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Telecom - Staff letter addressed to the Distribution List

Ottawa, 10 July 2023

Reference: 1011-NOC2023-0056

BY EMAIL

Distribution List

Subject: Telecom Notice of Consultation 2023-56 – Further Requests for Information

Attached to this letter are further requests for information (RFIs) issued within the context of the proceeding initiated by Telecom Notice of Consultation CRTC 2023-56. Responses to the RFIs are due no later than 14 August 2023. Staff may issue additional RFIs over the course of the proceeding.
Recipients are to respond to the questions in the appendix to this letter that are addressed to them, with their responses to be filed with the Commission and served on the persons included in the distribution list below. These responses must be received, not merely sent, by the date mentioned above.

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.

Pursuant to paragraph 39(4)(b) of the Telecommunications Act and the request of the Commissioner of Competition (the “Commissioner”) dated 4 May 2023, complete responses to questions 1, 2, and 4, including all information designated as confidential, are also to be provided to the Commissioner at the time that they are filed with the Commission.

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 [21] August 2023. Responses to those disclosure requests may then be filed with the Commission no later than [23] August 2023.

Sincerely,

Original signed by Jeremy Lendvay for

Philippe Kent
Director, Telecommunications Services Policy
Telecommunications Sector

c. c.

Peter Keriakos, CRTC, peter.keriakos@crtc.gc.ca
Greg Lang, CRTC, greg.lang@crtc.gc.ca
Adam Mills, CRTC, admin.mills@crtc.gc.ca
Chris Roy, CRTC, christopher.roy@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.com;
Shaw, Regulatory@sjrb.ca;
TCI, regulatory.affairs@telus.com;
Videotron, regaffairs@quebecor.com;
CNOC, regulatory@cnoc.ca;
Community Fibre, ben@communityfibre.ca;
Comwave, legal@comwave.net;
Public Interest Advocacy Centre, jlawford@piac.ca;
TekSavvy, regulatory@teksavvy.ca;
Vaxination Informatique, jfmezei@vaxination.ca;
John Roman, johnphiliproman@gmail.com;
WaveDirect Telecommunications Limited, joanne@wavedirect.org;
Vaxxine Computer Systems Inc., president@vaxxine.com;
Truespeed Internet Services Inc., adam@truespeed.ca;
SkyChoice Communications, serge@skychoice.ca;
Securenet, info@securenet.net;
Secure by Design, kirk@secure-by-design.com;
OpenMedia, erin@openmedia.org;
Netrevolution inc., drouleau@gtvr.com;
National Capital FreeNet, execdir@ncf.ca;
IGS Hawkesbury Inc., jbogue@hawkmail.ca;
First Mile Connectivity Consortium, info@firstmile.ca;
Devtel Communications Inc., devin@devtelcommunications.ca;
CPC, campbell@campbellpatterson.com;
Canadian Anti-Monopoly Project (CAMP), keldon@antimonopoly.ca;
Beanfield, todd@beanfield.com;
Marc Nanni, mn_crtc@proton.me;
Competition Bureau, Conor.Parson@cb-bc.gc.ca;
Competition Bureau, crtc2023-56@cb-bc.gc.ca;
Coextro, skhandor@coextro.com;
Carry Telecom, frankw@carrytel.ca;
Execulink, yasmin.charania@execulinktelecom.ca;
Frontier Networks, cgooey@frontiernetworks.ca;
Citywide, david@yourcitywide.com;
CIK Telecom, jordan.d@ciktel.com;
British Columbia Broadband Association (BCBA), regulatory@bcba.ca

Appendix 1 – NoC 2023-56 Requests for Information #2

Bell Canada, Bell MTS, Bell Aliant, TCI, and SaskTel (ILECs)

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, broken down by Canadian Census Metropolitan Areas (CMA, as defined by Statistics CanadaFootnote1), by wholesale high speed access (HSA) customer, and by aggregated and disaggregated services:
    1. the total year-end wholesale HSA service end-users and the associated revenues by access technology (i.e., Fibre to the premise (FTTP), fibre to the node (FTTN), and legacy Digital Subscriber Line (DSL)); and
    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.
    • If data is not available at the CMA level, provide data at an appropriate lower level of aggregation that your company tracks (e.g., by postal code, central office, etc.). In such circumstances, provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level.

Cogeco, Eastlink, Rogers, Shaw, and Videotron (Cablecos)

  1. For each of the historical years 2018 to 2022 and forecast years 2023 and 2024, provide, in tabular form in an Excel spreadsheet, broken down by Canadian CMAs, by wholesale HSA customer, and 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 Hybrid Fibre Cable (HFC)); and
    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.
    • If data is not available at the CMA level, provide data at an appropriate lower level of aggregation that your company tracks (e.g., by postal code, head end, etc.). In such circumstances, provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level.
  2. Explain how the company is evolving its network to provide higher speeds (both upload and download) to compete against FTTP networks. If the company is deploying DOCSIS 4.0 anywhere in its network, provide an overview of the company’s strategy, coverage, and timelines for this deployment, and explain how DOCSIS 4.0 is expected to assist the company in competing against FTTP networks. Moreover, explain the company’s strategy, coverage, and timelines for the deployment of FTTP in its network.

Bell Canada (Distributel, EBOX), Cogeco (Oxio), TELUS (Altima, Start),  Videotron (Vmedia), TekSavvy, City Wide, CIK Telecom, Execulink Telecom, Beanfield Technologies, Vianet, Zayo Canada, Carry Telecom, Comwave, Frontier Networks, Wavedirect Telecom and other smaller ISPs

  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 AffiliatesFootnote2), broken down first by province and then by Canadian CMAs, by speed tier and by technology, provide (using the Excel spreadsheet template attached in appendix 2) :
    1. total annual retail revenues and number of subscribers;
    2. the average revenue per user (ARPU); and
    3. a list of the retail wireline Internet service plans offered, and the underlying wholesale provider(s) associated with those plans (including data caps, if applicable).
    • If data is not available at the CMA level, provide data at an appropriate lower level of aggregation that your company tracks (e.g., by postal code, central office, head end, etc.). In such circumstances, provide a description and any relevant maps detailing how the data provided can be reasonably aggregated to a CMA level.
  2. Indicate whether you currently offer, or have plans to offer, services in addition to retail wireline Internet, local home phone, or television, such as home security/monitoring or mobile wireless.
  3. Describe any plans or strategies you have to offer retail wireline Internet services in parts of Canada that you do not currently serve. If there are parts of Canada that you currently do not serve, describe the reasons why you have not expanded to those areas.
  4. Provide copies of any business plans or other formal assessments you have created since 1 January 2020 relating to expansion or contraction of the areas that you provide retail wireline Internet service in Canada.

ILECs and Cablecos

  1. Provide a list of all companies who provide retail wireline Internet services to end users in Canada that you, or an Affiliate, have established control over or a significant interest in all or part of, since 1 January 2020.
  2. For each of the entities listed in your response to [Q8], describe how their product offerings and target end users differ from those of your company, flanker brands or Affiliates.
  3. Provide a copy of all agreements between your company, or an Affiliate, and other companies currently using your network to provide retail wireline Internet services to end users.
  4. For the historical years 2020 to 2022, provide a copy of all off-tariff agreements in respect of retail wireline Internet services to which you are or were a party. Furthermore, complete the following table:
    Name of Provider (i.e., parent company, flanker brand, or Affiliate) Name of provider (i.e., parent company, flanker brand, or Affiliate) with whom the agreement is, or was, held Identify the period of time for which the off-tariff agreement was valid for, including months and years, where possible List number of off-tariff agreements entered into Identify the service for which each off-tariff agreement corresponds to Identify the geographic market(s) for which these agreements are in place. Information should be organized by city or region, followed by the province or territory
               
  5. For the historical years 2020 to 2022, provide the percentage of total wholesale HSA revenue that was earned pursuant to an off-tariff agreement.

ILECs, Cablecos, and Wholesale-Based ISPs

  1. Provide your current total number of:
    1. stand-alone retail wireline Internet subscribers;
    2. retail wireline Internet subscribers that also subscribe to local home phone services;
    3. retail wireline Internet subscribers that also subscribe to television services; and
    4. retail wireline Internet subscribers that also subscribe to both local home phone and television services.
  2. Provide a list of all companies who provide retail wireline internet services in Canada that you, or an Affiliate, have held formal discussions with for the purpose of negotiating a MergerFootnote3, since 1 January 2020. For each company listed, indicate the timeframe and the status of those discussions.
  3. Comment on how the Commission and the public should be informed of Mergers in the Canadian telecommunications services industry. Identify the terms and conditions of a Merger that should be disclosed to: (a) the Commission and (b) the public.
  4. Indicate whether any of the retail wireline Internet service plans offered by your companies include monthly data caps and indicate the total number of subscribers that currently subscribe to such plans. Comment on the continued appropriateness of applying data caps to any retail wireline Internet services. Describe the rationale for any such caps, including whether there are any economic or network management justifications for their continued application.
  5. Describe how and why your rates vary from customer to customer within specific geographic areas. For example, discuss whether and how customers living within the same province, city, or postal code may be offered different rates for the same service. If so, explain the factors that influence the differential charges.
  6. Provide an explanation of the company’s strategies to identify and win back retail customers that have cancelled subscriptions. Disclose whether the company has different win-back strategies for customers that have left for other incumbents versus wholesale-based competitors and, if so, describe such strategies.
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