ procedures for changing installation or repair windows in the event that a Cable carrier’s technician is unable to perform the installation or repair at the scheduled time, through no fault of the TPIA end-user? Explain how these procedures were established.
3. HSRE003 states that, in the event that an order cannot be completed because nobody was home, it is the ISPs responsibility to re-schedule a new installation date or create a new installation order. HSRE003 also states that proposed installation dates cannot be scheduled less than 5 business days after the date of the installation order.
   1. What modifications can be made to the installation and repair appointment scheduling process to minimize the amount of time it takes to re-schedule an appointment in the event that a Cable carrier’s technician is unable to perform the installation or repair?
4. HSRE003 states that, in situations where an installation was attempted but the end-user was not at home, the CSG will notify the ISP through the business interface system that nobody was home and the order could not be completed. Indicate whether or not this procedure is followed for installation and repair appointments. If not, explain why not.
5. Refer to Trouble-shooting end-user technical problems (HSRE013), dated 29 August 2001, which describes the procedures to trouble-shoot end-user technical problems related to third-party Internet access. Do ISPs have the ability to determine that a technical problem does not originate from the ISP’s installations or equipment, or the equipment of its end-user(s)? Explain why or why not.

To the Cable carriers:

6. Explain any differences between the scheduling of installation or repair appointments for your own retail customers, and the process used for your TPIA end-users.
7. Cable carriers submitted that, under existing procedures, TPIA customers cannot be provided with direct access to the Cable carriers’ technician dispatch staff because scheduling requests must be processed through the CSG to ensure that the request is properly validated and tracked for billing purposes.
   1. What changes to existing procedures would be required to provide TPIA customers with direct access to the Cable carriers’ technician dispatch staff, while also ensuring that requests are properly validated and tracked for billing purposes?
   2. Explain any technical challenges and provide an estimate of the total cost of changing these procedures.
   3. How would these costs be recovered? If these costs would be recovered through TPIA rates, explain what the impact on TPIA rates would be. 
8. Refer to End-user Service Initiation Process (HSRE003), dated 11 April 2001, which sets out a standard service process and procedure to complete an order for TPIA service to an ISP's end-user. HSRE003 states that “The business interface system will permit the ISP to pre-qualify End-user customers prior to order processing. The ISP will use a database to look-up the potential End-user’s civic address to verify that the TPIA service is available to that End-User”. Do Cable carriers provide TPIA customers with access to the database described above? If not, explain why not.
9. Are all TPIA service speeds available in all of the areas that Internet service is available?
   1. If not, how can a TPIA customer determine whether a potential end-user is eligible for a particular service speed prior to submitting an order to a Cable carrier?
   2. If TPIA customers are currently unable to determine whether a potential end-user is eligible for a particular service speed prior to submitting an order to a Cable carrier, discuss whether it is technically feasible to offer such functionality to TPIA customers. 
      1. Discuss what technical challenges developing a solution would present and provide an estimate of the total cost of offering this functionality (i.e. adding it to the existing service availability tool on your website or providing it as a database).
      2. How would these costs be recovered? If these costs would be recovered through TPIA rates, explain what the impact on TPIA rates would be.
10. If ISPs do not have the ability described in 5. above, discuss what technical challenges providing ISPs with this ability would present and provide an estimate of the total costs.
    1. How would these costs be recovered? If these costs would be recovered through TPIA rates, explain what the impact on TPIA rates would be.
11. Cable carriers submitted that developing troubleshooting tools that would ensure ISPs could not gain access to competitors’ end-user modems may not be technically or economically feasible. Discuss what technical challenges developing a solution would present and provide an estimate of the total cost of offering such troubleshooting tools to ISPs.
    1. How would these costs be recovered? If these costs would be recovered through TPIA rates, explain what the impact on TPIA rates would be.

To Cogeco only:

12. Cogeco submitted that “TPIA customers have the responsibility of confirming the installation order date provided by the Cogeco CSG in response to a booking request.”
    1. Clarify with whom TPIA customers have the responsibility of confirming the installation order date. If TPIA customers are requested to confirm the installation order date with Cogeco, then proceed to 12.b.
    2. Requiring that TPIA customers confirm the installation date with Cogeco does not appear to be consistent with HSRE003. Explain why Cogeco requests such confirmation and indicate whether TPIA customers can opt-out of responding to such confirmation requests. What would be the impact if TPIA customers did not confirm the installation date with Cogeco?

To Rogers only:

13. In its response to CNOC’s Part 1 Application, Rogers submitted that one of its technicians rolls to the address for every TPIA install call requiring a truck roll, even if there is no answer when the technician calls the end-user. In its contribution 1540AO0001e to the 1540 Wholesale High-speed Access Ad Hoc Working Group dated 1 April 2015, Rogers submitted that the technician and dispatch will try to phone the end-user twice prior to the technician’s arrival to the end user’s premises. If there is no answer to the call, then Rogers assumes that nobody’s home and the call is cancelled.
    1. Clarify whether or not a technician rolls to the address for every TPIA install call requiring a truck roll, even if there is no answer when the technician calls the end-user.
    2. Does Rogers use the same procedures for its own retail Internet customers as it does for its TPIA end-users?

Date modified:

2015-04-28