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Telecom - Commission letter addressed to the Distribution List

Ottawa, 21 April 2021

Our reference: 1011-NOC2020-0187

BY EMAIL

Distribution List

Re:Telecom Notice of Consultation 2020-187, Call for comments – Appropriate network configuration for disaggregated wholesale high-speed access services – Requests for information

In Telecom Notice of Consultation CRTC 2020-187 footnote1 , the Commission directed all wholesale high-speed access (HSA) service providers to submit their responses to questions and requests for information, including providing proposed configurations for disaggregated wholesale HSA services that include a reduced level of disaggregation (as opposed to full disaggregation).

To assist the Commission in its analysis, the wholesale HSA service providers are to respond to the requests for information attached to this letter.

The following process is established for filing responses to the attached requests for information and for any subsequent requests for disclosure of information that is designated as confidential in the responses:

Following any disclosure process, parties will have the opportunity to file comments and replies strictly limited to the information provided in the responses to the requests for information. Commission staff will establish the subsequent process following any disclosure process.

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.

Please contact Tom Vilmansen (tom.vilmansen@crtc.gc.ca) at (819) 997‑9253 or myself (chris.noonan@crtc.gc.ca) at (873) 354‑0359 should you have any questions in regards to this letter.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services and Costing Implementation
Telecommunications Sector

Attach. (2): Distribution List

Request for Information

DISTRIBUTION LIST

chen@cshen.ca; harry_ism@hotmail.com; regulatory@internetsociety.ca; regulatory@cnoc.ca; regulatory@tacitlaw.com; john.powell@uniserveteam.com; regulatorynotice@allstream.com; regulatory@bcba.ca; ben@communityfibre.ca; regulatory.matters@corp.eastlink.ca; regulatory@rci.rogers.com; document.control@sasktel.com; patrick.desy@quebecor.com; bell.regulatory@bell.ca; leonard.eichel@cogeco.com; telecom.regulatory@cogeco.com; christopher.hickey@distributel.ca; jlawford@piac.ca; carreen.unguran@telus.com; regulatory.affairs@telus.com; regulatory@teksavvy.ca; regulatory@sjrb.ca; jfmezei@vaxination.ca; abderrahman.elfatihi@crtc.gc.ca

Request for Information

Bell Canada

  1. Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at central offices (COs) with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide the rationale for using a threshold of 30,000 premises passed for choosing COs that have dedicated POIs.
    2. For your identified regions - Ontario and Quebec, Manitoba and Atlantic provinces:
      1. Provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each CO that would be a POI and the name of each other CO that would be served from the POI along with the total premises passed for each CO.
        Table 1:
        POI CLLI CO CLLI Total Premises Passed
        POI CLLI (1) POI CLLI (1)  
          CO CLLI (1)  
          CO CLLI (2)  
          CO CLLI (3)  
          CO CLLI (4)  
        POI CLLI (2) POI CLLI (2)  
        POI CLLI (3) POI CLLI (3)  
          CO CLLI (5)  
          CO CLLI (6)  
          CO CLLI (7)  
      2. Identify the names of transport facilities providers that have transport facilities that are connected to each POI or are available to competitors for connection at each POI(in Excel spreadsheet as per the format in the table below).
        Table 2:
        POI CLLI Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
        POI CLLI (1)      
        POI CLLI (2)      
        POI CLLI (3)      
  2. TekSavvy requested that Bell Canada combine the processes for POI establishment and co-location in order to reduce the time required to establish a POI. Describe the steps required to establish co-location at a CO and the steps to establish a POI at a CO. Describe what has to be done to combine the two processes. Your response is to specify, with supporting rationale, which steps can be combined and which steps can be done in parallel for such a combined process.
  3. Assume that Bell Canada’s proposed configuration is to be implemented.
    1. For each CO that is a POI in Bell Canada’s proposed configuration, specify the following in an Excel spreadsheet in the format shown below:
      1. For Ontario and Quebec, specify whether the CO contains an Ethernet trunk switch and specify whether the CO contains a distribution router.
        Table 3:
        Region POI CLLI Ethernet Trunk Switch Distribution Router
        Ontario/Quebec POI CLLI (1)    
          POI CLLI (2)    
          POI CLLI (3)    
      2. For the Atlantic provinces and Manitoba, specify whether the CO contains an Ethernet trunk switch and specify whether the CO contains a dedicated Ethernet switch that can support wholesale high-speed access service.
        Table 4:
        Region POI CLLI Ethernet Trunk Switch Dedicated Ethernet Switch
        Atlantic POI CLLI (1)    
          POI CLLI (2)    
          POI CLLI (3)    
        Manitoba POI CLLI (1)    
          POI CLLI (2)    
          POI CLLI (3)    
    2. For POIs that have a distribution router (in Ontario and Quebec) or a dedicated Ethernet switch that can support wholesale HSA service (in Atlantic provinces and Manitoba) in place, describe what is required from a technical perspective and an operational perspective to support competitor interconnection to the disaggregated HSA service on a local distribution router (in Ontario and Quebec) or a dedicated Ethernet switch (in Atlantic provinces and Manitoba) instead of a DBS switch.
  4. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.
  5. Refer to question 2.m addressed to Bell Canada in the Appendix to Telecom Notice of Consultation CRTC 2020-187. While Bell Canada provided the requested information with respect to some central offices, the information for numerous other central offices was not provided. Provide a complete response to question 2.m that includes the requested information for each of the company’s central offices capable of providing wholesale HSA service.

Cogeco

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which head-ends with an addressable market equal to or greater than the threshold are served through a dedicated POI and head-ends with an addressable market less than the threshold are served through POIs that serve multiple head-ends:
        Table 5:
        Region Addressable Market Threshold (Premises Passed) Number of Head Ends Number of POIs (Some aggregation) Number of POIs (No aggregation)
        Ontario 30,000      
        Quebec 30,000      
      2. Having regard to your response in a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each head-end from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each head-end that would be a POI and the name of each other head-end that would be served from the POI along with the premises passed for each head-end.
          Table 6:
          POI Head-end Centre distributeur Nombre total de locaux desservis
          Centre distributeur PI (1) POI Head-end (1)  
            Head-end (1)  
            Head-end (2)  
            Head-end (3)  
            Head-end (4)  
          POI Head-end (2) POI Head-end (2)  
          POI Head-end (3) POI Head-end (3)  
            Head-end (5)  
            Head-end (6)  
            Head-end (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI head-end (or meet-me-point) or are available to competitors for connection at each POI head-end (or meet-me-point) (in Excel spreadsheet as per the format in the table below).
          Table 21:
          POI Head-end Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI Head-end (1)      
          POI Head-end (2)      
          POI Head-end (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per head-end) as a threshold for determining the level of aggregation in establishing a POI.
  2. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.

Eastlink

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which head-ends with an addressable market equal to or greater than the threshold are served through a dedicated POI and head-ends with an addressable market less than the threshold are served through POIs that serve multiple head-ends:
        Table 8:
        Region Addressable Market Threshold (Premises Passed) Number of Head Ends Number of POIs (Some aggregation) Number of POIs (No aggregation)
        Atlantic 30,000      
        Ontario 30,000      
      2. Having regard to your response to a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each head-end from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each head-end that would be a POI and the name of each other head-end that would be served from the POI along with the premises passed for each head-end.
          Table 20:
          POI Head-end Head-end Total Premises Passed
          POI Head-end (1) POI Head-end (1)  
            Head-end (1)  
            Head-end (2)  
            Head-end (3)  
            Head-end (4)  
          POI Head-end (2) POI Head-end (2)  
          POI Head-end (3) POI Head-end (3)  
            Head-end (5)  
            Head-end (6)  
            Head-end (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI head-end (or meet-me-point) or are available to competitors for connection at each POI head-end (or meet-me-point) (in Excel spreadsheet as per the format in the table below).
          Table 21:
          POI Head-end Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI Head-end (1)      
          POI Head-end (2)      
          POI Head-end (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per head-end) as a threshold for determining the level of aggregation in establishing a POI.
  2. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.
  3. Refer to questions 2.g and 2.h addressed to Eastlink in the Appendix to Telecom Notice of Consultation CRTC 2020-187. In its response to the questions, Eastlink indicated that it does not have information on premises passed by CMTS and on the number of TV subscribers by CMTS. However, the information requested was for the total number of premises passed that are capable of receiving HSA services at each site, along with a breakdown by access technology deployed, and the number of cable television subscribers served by each site. Provide complete responses to questions 2.g and 2.h that include the requested information for each of the company’s sites capable of providing wholesale HSA service.

Rogers

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which head-ends with an addressable market equal to or greater than the threshold are served through a dedicated POI and head-ends with an addressable market less than the threshold are served through POIs that serve multiple head-ends:
        Table 12:
        Region Addressable Market Threshold (Premises Passed) Number of Head Ends Number of POIs (Some aggregation) Number of POIs (No aggregation)
        Ontario 30,000      
        Atlantic 30,000      
      2. Having regard to your response to a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each head-end from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each head-end that would be a POI and the name of each other head-end that would be served from the POI along with the premises passed for each head-end.
          Table 20:
          POI Head-end Head-end Total Premises Passed
          POI Head-end (1) POI Head-end (1)  
            Head-end (1)  
            Head-end (2)  
            Head-end (3)  
            Head-end (4)  
          POI Head-end (2) POI Head-end (2)  
          POI Head-end (3) POI Head-end (3)  
            Head-end (5)  
            Head-end (6)  
            Head-end (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI head-end (or meet-me-point) or are available to competitors for connection at each POI head-end (or meet-me-point) (in Excel spreadsheet as per the format in the table below).
          Table 21:
          POI Head-end Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI Head-end (1)      
          POI Head-end (2)      
          POI Head-end (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per head-end) as a threshold for determining the level of aggregation in establishing a POI.
  2. To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.
  3. Refer to question 2.f addressed to Rogers in the Appendix to Telecom Notice of Consultation CRTC 2020-187. In its response to the question, Rogers provided a “yes” or “no” response as to whether there was routing equipment on site. However, this was not the information that was requested. Provide a complete response to question 2.f that includes the requested information for each of the company’s sites capable of providing wholesale HSA service (i.e., identify the site or sites with routing equipment to which the CMTS and/or CCAP at this site is/are connected).

SaskTel

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which COs with an addressable market equal to or greater than the threshold are served through a dedicated POI and COs with an addressable market less than the threshold are served through POIs that serve multiple COs:
        Table 16:
        Region Addressable Market Threshold (Premises Passed) Number of COs Number of POIs (Some aggregation) Number of POIs (No aggregation)
        Saskatchewan 30,000      
      2. Having regard to your response to a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each CO from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each CO that would be a POI and the name of each other CO that would be served from the POI along with the premises passed for each CO.
          Table 17:
          POI CLLI CO CLLI Total Premises Passed
          POI CLLI (1) POI CLLI (1)  
            CO CLLI (1)  
            CO CLLI (2)  
            CO CLLI (3)  
            CO CLLI (4)  
          POI CLLI (2) POI CLLI (2)  
          POI CLLI (3) POI CLLI (3)  
            CO CLLI (5)  
            CO CLLI (6)  
            CO CLLI (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI or are available to competitors for connection at each POI (in Excel spreadsheet as per the format in the table below).
          Table 18:
          POI CLLI Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI CLLI (1)      
          POI CLLI (2)      
          POI CLLI (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per CO) as a threshold for determining the level of aggregation in establishing a POI.
  2. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.
  3. Refer to question 2.h addressed to SaskTel in the Appendix to Telecom Notice of Consultation CRTC 2020-187. In its response, SaskTel indicated that it does not track homes passed by technology at this level of detail. Provide a complete response to question 2.h that includes the requested information for each of the company’s central offices capable of providing wholesale HSA service. Otherwise, provide further information as to why SaskTel does not track homes passed by technology at this level of detail.

Shaw

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which head-ends with an addressable market equal to or greater than the threshold are served through a dedicated POI and head-ends with an addressable market less than the threshold are served through POIs that serve multiple head-ends:
        Table 19:
        Region Addressable Market Threshold (Premises Passed) Number of Head Ends Number of POIs (Some aggregation) Number of POIs (No aggregation)
        British Columbia 30,000      
        Alberta 30,000      
        Saskatchewan 30,000      
        Manitoba & Northern Ontario 30,000      
      2. Having regard to your response to a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each head-end from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each head-end that would be a POI and the name of each other head-end that would be served from the POI along with the premises passed for each head-end.
          Table 20:
          POI Head-end Head-end Total Premises Passed
          POI Head-end (1) POI Head-end (1)  
            Head-end (1)  
            Head-end (2)  
            Head-end (3)  
            Head-end (4)  
          POI Head-end (2) POI Head-end (2)  
          POI Head-end (3) POI Head-end (3)  
            Head-end (5)  
            Head-end (6)  
            Head-end (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI head-end (or meet-me-point) or are available to competitors for connection at each POI head-end (or meet-me-point) (in Excel spreadsheet as per the format in the table below).
          Table 21:
          POI Head-end Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI Head-end (1)      
          POI Head-end (2)      
          POI Head-end (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per head-end) as a threshold for determining the level of aggregation in establishing a POI.
  2. In Shaw’s description of its proposed configuration, the company submitted that over time it would increase the number of POIs to reflect the impact of its network evolution. Starting with the company’s initial proposed configuration, provide details on the changes in POI sites over time. The response is to specify (in an Excel spreadsheet) on a yearly basis what POI locations will be added and what sites will be supported by each POI.
  3. Describe what additional equipment, beyond what Shaw uses for its retail service, it would introduce at a site to implement a POI for disaggregated HSA service. Further, specify what a competitor would have to provide to interconnect to the POI.
  4. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.

TCI

  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. For your network, provide the requested information in the table below for a configuration in which COs with an addressable market equal to or greater than the threshold are served through a dedicated POI and COs with an addressable market less than the threshold are served through POIs that serve multiple COs:
      Table 22:
      Region Addressable Market Threshold (Premises Passed) Number of COs Number of POIs (Some aggregation) Number of POIs (No aggregation)
      British Columbia 30,000      
      Alberta 30,000      
      Quebec 30,000      
    2. Having regard to your response to a) above:
      1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
      2. For the addressable market threshold of 30,000 premises passed in each CO from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each CO that would be a POI and the name of each other CO that would be served from the POI along with the premises passed for each CO.
        Table 23:
        POI CLLI CO CLLI Total Premises Passed
        POI CLLI (1) POI CLLI (1)  
          CO CLLI (1)  
          CO CLLI (2)  
          CO CLLI (3)  
          CO CLLI (4)  
        POI CLLI (2) POI CLLI (2)  
        POI CLLI (3) POI CLLI (3)  
          CO CLLI (5)  
          CO CLLI (6)  
          CO CLLI (7)  
      3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI or are available to competitors for connection at each POI (in Excel spreadsheet as per the format in the table below).
        Table 24:
        POI CLLI Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
        POI CLLI (1)      
        POI CLLI (2)      
        POI CLLI (3)      
    3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
      1. Propose an alternative addressable market threshold with supporting rationale.
      2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
    4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per CO) as a threshold for determining the level of aggregation in establishing a POI.
  2. TCI indicated that its proposed configuration would minimize the equipment required to support the disaggregated HSA service. Describe what additional equipment, beyond what TCI uses for its retail service, it would introduce at a CO to implement a POI for disaggregated HSA service. Further, specify what a competitor would have to provide to interconnect to the POI.
  3. In its intervention dated 5 October 2020, TCI described how it planned to consolidate its urban COs over time. Provide details for the company’s planned network evolution, indicating for each affected urban area which COs are to be consolidated along with the estimated dates for consolidation.
  4. Provide an estimate of the time required to implement a POI. Provide a breakdown of the steps required (with time estimates for each step) from the initial request by a competitor for a POI at a CO to the interconnection of the competitor to an enabled POI.
  5. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.

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  1. In accordance with Telecom Notice of Consultation CRTC 2020-187, wholesale HSA service providers were required to “propose a configuration (or configurations)…that includes a reduced level of disaggregation (as opposed to full disaggregation)”, while considering the following factors:
    • achieving minimal disruption to the wholesale HSA service provider’s existing network and the planned evolution of the network;
    • reducing changes to the wholesale HSA service provider’s network, taking into account existing and planned network architecture;
    • establishing a minimum addressable market at a competitor point of interconnection, taking into account geographical considerations (e.g. the distinction between rural and urban areas, where applicable);
    • minimizing barriers to entry for competitors, such as costs for transport or for point of interconnection implementation; and
    • minimizing the deployment timeline and costs.
    • Refer to Bell Canada's intervention submitted on 5 October 2020, where it proposed that competitor access to HSA service at COs with 30,000 or more premises passed would be through a POI dedicated to that CO (no aggregation), and competitor access to COs with less than 30,000 premises passed would be through a POI located at another CO that serves multiple COs (some aggregation). To assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
      1. For your network, provide the requested information in the table below for a configuration in which head-ends with an addressable market equal to or greater than the threshold are served through a dedicated POI and head-ends with an addressable market less than the threshold are served through POIs that serve multiple head-ends:
        Table 25:
        Region Addressable Market Threshold (Premises Passed) Number of Head-ends Number of POIs (Some aggregation) Number of POIs (No aggregation)
        Quebec 30,000      
      2. Having regard to your response to a) above:
        1. Although such an approach could impact your network architecture, describe how you would select POIs under this approach.
        2. For the addressable market threshold of 30,000 premises passed in each head-end from a) above, provide your disaggregated HSA configuration (in Excel spreadsheet as per the format in the table below) specifying the name of each head-end that would be a POI and the name of each other head-end that would be served from the POI along with the premises passed for each head-end.
          Table 26:
          POI Head-end Head-end Total Premises Passed
          POI Head-end (1) POI Head-end (1)  
            Head-end (1)  
            Head-end (2)  
            Head-end (3)  
            Head-end (4)  
          POI Head-end (2) POI Head-end (2)  
          POI Head-end (3) POI Head-end (3)  
            Head-end (5)  
            Head-end (6)  
            Head-end (7)  
        3. Identify the names of transport facilities providers that have transport facilities that are connected to each POI head-end (or meet-me-point) or are available to competitors for connection at each POI head-end (or meet-me-point) (in Excel spreadsheet as per the format in the table below).
          Table 27:
          POI Head-end Transport Facilities Provider 1 Transport Facilities Provider 2 Transport Facilities Provider 3
          POI Head-end (1)      
          POI Head-end (2)      
          POI Head-end (3)      
      3. If the addressable market threshold in a) above is not acceptable to the company (note that this does not preclude the requirement to respond to questions a) and b) above):
        1. Propose an alternative addressable market threshold with supporting rationale.
        2. Based on your proposed alternative addressable market threshold, provide the information in the same table format as described in a), b)(ii) and b)(iii) above.
      4. Provide your view on the appropriateness of utilizing the addressable market (i.e., premises passed per head-end) as a threshold for determining the level of aggregation in establishing a POI.
  2. To further assist the Commission in its assessment of the proposed level of disaggregation, provide responses to the following questions:
    1. Provide your view on the appropriateness of providing competitors with the option of maintaining a fully disaggregated wholesale HSA service in parallel with a wholesale HSA service model with a reduced level of disaggregation.
    2. Describe the impact(s) of such a scenario from an operational and costing perspective.
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