Telecom Commission Letter Addressed to the Distribution List

Ottawa, 24 May 2017

Our reference:  1011-NOC2017-0049

BY EMAIL

Distribution

RE:  Review of the competitor quality of service regime, Telecom Notice of Consultation 2017-49 – Requests for information

Dear Madam, Sir:

Pursuant to the procedure set out in Review of the competitor quality of service regime, Telecom Notice of Consultation 2017-49, 23 February 2017, attached are requests for information from Commission staff to Bragg Communications Inc., operating as Eastlink (Eastlink); Cogeco Communications Inc., on behalf of its affiliate Cogeco Connexion Inc. (Cogeco); Quebecor Media Inc. on behalf of its affiliate Videotron (Videotron); Rogers Communications Canada Inc. (RCCI); and Shaw Cablesystems G.P. (Shaw).

Responses to the requests for information in the attached Appendix are to be filed with the Commission by 23 June 2017.

Responses are to be provided in a single document to facilitate accessibility and administrative processing. However, any information provided in spreadsheet format should be attached as an appendix, in MS Excel format.

Please contact Laurie Ventura (laurie.ventura@crtc.gc.ca) at 819-997-4589 should you have any questions in regard to this letter.

Sincerely,

Original signed by

Kay Saicheua
Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.:  Laurie Ventura, CRTC, 819-997-4589, laurie.ventura@crtc.gc.ca
Eric Macfarlane, CRTC, 819-997-4389, eric.macfarlane@crtc.gc.ca
Josiane Lord, CRTC, 819-576-2568, josiane.lord@crtc,gc,ca
Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca

Attach. (1)

Distribution List:  michel.messier@cogeco.com; telecom.regulatory@cogeco.com; regulatory.matters@corp.eastlink.ca; regaffairs@quebecor.com; david.watt@rci.rogers.com; rwi_gr@rci.rogers.com; regulatory@sjrb.ca


ATTACHMENT

  1. Questions for Cogeco, Eastlink, RCCI, Shaw, and Videotron:
    1. As part of this proceeding, Internet customers whose service providers rely on incumbent local exchange carriers’ (ILECs) or cable companies’ wholesale high-speed access (HSA) services submitted interventions about issues related to services the underlying wholesale service provider also provides to its retail Internet customers. They cited, among other things:
      • numerous missed appointments;
      • unreasonably large appointment windows;
      • unreasonably long installation or repair times associated with their services;
      • issues with the quality of their services; and
      • technicians taking advantage of appointments to solicit them to switch providers, suggesting that this would resolve or expedite the repair of network issues.

      Many of those interveners added that the wholesale HSA service provider’s retail Internet customers were not subject to the same kind of service interruptions, both in terms of the frequency and duration of these interruptions.

      1. Describe, in detail, your company’s process for receiving, assigning, and fulfilling service requests for installation, repair, and/or any other service changes for end‑customers. Your response should outline processes for (i) your own retail Internet customers, (ii) those of your wholesale HSA customers, and (iii) customers of your own flanker brand, if applicable (i.e. in the case of RCCI, for Fido Home Internet customers). If there are any differences between the processes for any of those activities, clearly identify and provide rationale to explain any differences in the way your company processes requests for your retail Internet customers and your wholesale HSA customers’ end-users – and, in the case of RCCI, for Fido Home Internet customers.
      2. What service and/or quality standards are imposed on your technicians that deal with wholesale HSA customers’ end-users? Is there any difference in the standards that apply when they are dealing with a wholesale HSA customer’s end-user versus one of your company’s retail Internet customers – or, in the case of RCCI, with a Fido Home Internet customer? If so, explain why there is a difference.
      3. Should the Commission decide to expand the competitor quality of Q of S regime to implement an HSA component, provide your view, with supporting rationale, on how to measure the time taken to fulfill a service order, beginning at the time the wholesale HSA customer places an order for service installation, repair, and/or in relation to any other customer request for its end-users. Explain how this would allow for easy comparison with service order fulfillment for your retail Internet customers – and, in the case of RCCI, for Fido Home Internet customers.
    2. Indicate whether any Q of S commitments are included in any of the tariffed wholesale services your company offers. If so, list any relevant tariff item numbers and service names, as well as the specific Q of S requirement and associated rebate or other specified remedial measures to address failures.
    3. Indicate whether your company has signed off-tariff agreements for wholesale HSA services between January 2014 and April 2017. If so, provide:
      1. the names of competitors that have signed off-tariff agreements for your wholesale HSA services; and
      2. any clauses that address Q of S, including service intervals, contained in these off-tariff agreements.
    4. Provide your company’s internal service interval targets for the installation, repair, and/or any other service changes associated with retail Internet and/or wholesale HSA services – and, in the case of RCCI, with Fido Home Internet service. Specify any differences by region or province in your operating territory.
    5. Indicate whether your company compiles information about the average service delivery time associated with service installation, repair, and any other service changes for your retail Internet customers and/or your wholesale HSA customers’ end-users – and, in the case of RCCI, for Fido Home Internet customers. If not, why not? If so:
      1. provide a description of the specific delivery time information your company compiles, for both your retail Internet customers and your wholesale HSA customers’ end-users – and, in the case of RCCI, for Fido Home Internet customers;
      2. indicate, with supporting rationale, whether and how the systems and procedures for compiling the information described above could be leveraged to apply to a wholesale HSA Q of S regime; and
      3. provide the average service delivery time associated with each of the following: service installation, repair, and any other service changes. Your response must distinguish averages for (i) your retail Internet customers, (ii) your wholesale HSA customers’ end-users, and (iii) Fido Home Internet customers in the case of RCCI, for 2014 to 2016 on a monthly basis. If available, provide a breakdown of the information requested in (ii) for each of your wholesale HSA customers.
  2. Question for Cogeco, Eastlink, Rogers, and Videotron:
    1. In paragraphs 115 to 122 of their intervention, Cogeco, Eastlink, Rogers and Videotron indicated that other mechanisms (such as bilateral discussions, multilateral negotiations, Commission-supervised dispute resolution, and/or Part 1 applications) can be used to ensure that regulated wholesale services are provided to competitors at a sufficient quality level to foster competition. Explain, with supporting rationale, how wholesale customers would be able to verify and ensure they receive adequate service from wholesale service providers under these mechanisms.
  3. Question for Shaw:
    1. In its intervention, in answer to question 4, Shaw indicated that the Commission has regulatory tools to address concerns related to mandated wholesale services, such as the Commission’s Alternative Dispute Resolution process, Part I applications, bi-lateral negotiation, off-tariff agreements, and CISC Working Group discussions. Explain, with supporting rationale, how wholesale customers would be able to verify and ensure they receive adequate service from wholesale service providers under these regulatory tools.
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