O Canada! > Canadian > Canadian Broadband > CNOC's Part 1 Filing on the 703/704 tariffs

reply to Ott_Cable

Re: CNOC's Part 1 Filing on the 703/704 tariffs

Unexpected twist from my buddies at Bell today

In the email:

quote:

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1 February 2012 - The Companies

Description:
In light of the fact that all parties must be able to comment and reply with regard to these new issues, and in order to avoid the creation of yet another parallel proceeding on issues related to the implementation of CBB, the Companies request that: in addition to the issues raised in CNOC's Application, all parties, including CNOC, be requested to comment by 13 February 2012 (instead of 6 February 2012) on the appropriateness of a) parallel regimes which ISPs can choose to be billed in accordance with, and b) the 10 percent reduction of the business rate access charges. The Companies further request that all parties have a right of reply 10 days following comments on these issues.

File name:
120201-The Comp-CNOC Part 1-Process Letter.doc (73 KB)

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The enclosed letter:

quote:

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2012 02 01

To: Mr. John Traversy
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
K1A 0N2

Subject: Canadian Network Operators Consortium Inc. (CNOC) Part 1 Application requesting expedited relief to address implementation of the capacity model approved in Telecom Regulatory Policy CRTC 2011-703 – The Companies’ request for a change in process in light of new implementation models proposed by the Commission in Telecom Decision CRTC 2012-60, Implementation date for the wholesale high-speed access services capacity model approved in Telecom Regulatory Policy 2011-703 (Decision 2012-60)

Dear Mr. Traversy,

On 15 November 2011 the Commission issued Telecom Regulatory Policy CRTC 2011703, Billing practices for wholesale residential high-speed access services (TRP 2011-703) in which the Commission mandated the implementation of a capacity-based billing (CBB) model by 1 February 2012, less than three months following the Commission’s decision. Bell Canada and Bell Aliant Regional Communications, Limited Partnership (collectively, the Companies) proposed to implement the Commission’s decision in such a way that would allow independent Internet service providers (ISPs) to segregate their residential traffic from their business traffic through realm splitting. CNOC filed a Part 1 Application on 4 January 2012 claiming that the Companies’ proposed implementation of TRP 2011-703 was unreasonable and proposing an alternative means of implementation through the use of dynamic RADIUS and requesting an expedited process for its Application in light of the 1 February 2012 implementation deadline. On 6 January 2012 the Commission rejected CNOC’s request for an expedited process, ruling that the standard process with 30 days for answers and interventions and 10 days for reply is maintained. The Commission also requested comments with regard to the appropriateness of the 1 February 2012 deadline and requested parties to comment on the following options:

i. maintain the terms and conditions of the respondents’ tariffs as final with implementation on 1 February 2012;
ii. make these terms and conditions interim as of 1 February 2012; or
iii. delay the implementation date for the capacity model until the Commission has resolved CNOC’s Application.

On 27 January 2012 the Commission issued Telecom Decision CRTC 2012-60, Implementation date for the wholesale high-speed access services capacity model approved in Telecom Regulatory Policy 2011-703 (Decision 2012-60) in which it requires the Companies to maintain their proposed implementation of TRP 2011-703 by 1 February 2011 and also to:

a. Allow independent ISPs to use a single realm to support both residential and business traffic. Independent ISPs would be required to purchase the appropriate capacity in 100 megabits per second increments to carry their combined residential and business traffic using the rates for the approved capacity model.
b. Allow independent ISPs an initial order for the capacity to carry the combined residential and business traffic required on the implementation date at no charge.
c. Provide compensation to independent ISPs to recognize the potential double-counting for business usage through a reduction set at 10 percent of the monthly business rate access charges for independent ISPs.

In effect, the Commission has introduced a new model to be managed in parallel with the Companies own proposed means of implementing TRP 2011-703 and requires the Companies to allow ISPs to choose to be billed in accordance with one or the other. The Companies suspect that other parties, including CNOC, will likely wish to comment on the appropriateness of: a) parallel regimes which ISPs can choose to be billed in accordance with, and b) the 10 percent reduction of the business rate access charges as a longer term solution. However, under the current process, parties can comment on the issues raised in CNOC’s Application and only CNOC has a final right of reply 10 days later. This process would unfairly advantage CNOC should CNOC and parties to CNOC’s Part 1 Application choose to address the issues raised above as only CNOC would have a right of reply and other parties would be denied the right to address new arguments raised during the comment or final reply stage of CNOC’s Part 1 Application.

In light of the fact that all parties must be able to comment and reply with regard to these new issues, and in order to avoid the creation of yet another parallel proceeding on issues related to the implementation of CBB, the Companies request that: in addition to the issues raised in CNOC’s Application, all parties, including CNOC, be requested to comment by 13 February 2012 (instead of 6 February 2012) on the appropriateness of a) parallel regimes which ISPs can choose to be billed in accordance with, and b) the 10 percent reduction of the business rate access charges. The Companies further request that all parties have a right of reply 10 days following comments on these issues.

Yours truly,

[ Original signed by P. Gauvin ]

Philippe Gauvin
Counsel - Regulatory Law and Policy
Bell Canada

c.c: Parties to TNC 2011-77
Martin Brazeau, CRTC
Lynne Fancy, CRTC
Yvan Davidson, CRTC

PG/sm
*** End of Document ***

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This is just a placeholder post to keep this topic active. Next week, it should get some activity because the deadline for final replies is now March 28th.

here is a true gem from the cable company's Feb 13 filing:

quote:

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8. The Cable Carriers suspect that the true purpose of CNOC’s Application is to revise the capacity model approved in TRP 2011-703 so that the wholesale ISP customer only has to order, and pay for, the capacity it will actually use and no more.

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Reading the march 8th responses. CNOC has been a bad boy and have purchased wholesale volumes of "#" from Bell for their filing....

quote:

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Pursuant to section 39 of the Telecommunications Act, the network details of the three CNOC members that have elected to provide responses to the Commission’s request for information are being filed in confidence with the Commission. The information in question is of a competitively sensitive nature to the three CNOC members.

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Is this the ISP I can't name or Acanac/Distributel ?

quote:

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Large Independent ISP
A) The company uses the services of a number of incumbents in order to provide service to its end users. For the purpose of responding to this question, the company is focusing on those incumbents that have adopted the capacity method approved in TRP 2011-703.

Bell Canada: The company interconnects with Bell Canada through 23 1 Gbps AHHSPIs mapped to EAS links according to a 1 to 1 relationship. This arrangement provides the company access to end users encompassed by Bell Aliant’s/Bell Canada’s entire footprint in Ontario and Quebec.

Rogers: The company interconnects to Rogers using 4 10 Gbps links that are mapped into 37 VLANs that connect to a total of 19 POIs. This arrangement provides the company access to end users encompassed by these Rogers POIs.

Cogeco: The company has 1 Gbps # link to one POI in Cogeco’s serving territory. This arrangement provides the company access to end users encompassed by the Cogeco area served by that single POI.

Videotron: The company has 1 Gbps connection to Videotron’s main aggregation POI in Montreal. This arrangement provides the company access to end users encompassed by Videotron’s entire footprint.

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reply to jfmezei
Cogeco says it uses ECMP (Equal Cost MultiPath) to distribute upstream traffic amongst the number of links that exist to the ISP and that this provides load balancing as well as automated failover.

Can anyone comment on ECMP ? Wikipedia does not have nice things to say about it.

Anything preventing ISPs from using the same for the downstrieam traffic (from ISP to the cableco) ?

Also, assuming that the lan extensions between the caleco and the ISP are terminated by switches, with ECMP, how would a router know that one of 4 links has gone down ?

reply to InvalidError

Anyone able to post incumbent replies from yesterday?

I just checked the file, the last document posted was from CNOC on the 21st.

The incumbent replies from yesterday were about tariffs on service charges (5 different processes)

Today is the deadline for the CNOC Part 1 final replies. Tey should be pouring in later today.

I'll try to post the replies. I really have not had the time to read any of them. and today I have to do the replit to Shaw's R&V. There are deadlines every day for some time now, with some days having multiple deadlines.