ARCHIVED - Telecom Procedural Letter Addressed to Philippe Gauvin (Bell Canada)

Ottawa, 18 May 2017

Our reference: 8662-B2-201612391

BY EMAIL

Mr. Philippe Gauvin
Senior Legal Counsel
Bell Canada
160 Elgin Street, floor 19
Ottawa, ON, K2P 2C4
bell.regulatory@bell.ca

RE: Review and Vary and Stay Telecom Decision CRTC 2016-379, follow-up to Telecom Regulatory Policy 2015-326 – Implementation of a disaggregated wholesale high-speed access service, including over fibre-to-the premises access facilities

On 2 December 2016, Bell Canada filed the above noted application and subsequently filed a revised version of the application on 9 December 2016. The Part 1 application requested the Commission to review and vary Decision 2016-379^Footnote1 , to eliminate the requirement to implement an outside meet-me point of interconnection for the disaggregated wholesale High Speed Access service (R&V Application).

In Telecom Decision CRTC 2016-379 the Commission concluded, at paragraph 82 that, if the meet-me point for Bell Canada is similar to that of the Cablecos then it is expected that the costs for supporting interconnection should be similar to the costs and associated rates that have been established for Cablecos.

In its R&V Application, Bell Canada argues that the Commission made an error in determining that the costs of co-location were a deterrent to competition and provided evidence to support its position as to the actual costs of co-location. However, Bell Canada did not address the costs of the competitor service (i.e. the meet-me-point option) other than to reiterate that it would be expensive and costly to implement.

Since the filing of its R&V Application, Bell Canada also filed, on 31 January 31, 2017, Tariff Notice 7524- Disaggregated Broadband Service (BDS) Meet-me Point (DMMP) Service, which proposed rates for its Disaggregated Broadband service meet-me point service supported by a cost study.

With this letter, Commission staff is requesting comments on the appropriateness of using of the meet-me point rates proposed in TN 7524 for the purpose of evaluating the relative costs of existing co-location options and the meet-me-point alternative mandated by the Commission in Decision 2016-379.

Bell Canada is to provide its view on this matter by 29 May 2017. Parties may file comments limited to this new information by the same date as the deadline to file comments on the Commission’s staff request for information dated 26 April 2017, being by 5 June 2017. Bell Canada may file reply comments by 12 June 2017.

Responses and comments are to be served on all parties to this application by the specified dates. Copies of the document should also be sent to nat.natraj@crtc.gc.ca

Sincerely,

Original signed by

Lyne Renaud
Director, Competitor Services and Costing Implementation
Telecommunications Sector

c.c.: Distribution list