Telecom - Staff Letter addressed to the Distribution List

Ottawa, 8 March 2023

Our reference: 1011-NOC2023-0056

BY EMAIL 

Distribution List

Re: Review of wholesale high-speed access service framework, Telecom Notice of Consultation 2023-56 – Requests for Information

Attached to this letter are requests for information issued within the context of the proceeding initiated by Telecom Notice of Consultation CRTC 2023-56. Staff notes that two separate requests for information (RFIs) have been issued in separate attachments and which are subject to separate filling dates. Responses to the RFIs in appendix 1 are due by 24 April 2023, and the responses to the RFIs in appendix 2 are due by 22 June 2023. Further, staff notes that these RFIs are the first in a series of questions that are expected to be issued over the course of the above referenced proceeding.

Responses to the RFIs, as set out in the corresponding appendices, are to be filed with the Commission, and served on the persons included in the distribution to this letter. These responses must be received, not merely sent, by the dates mentioned above. Entities are only to respond to those questions contained in the appendices that are addressed to them. Smaller, independent Internet service providers (ISPs) that are not included in the distribution to this letter are also invited to respond to the questions that are addressed to smaller ISPs.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, 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. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed. 

Parties and interested persons may request the public disclosure of information that has been designated confidential in responses to the attached RFIs, setting out in each case the reasons for disclosure. These disclosure requests must be filed with the Commission and served on the entities to whom they are addressed, by 4 May 2023 for information in responses to the RFIs in Appendix 1, and by 4 July 2023 for information in responses to RFIs in Appendix 2.

Sincerely, 

Original signed by

Philippe Kent 
Director, Telecommunications Services Policy

c.c.: Peter Keriakos, CRTC, peter.keriakos@crtc.gc.ca        
Adam Mills, CRTC, adam.mills@crtc.gc.ca 
Sarah McMaster, CRTC, sarah.mcmaster@crtc.gc.ca           
Andrew Gaiero, CRTC, andrew.gaiero@crtc.gc.ca

Distribution List

Bell Canada, bell.regulatory@bell.ca;
Cogeco, telecom.regulatory@cogeco.com;
Eastlink, regulatory.matters@corp.eastlink.ca;
RCCI, regulatory@rci.rogers.com;
SaskTel, document.control@sasktel.sk.ca;
Shaw, Regulatory@sjrb.ca;
TCI, regulatory.affairs@telus.com;
Videotron, regaffairs@quebecor.com;
TekSavvy, regulatory@teksavvy.ca;
Distributel, regulatory@distributel.ca;
Ebox, jp@ebox.ca;
Vmedia, george.burger@vmedia.ca ;
Altima Telecom, franky@altimatelecom.com ;
Start, rocca@start.ca;
CNOC, regulatory@cnoc.ca;
Citywide, david@yourcitywide.com;
BCBA, Regulatory@bcba.ca;
CIK Telecom, jordan.d@ciktel.com;
Sunwire, jason@sunwire.ca;
Comwave, edelduca@comwave.net;
Community Fibre, ben@communityfibre.ca;
Vianet, regulatory@vianet.ca;
Zayo Canada, regulatory@zayo.com;

Appendix 1 – NoC 2023-56 Requests for Information #1a –Deployment of FTTP facilities and financial summaries

Bell Canada, Bell MTS, Bell Aliant, TCI, SaskTel

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province:
    1. total number of premises passed by fibre-to-the-premise (FTTP), fibre-to-the-node (FTTN), and legacy digital subscriber line (DSL) facilities;
    2. the number of premises passed only by FTTP facilities;
    3. the number of premises passed only by FTTN facilities;
    4. the number of premises passed only by legacy DSL facilities;
    5. the number of premises passed by both FTTP and FTTN facilities;
    6. the number of premises passed by both FTTP and legacy DSL facilities;
    7. the number of premises passed by both FTTN and legacy DSL facilities;
    8. the penetration of the FTTP service calculated by dividing the number of FTTP service subscribers by the number of premises passed by FTTP facilities.
  2. In areas that the company has deployed FTTP in a neighbourhood, indicate whether the company has continued to provide the following over the existing copper-based access infrastructure (including FTTN and legacy DSL) in that neighbourhood.
    1. both retail Internet services and wholesale high-speed access (HSA) services;
    2. retail Internet services but not wholesale HSA services;
    3. wholesale HSA services but not retail Internet service

Further, for a), b) and c) above, provide explanations for why the company does or does not continue to provide retail Internet services and/or wholesale HSA services over FTTN and legacy DSL facilities where it has deployed FTTP access facilities.

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province:
    1. the number of premises passed by copper access lines;
    2. the number of premises passed by both copper access lines and FTTP facilities;
    3. for premises passed by both FTTP facilities and copper access lines, provide the following:
      1. the total number of premises passed for which both retail internet services and wholesale high-speed access (HSA) access services over copper access lines are not available;
      2. the total number of premises passed for which retail internet services over copper access lines are available but wholesale HSA access services over copper access lines are not available;
      3. the total number of premises for which wholesale HSA access services over copper access lines are available but retail internet services over copper access lines are not available.
  2. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province, by wholesale HSA customer, broken down by aggregated and disaggregated services:
    1. the total wholesale HSA year-end Internet service end-users and the associated revenues by access technology (i.e., FTTP, FTTN, and Legacy DSL);
    2. For each of FTTP, FTTN, and legacy DSL facilities, for each speed band, a breakdown of the wholesale HSA year-end Internet service end-users and associated revenues.
  3. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province;
    1. the measured all carrier average year-end peak period downstream usage per end-user by service speed in Mbps;
    2. the supporting rationale and methodologies used to measure the peak period downstream usage per end-user.

Cogeco, Eastlink, Rogers, Shaw, Videotron

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province:
    1. total number of premises passed by FTTP and hybrid fibre coaxial (HFC) facilities;
    2. the number of premises passed only by FTTP facilities;
    3. the number of premises passed only by HFC facilities;
    4. the penetration of the FTTP service calculated by dividing the number of FTTP service subscribers by the number of premises passed by FTTP facilities.
  2. In areas that the company has deployed FTTP in a neighbourhood, indicate whether the company has continued to provide the following over the existing HFC access infrastructure in that neighbourhood.
    1. both retail Internet services and wholesale high-speed access (HSA) services;
    2. retail Internet services but not wholesale HSA services;
    3. wholesale HSA services but not retail Internet service.

Further, for a), b) and c) above, provide explanations for why the company does or does not continue to provide retail Internet services and/or wholesale HSA services over HFC facilities where it has deployed FTTP access facilities.

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province;
    1. the number of premises passed by HFC access lines;
    2. the number of premises passed by both HFC access lines and FTTP facilities;
    3. for premises passed by both FTTP facilities and HFC access lines, provide the following:
      1. the total number of premises passed for which both retail internet services and wholesale high-speed access (HSA) access services over HFC access lines are not available;
      2. the total number of premises passed for which retail internet services over HFC access lines are available but wholesale HSA access services over HFC access lines are not available;
      3. the total number of premises for which wholesale HSA access services over HFC access lines are available but retail internet services over HFC access lines are not available.
  2. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province, by wholesale HSA customer, broken down by aggregated and disaggregated services:
    1. the total year-end wholesale HSA service end-users and the associated revenues by access technology (i.e. FTTP and HFC);
    2. For each of FTTP and HFC facilities, for each speed band, a breakdown of the year-end wholesale HSA service end-users and associated revenues.
  3. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province;
    1. the measured all carrier average year-end peak period downstream usage per end-user by service speed in Mbps;
    2. the supporting rationale and methodologies used to measure the peak period downstream usage per end-user.

Bell Canada, Bell MTS, Cogeco, Eastlink, Rogers, Shaw, Videotron

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, by province, by wholesale HSA customer, the total wholesale HSA year-end demand and the associated revenues for 100 Mbps capacity increments.

Bell Canada, Bell MTS, Bell Aliant, Cogeco, Eastlink, Rogers, SaskTel, Shaw, TCI, Videotron

  1. For each of the years 2018 to 2022 as well as forecasts for each of the years 2023 and 2024, separately and for each brand and division your company or an affiliate operates (including Flankers), provide (using the Excel spreadsheet template in appendix 3) your total broadband wireline retail internet revenues and subscribers by access technology (DSL, FTTN, FTTP, HFC, etc.).
  2. For each of the years 2018 to 2022 as well as forecasts for each of the years 2023 and 2024, separately and for each brand and division your company or an affiliate operates (including Flankers), provide (using the Excel spreadsheet template in appendix 3) your broadband wireline retail internet total operating expenses and total earnings before interest, taxes, depreciation, and amortization (EBITDA).
  3. With respect to investment in your company’s broadband network, provide (using the Excel spreadsheet template in appendix 3) the following, by province:
    1. For each of the years 2018 to 2022 as well as forecasts for each of the years 2023 and 2024, a breakdown of the total capital expenditures attributed to your broadband network;
    2.  For each of the years 2018 to 2022 as well as forecasts for each of the years 2023 and 2024, a breakdown of the total capital expenditures and premises passed associated with the rollout of your FTTP network;
    3. For each of the years 2018 to 2022, the total amount of public funding dedicated to broadband network investments, and the rollout of your FTTP network, broken down by the sources of funding (e.g., Municipal, provincial, federal, CRTC contribution fund);  
    4. If applicable, forecasted annual public funding for 2023 and 2024.

Appendix 2 – NoC 2023-56 Requests for Information #1b –additional information on broadband internet industry

Bell Canada, Bell MTS, Bell Aliant, Cogeco, Eastlink, Rogers, SaskTel, Shaw, TCI, Videotron

  1. For each of the years 2018 to 2022 and forecast years 2023 and 2024, for each brand and division your company operates (including Flankers or affiliates), broken down first by province and then by Canadian CMAs (as defined by StatsCanFootnote1 ), by speed tier and by technology, provide (using the Excel spreadsheet template attached in appendix 4):
    1. The retail revenues and number of subscribers;
    2. The average revenue per user (ARPU).
    3. A list of the retail internet service plans offered (including data caps, if applicable);
  2. For each of your retail internet service plans, for each of the years 2018 to 2022, and for each brand and division your company or an affiliate operates (including Flankers), broken down by Canadian CMAs (as defined by StatsCan) and by speed tier, provide (using the Excel spreadsheet template attached in appendix 4):
    1. The corresponding stand-alone average monthly retail Internet rate and number of subscribers. If the company offers different stand-alone rates in different regions of a CMA or non- CMA, define these regions, and provide their corresponding rates;
    2. The corresponding bundled average monthly retail Internet rates and number of subscribers (e.g., bundle A for 2 services, bundle B for 3 service, etc.). If your company offers different bundled rates in different regions of a CMA, or non-CMA define these regions, and provide their corresponding rates;
  3. With respect to the retail internet service plans identified in responses 2 a) and b) above:
    1. Explain how your company allocates discounts off advertised prices when a bundle of services are purchased by customers;
    2. Provide (using the Excel spreadsheet template attached in appendix 4) all the changes made to the monthly retail rates throughout each year, identifying those changes that reflect the introduction or conclusion of a promotional offer (specify the dates of the changes);
    3. Provide (using the Excel spreadsheet template attached in appendix 4) the average monthly advertised promotional rate and the average monthly unadvertised promotional rate charged to your customers and associated average number (and percentage) of subscribers ,
    4. Provide (using the Excel spreadsheet template attached in appendix 4) the average monthly rate charged to customers newly subscribing to your services and associated average number (and percentage) of subscribers. Further, provide the average percentage discount that you offer new customers relative to the average rate charged to existing customers;
    5. Provide (using the Excel spreadsheet template attached in appendix 4) the average monthly “winback” rate charged to win back customers that have cancelled or indicated an intention to cancel subscriptions and the associated average number (and percentage) of subscribers. Further, provide the average percentage discount that you offer winback customers relative to the average rate charged to existing customers.

TekSavvy, Vmedia, Ebox, and Distributel, Start, Altima, City Wide and other smaller ISPs

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet:
    1. the number of retail Internet service customers you serve using wholesale HSA services provided by each ILEC, by province, by speed band, and by network (i.e. FTTP, FTTN, or legacy DSL facilities);
    2. the number of 100 Mbps capacity increments that you purchase by ILEC and by province (where applicable);
    3. the total amounts paid for retail Internet service customers you serve using wholesale HSA services provided by each ILEC, by province, by speed band, and by network (i.e. FTTP, FTTN, or legacy DSL facilities);
    4. the total amounts paid to each ILEC, by province, for the 100 Mbps capacity increments (if applicable);
    5. the number of retail Internet service customers you serve using the wholesale HSA services provided by each Cable Carrier, by speed band, and by network (i.e. HFC, FTTP facilities);
    6. the number of 100 Mbps capacity increments that you purchase by Cable Carrier and by province (where applicable);
    7. the total amounts paid for retail Internet service customers you serve using the wholesale HSA services provided by each Cable Carrier, by speed band, and by network (i.e. HFC, FTTP facilities);
    8.  the total amounts paid to each Cable Carrier, by province, for the 100 Mbps capacity increments (if applicable);
    9. the number of retail Internet service customers you serve by leveraging another wholesale-based ISP that acts an aggregator/intermediary between you and the wholesale provider, provided by each wholesale-based ISP, by province, by speed band, and by network type (i.e. FTTP, FTTN, HFC, or legacy DSL facilities) (where applicable);
    10. the total amounts paidto these wholesale-based ISPs, by province and by speed band, to support your provision of retail Internet services to end-customers (where applicable).
  2. Describe the methodology the company uses to determine the number of 100 Mbps capacity increments it requires the address the number of subscribers and their peak period usage requirements.
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