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29 April 2011 Our Reference: 8663-C12-201102350
BY E-MAIL
To: Distribution List
Re: Request for information – Telecom Notice of Consultation CRTC 2011-77,
Review of billing practices for wholesale residential high-speed access services
(NoC 2011-77), as amended by NoC 2011-77-1 and NoC 2011-77-2
Dear Madam or Sir:
Pursuant to the process specified in paragraph 22 of NoC 2011-77-2, attached are
Commission interrogatories associated with this proceeding.
The following parties are requested to provide responses to the attached interrogatories: Bell
Aliant Regional Communications, Limited Partnership and Bell Canada (together, the Bell
companies); MTS Allstream Inc.; TELUS Communications Company; Cogeco Cable Inc.,
Quebecor Media Inc. on behalf of its affiliate Videotron Ltd., Rogers Communications Inc.,
(collectively, the cable carriers); Shaw Communications Inc.; and the Canadian Network
Operators Consortium (CNOC).
Pursuant to the process set out in paragraph 23 of NoC 2011-77-1, parties are to file their
responses with the Commission, serving copies on all other parties, by 24 May 2011. These
responses are to be received, and not merely sent, by this date.
Copies of the documents should also be sent to Tom Vilmansen ([email protected]),
Richard Pagé ([email protected]), and Mohammed Omar
Yours sincerely,
Lynne Fancy
Director General
Competition, Costing and Tariffs
Telecommunications
2
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art.com; [email protected]; [email protected]; [email protected];
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3
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[email protected]; [email protected]; [email protected];
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[email protected]; [email protected]; [email protected];
4
Interrogatories to Bell Aliant Regional Communications, Limited Partnership and Bell
Canada (together, the Bell companies)
1. In their intervention dated 28 March 2011, the Bell companies proposed the
introduction of Aggregated Volume Pricing (AVP) for their residential Gateway
Access Services (GAS - both legacy and FTTN). Under the AVP proposal, a
wholesale customer of GAS would be billed for the monthly aggregated usage of its
end-users.
a. Explain in detail how the Bell companies would measure the monthly
aggregated volumes for each wholesale customer of GAS under their AVP
proposal.
b. Describe to what degree measurement can be duplicated by the wholesale
customer of GAS to facilitate billing reconciliation.
c. Provide the Bell companies‟ justification for their proposed markups for the
AVP component of their proposal.
2. If the proposed AVP model was implemented,
a. describe how the proposed AVP model will address the problem of network
congestion during peak periods;
b. specify the effect of the proposed AVP model on end-user usage. The
response should provide five-year forecasts starting at 2011 for i) average
monthly per end-user usage by year for residential GAS service under the
existing rate structure ii) average monthly per end-user usage by year under
the proposed AVP model;
c. if the proposed AVP model was modified so that wholesale customers of GAS
paid for total volume generated in a month at a rate of $.195 per GB, provide a
five-year forecast starting at 2011 for average monthly per end-user usage by
year for residential GAS service under the modified model;
d. explain how the proposed rates for the AVP model accommodate the impact
of ongoing changes in end-user behaviour (e.g. increased monthly traffic
volumes, increased traffic during peak periods, changes in the ratio of total
traffic volume to peak traffic ). The response should address any
requirements for ongoing adjustments to rates, with supporting rationale.
5
3. In their proposed AVP model, the Bell companies proposed that each wholesale
customer of GAS be given an aggregated traffic volume credit in proportion to their
legacy usage, in recognition that usage was included in the access costs associated
with legacy GAS services, specifically those costs submitted in the cost study filed on
16 July 2009 in Bell Canada TN 7181 and Bell Aliant TN 242
(as adjusted by the Commission in Decision 2010-255).
a. Provide the Bell companies‟ views, with supporting rationale, on an AVP
model in which the access rates for the legacy residential GAS services would
be based on costs excluding usage-driven costs (i.e. the same model as that
proposed for FTTN-based GAS ).
b. For the Bell companies 16 July 2009 cost study referenced above, using the
format of tables 1 to 5, provide a breakdown of the legacy residential GAS
services costs into (i) access excluding usage-driven costs and (ii) usage-
driven costs, with supporting assumptions and rationale.
4. Where certain speed tiers of GAS can be provided by either legacy technology or
FTTN technology, comment on the feasibility of a harmonized rate for these speed
tiers.
5. In its intervention dated 28 March 2011, CNOC proposed a pricing model where
usage would be aggregated and charged on a per wholesale customer basis and
submitted that wholesale customers would have to pay for any peak traffic that their
users cause in the aggregate on incumbent networks. CNOC further submitted that
measurement of a wholesale customer‟s monthly use of the network should be done
on a 95th
percentile basis.
Assuming that the Bell companies were to offer their residential GAS services based
on CNOC's proposed pricing model,
a. describe how and where in the network the Bell companies would measure,
for billing purposes, the monthly peak traffic caused by the end-users of each
wholesale customer.
b. specify how much elapsed time would be required to implement CNOC‟s
model. The response should identify the additional activities that the Bell
companies would have to undertake and the time required for each activity.
6
c. specify whether the Bell companies use the 95th
percentile measurement
approach in determination of peak traffic in any of its services or in any of
their provisioning practices. If yes, identify the services and describe the
provisioning practices. If no, describe the approach the Bell companies use
for measuring peak traffic in their networks that support high-speed access
services.
6. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided
Chart B3 entitled “Internet Usage by Time of Day – North America 2010”. The chart
provided i) the level of traffic per end-user as a percentage of the maximum level of
traffic per end-user by time of day and ii) the number of end-users that are connected
as a percentage of the maximum number of end-users that are connected by time of
day.
Indicate whether this chart is representative of the daily Internet usage of the Bell
companies‟ end-users. If not, provide an equivalent chart for the Internet usage by
time of day for the Bell companies‟ end-users. The response should specify whether
the provided information is for retail end-users only or for both retail and wholesale
end-users combined.
7. In their intervention dated 28 March 2011, the Bell companies provided in
confidence, an estimate of the projected 2011 investment required to reduce
congestion to acceptable levels (i.e. network capacity relief) in their networks
supporting high-speed access. Explain how the Bell companies determined their
estimate of this projected 2011 investment. The response should identify the network
components included and the methodology and assumptions used, with supporting
rationale.
8. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network congestion of the ISP operators‟ networks. In this proceeding, parties have
also commented on the need to demonstrate the existence of congestion within the
networks. As such, questions a), b), and c) below are substantially the same as those
posed in PN 2008-19.
a) How does the company define congestion in the networks it uses to provide
broadband Internet services? What criteria and measurements are used to
determine that there is congestion in the company‟s networks?
7
b) Have the company‟s congestion criteria changed between 2008 and 2011? If so,
explain how they have changed.
c) Describe which components (e.g. network elements or links) of the company‟s
networks, used to provide broadband Internet services, are provisioned based on
Internet traffic volumes. The discussion should include a general description of
the architecture of the company‟s networks.
d) If congestion is currently present in the company‟s network, provide quantitative
evidence of such congestion. Using the components identified in the response to
part c) above, specify when this congestion occurs, how many components by
type are affected, what proportion of the total components by type are affected, as
well as how often congestion is being experienced (i.e. what % of the time
elements are experiencing congestion).
9. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network provisioning of the ISP operator‟s networks. As such, questions a) and b)
and c) below explore the same subject matter
a) For each component identified above in question 8 c), describe the practices that
the company employs to provision its networks. The answer should include a
description of the conditions under which the company would augment its
network capacities to address congestion. Describe in detail the process used to
identify when and where additional network capacity is required and how the
additional capacity requirements are determined.
b) For each component identified in question 8 c), specify the amount of time
required to increase capacity of the component in the company‟s network, taking
into account the time that elapses between identification of a need to add capacity
for the component and the subsequent ordering, provisioning, installation, testing
and activation of the additional capacity.
c) Describe any major changes to the company‟s provisioning practices for the years
2008 to 2011. The response should include details on any changes in
provisioning assumptions.
d) With respect to other company services being offered using a common network
(e.g. managed services such as IPTV services over xDSL networks),
8
i. describe the differences between the company‟s managed services and
Internet services that have led the company to separate them. Clearly
define the parameters used to distinguish its managed services from its
Internet services,
ii. explain how the company separates its managed services from its Internet
services,
iii. explain how such services are planned and provisioned for in a common
manner. Explanations should include a description with diagrams
identifying which elements of the networks share common capacity, as
well as identifying elements of the network where capacity is provisioned
in a separate manner. For elements of the networks that share capacity
specify how much capacity is allocated to managed services and how
much capacity is allocated to Internet services.
e) With reference to the responses provided in question 8 d) and question 9 d),
explain why other services which are provisioned over the same network elements
do or do not contribute to network congestion, as well as how the company
determines whether to allocate additional capacity to either the Internet services
or the other services sharing the capacity.
9
Interrogatories to MTS Allstream Inc.
1. Refer to MTS Allstream‟s proposed Tariff Page for „Item 5830, Very High-Speed
Digital Subscriber Line (VDSL) Data Access Service‟, where the company provided
proposed monthly rates for 100 Mbps, 400 Mbps, and 1 Gbps Very High-Speed
Aggregated High-Speed Service Provider Interfaces (V-AHSSPI). Under this service
proposal a wholesale customer would interconnect at the V-AHSSPI to exchange
traffic with its end-customers, and would pre-purchase network traffic capacity
(increments of 100 Mbps, 400 Mbps, or 1Gbps) on a monthly basis. Provide
responses to the following:
a. Explain whether the company measures each competitor‟s traffic over its
network that supports wholesale high-speed access. If yes, describe how the
measurement is done, identifying the points in the network where the traffic is
measured.
b. If a competitor‟s end-users generate more traffic in aggregate than the level of
traffic purchased by the competitor under the proposed tariff for the
V-AHSSPI, explain whether the company would control or limit this traffic.
i. If the company controls or limits this traffic, explain how and at
what points in the network it controls the competitor‟s traffic flow.
ii. If the company does not control or limit the competitor‟s traffic,
explain what impact the additional traffic would have on the
company‟s network performance.
2. In its intervention dated 28 March 2011, CNOC proposed a pricing model where
usage would be aggregated and charged on a per wholesale customer basis and
submitted that wholesale customers would have to pay for any peak traffic that their
users cause in the aggregate on incumbent networks. CNOC further submitted that
measurement of a wholesale customer‟s monthly use of the network should be done
on a 95th
percentile basis.
a. Describe how the current model proposed by the company that charges
wholesale customers based on a pre-purchased level of aggregate monthly
traffic could be adapted to CNOC‟s proposed model. The response should
outline the major cost differences between the company‟s current model and a
model based on CNOC‟s proposed model along with changes in costing
assumptions, with rationale;
10
b. If the company was to offer its residential wholesale high-speed access service
based on CNOC's proposed model,
i. describe how and where in the network the company would measure,
for billing purposes, the monthly peak traffic caused by the end-users
of each wholesale customer. The response should indicate where
measurements would take place and what additional equipment or
software would be required to support the ongoing monthly
measurement; further, the response should provide an estimate of the
additional development costs (PWAC and MEC per end-user) the
company expects to incur to implement CNOC‟s model, along with
supporting costing assumptions and rationale.
ii. specify how much elapsed time would be required to implement
CNOC‟s model. The response should identify the additional
activities that the company would have to undertake and the time
required for each activity,
iii. specify whether the company uses the 95th percentile measurement
approach in determination of peak traffic in any of its services or in
any of its provisioning practices. If yes, identify the services and
describe the provisioning practices. If no, describe the approach the
company uses for measuring peak traffic in their networks that
support high-speed access services.
3. In their intervention dated 28 March 2011, the Bell companies provided in
confidence, an estimate of the projected 2011 investments required to reduce
congestion to acceptable levels (i.e. network capacity relief) in their network
supporting high-speed access, the revenues generated in 2010 from their residential
GAS customers and an estimate of their residential GAS revenues that would be
required to be spent for their proportion of congestion relief. Provide the following
information:
a. the company‟s projected 2011 investments required to reduce congestion in
the network supporting high-speed access. Explain how the company
determined its estimate of this projected investment. The response should
identify the network components included and the methodology and
assumptions used, with supporting rationale;
11
b. the revenues generated in 2010 for the company‟s wholesale aggregated
ADSL access service
c. the estimated proportion of revenues in response to b) that would be spent for
congestion relief
4. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided
Chart B3 entitled “Internet Usage by Time of Day – North America 2010”. The chart
provided i) the level of traffic per end-user as a percentage of the maximum level of
traffic per end-user by time of day and ii) the number of end-users that are connected
as a percentage of the maximum number of end-users that are connected by time of
day.
Indicate whether this chart is representative of the daily Internet usage of the
company‟s end-users. If not, provide an equivalent chart for the Internet usage by
time of day for the company‟s end-users. The response should specify whether the
provided information is for retail end-users only or for both retail and wholesale end-
users combined.
5. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network congestion of the ISP operators‟ networks. In this proceeding, parties have
also commented on the need to demonstrate the existence of congestion within the
networks. As such, questions a), b), and c) below are substantially the same as those
posed in PN 2008-19.
a) How does the company define congestion in the networks it uses to provide
broadband Internet services? What criteria and measurements are used to
determine that there is congestion in the company‟s networks?
b) Have the company‟s congestion criteria changed between 2008 and 2011? If so,
explain how they have changed.
c) Describe which components (e.g. network elements or links) of the company‟s
networks, used to provide broadband Internet services, are provisioned based on
Internet traffic volumes. The discussion should include a general description of
the architecture of the company‟s networks.
12
d) If congestion is currently present in the company‟s network, provide quantitative
evidence of such congestion. Using the components identified in the response to
part c) above, specify when this congestion occurs, how many components by
type are affected, what proportion of the total components by type are affected, as
well as how often congestion is being experienced (i.e. what % of the time
elements are experiencing congestion).
6. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network provisioning of the ISP operator‟s networks. As such, questions a) and b)
and c) below explore the same subject matter
a) For each component identified above in question 5 c), describe the practices that
the company employs to provision its networks. The answer should include a
description of the conditions under which the company would augment its
network capacities to address congestion. Describe in detail the process used to
identify when and where additional network capacity is required and how the
additional capacity requirements are determined.
b) For each component identified in question 5 c), specify the amount of time
required to increase capacity of the component in the company‟s network, taking
into account the time that elapses between identification of a need to add capacity
for the component and the subsequent ordering, provisioning, installation, testing
and activation of the additional capacity.
c) Describe any major changes to the company‟s provisioning practices for the years
2008 to 2011. The response should include details on any changes in
provisioning assumptions.
d) With respect to other company services being offered using a common network
(e.g. managed services such as IPTV services over xDSL networks),
i. describe the differences between the company‟s managed services and
Internet services that have led the company to separate them. Clearly
define the parameters used to distinguish its managed services from its
Internet services,
ii. explain how the company separates its managed services from its Internet
services,
13
iii. explain how such services are planned and provisioned for in a common
manner. Explanations should include a description with diagrams
identifying which elements of the networks share common capacity, as
well as identifying elements of the network where capacity is provisioned
in a separate manner. For elements of the networks that share capacity
specify how much capacity is allocated to managed services and how
much capacity is allocated to Internet services.
e) With reference to the responses provided in question 5 d) and question 6 d),
explain why other services which are provisioned over the same network elements
do or do not contribute to network congestion, as well as how the company
determines whether to allocate additional capacity to either the Internet services
or the other services sharing the capacity.
14
Interrogatories to TELUS Communications Company
1. In their intervention dated 28 March 2011, the Bell companies provided, in
confidence, an estimate of the projected 2011 investments required to reduce
congestion to acceptable levels (i.e. network capacity relief) in their networks
supporting high-speed access, the revenues generated in 2010 from their residential
GAS customers and an estimate of their residential GAS revenues that would be
required to be spent for their proportion of congestion relief. Provide the following
information:
a. the company‟s projected 2011 investment required to reduce congestion in the
network supporting high-speed access. Explain how the company determined
its estimate of this projected investment. The response should identify the
network components included and the methodology and assumptions used,
with supporting rationale;
b. the revenues generated in 2010 for the company‟s wholesale aggregated
ADSL access service;
c. the estimated proportion of revenues in response to b) that will be spent for
congestion relief
2. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided
Chart B3 entitled “Internet Usage by Time of Day – North America 2010”. The chart
provided i) the level of traffic per end-user as a percentage of the maximum level of
traffic per end-user by time of day and ii) the number of end-users that are connected
as a percentage of the maximum number of end-users that are connected by time of
day.
Indicate whether this chart is representative of the daily Internet usage of the
company‟s end-users. If not, provide an equivalent chart for the Internet usage by
time of day for the company‟s end-users. The response should specify whether the
provided information is for retail end-users only or for both retail and wholesale end-
users combined.
15
3. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network congestion of the ISP operators‟ networks. In this proceeding, parties have
also commented on the need to demonstrate the existence of congestion within the
networks. As such, Questions a), b), and c) below are substantially the same as those
posed in PN 2008-19.
a) How does the company define congestion in the networks it uses to provide
broadband Internet services? What criteria and measurements are used to
determine that there is congestion in the company‟s networks?
b) Have the company‟s congestion criteria changed between 2008 and 2011? If so,
explain how they have changed.
c) Describe which components (e.g. network elements or links) of the company‟s
networks, used to provide broadband Internet services, are provisioned based on
Internet traffic volumes. The discussion should include a general description of
the architecture of the company‟s networks.
d) If congestion is currently present in the company‟s network, provide quantitative
evidence of such congestion. Using the components identified in the response to
part c) above, specify when this congestion occurs, how many components by
type are affected, what proportion of the total components by type are affected, as
well as how often congestion is being experienced (i.e. what % of the time
elements are experiencing congestion).
4. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network provisioning of the ISP operator‟s networks. As such, questions a) and b)
and c) below explore the same subject matter
a) For each component identified above in question 3 c), describe the practices that
the company employs to provision its networks. The answer should include a
description of the conditions under which the company would augment its
network capacities to address congestion. Describe in detail the process used to
identify when and where additional network capacity is required and how the
additional capacity requirements are determined.
16
b) For each component identified in question 3 c), specify the amount of time
required to increase capacity of the component in the company‟s network, taking
into account the time that elapses between identification of a need to add capacity
for the component and the subsequent ordering, provisioning, installation, testing
and activation of the additional capacity.
c) Describe any major changes to the company‟s provisioning practices for the years
2008 to 2011. The response should include details on any changes in
provisioning assumptions.
d) With respect to other company services being offered using a common network
(e.g. managed services such as IPTV services over xDSL networks),
i. describe the differences between the company‟s managed services and
Internet services that have led the company to separate them. Clearly
define the parameters used to distinguish its managed services from its
Internet services,
ii. explain how the company separates its managed services from its Internet
services,
iii. explain how such services are planned and provisioned for in a common
manner. Explanations should include a description with diagrams
identifying which elements of the networks share common capacity, as
well as identifying elements of the network where capacity is provisioned
in a separate manner. For elements of the networks that share capacity
specify how much capacity is allocated to managed services and how
much capacity is allocated to Internet services.
e) With reference to the responses provided in question 3 d) and question 4 d),
explain why other services which are provisioned over the same network elements
do or do not contribute to network congestion, as well as how the company
determines whether to allocate additional capacity to either the Internet services
or the other services sharing the capacity.
17
Interrogatories to Cogeco Cable Inc., Quebecor Media Inc., on behalf of its
affiliate Videotron Ltd., Rogers Communications Inc. (collectively the cable
carriers)
Each cable carrier is to provide responses to the interrogatories
1. In their intervention dated 28 March 2011, the Bell companies provided in
confidence, an estimate of the projected 2011 investments required to reduce
congestion to acceptable levels (i.e. network capacity relief) in their network
supporting high-speed access, the revenues generated in 2010 from their residential
GAS customers and an estimate of their residential GAS revenues that would be
required to be spent for their proportion of congestion relief. Provide the following
information:
a. the company‟s projected 2011 investments required to reduce congestion in
the network supporting the company‟s TPIA service. Explain how the
company determined its estimate of this projected investment. The response
should identify the network components included and the methodology and
assumptions used, with supporting rationale;
b. the revenues generated in 2010 for the company‟s TPIA service;
c. the estimated proportion of revenues in response to b) that would be spent for
congestion relief;
2. In their intervention dated 28 March 2011, the cable carriers proposed a model with
aggregated usage-based billing on a per wholesale TPIA customer basis for their third
party Internet access (TPIA) services
a. Explain in detail how the company would measure the monthly aggregated
volumes for a wholesale TPIA customer under this proposal.
b. Describe to what degree measurement can be duplicated by the wholesale
TPIA customer to facilitate billing reconciliation.
c. Specify how much elapsed time would be required for the company to
implement the proposed model. The response should identify the additional
activities that the company would have to undertake and the time required for
each activity.
18
d. Provide the company‟s justification for its proposed rates for overage charges.
3. If the cable carriers‟ proposed aggregated usage model was implemented for the
TPIA service
a. Describe how the proposed aggregated usage model addresses the problem of
network congestion during peak periods
b. Specify the effect of the proposed aggregated usage model on the monthly
usage of end-users of the company‟s TPIA service. The response should
provide five-year forecasts starting at 2011 for i) the average monthly per end-
user usage by year for TPIA service under the existing rate structure ii) the
average monthly per end-user usage by year under the proposed aggregated
usage model.
c. explain how the proposed rates for the aggregated usage model take into
account the impact of ongoing changes in end-user behaviour (e.g. increased
monthly traffic volumes, increased traffic during peak periods, changes in the
ratio of total traffic volume to peak traffic). The response should address any
requirements for ongoing adjustments to rates, with supporting rationale.
4. In its intervention dated 28 March 2011, CNOC proposed a pricing model where
usage would be aggregated and charged on a per wholesale customer basis and
submitted that wholesale customers would have to pay for any peak traffic that their
users cause in the aggregate on incumbent networks. CNOC further submitted that
measurement of an ISP‟s monthly use of the network should be done on a 95th
percentile basis.
Assuming that the company was to offer its residential TPIA service based on
CNOC's proposed pricing model,
a. describe how and where in the network the company would measure, for
billing purposes, the monthly peak traffic caused by the end-users of each
wholesale TPIA customer;
b. specify how much elapsed time would be required to implement CNOC‟s
proposed model. The response should identify the additional activities that
the company would have to undertake and the time required for each activity;
19
c. specify whether the company uses the 95th
percentile measurement approach
in determination of peak traffic in any of its services or in any of its
provisioning practices. If yes, identify the services and describe the
provisioning practices. If no, describe the approach the company uses for
measuring peak traffic in its networks that support high-speed access services.
5. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network congestion of the ISP operators‟ networks. In this proceeding, parties have
also commented on the need to demonstrate the existence of congestion within the
networks. As such, questions a), b), and c) below are substantially the same as those
posed in PN 2008-19.
a) How does the company define congestion in the networks it uses to provide
broadband Internet services? What criteria and measurements are used to
determine that there is congestion in the company‟s networks?
b) Have the company‟s congestion criteria changed between 2008 and 2011? If so,
explain how they have changed.
c) Describe which components (e.g. network elements or links) of the company‟s
networks, used to provide broadband Internet services, are provisioned based on
Internet traffic volumes. The discussion should include a general description of
the architecture of the company‟s networks.
d) If congestion is currently present in the company‟s network, provide quantitative
evidence of such congestion. Using the components identified in the response to
part c) above, specify when this congestion occurs, how many components by
type are affected, what proportion of the total components by type are affected, as
well as how often congestion is being experienced (i.e. what % of the time
elements are experiencing congestion).
6. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network provisioning of the ISP operator‟s networks. As such, questions a) and b)
and c) below explore the same subject matter
a) For each component identified above in question 5 c), describe the practices that
the company employs to provision its networks. The answer should include a
description of the conditions under which the company would augment its
network capacities to address congestion. Describe in detail the process used to
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identify when and where additional network capacity is required and how the
additional capacity requirements are determined.
b) For each component identified in question 5 c), specify the amount of time
required to increase capacity of the component in the company‟s network, taking
into account the time that elapses between identification of a need to add capacity
for the component and the subsequent ordering, provisioning, installation, testing
and activation of the additional capacity.
c) Describe any major changes to the company‟s provisioning practices for the years
2008 to 2011. The response should include details on any changes in
provisioning assumptions.
d) With respect to other company services being offered using a common network
(e.g. managed services and cable television services over HFC networks),
i. describe the differences between the company‟s managed services
and Internet services that have led the company to separate them.
Clearly define the parameters used to distinguish its managed
services from its Internet services,
ii. explain how the company separates its managed services from its
Internet services,
iii. explain how such services are planned and provisioned for in a
common manner. Explanations should include a description with
diagrams identifying which elements of the networks share
common capacity, as well as identifying elements of the network
where capacity is provisioned in a separate manner. For elements
of the networks that share capacity specify how much capacity is
allocated to managed services and how much capacity is allocated
to Internet services.
e) With reference to the responses provided in question 5 d) and question 6 d),
explain why other services which are provisioned over the same network elements
do or do not contribute to network congestion, as well as how the company
determines whether to allocate additional capacity to either the Internet services
or the other services sharing the capacity.
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Interrogatories to Shaw Communications Inc.
1. In its intervention dated 28 March 2011, the Bell companies provided in confidence,
an estimate of the projected 2011 investments required to reduce congestion to
acceptable levels (i.e. network capacity relief) in their network supporting high-speed
access, the revenues generated in 2010 from their residential GAS customers and an
estimate of their residential GAS revenues that would be required to be spent for their
proportion of congestion relief. Provide the following information:
a. the company‟s projected 2011 investments required to reduce congestion in
the network supporting the company‟s TPIA service. Explain how the
company determined its estimate of this projected investment. The response
should identify the network components included and the methodology and
assumptions used, with supporting rationale;
b. the revenues generated in 2010 for the company‟s TPIA service;
c. the estimated proportion of revenues in response to b) that would be spent for
congestion relief
7. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided
Chart B3 entitled “Internet Usage by Time of Day – North America 2010”. The chart
provided i) the level of traffic per end-user as a percentage of the maximum level of
traffic per end-user by time of day and ii) the number of end-users that are connected
as a percentage of the maximum number of end-users that are connected by time of
day.
Indicate whether this chart is representative of the daily Internet usage of the
company‟s end-users. If not, provide an equivalent chart for the Internet usage by
time of day for the company‟s end-users. The response should specify whether the
provided information is for retail end-users only or for both retail and wholesale end-
users combined.
2. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network congestion of the ISP operators‟ networks. In this proceeding, parties have
also commented on the need to demonstrate the existence of congestion within the
networks. As such, questions a), b), and c) below are substantially the same as those
posed in PN 2008-19.
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a) How does the company define congestion in the networks it uses to provide
broadband Internet services? What criteria and measurements are used to
determine that there is congestion in the company‟s networks?
b) Have the company‟s congestion criteria changed between 2008 and 2011? If so,
explain how they have changed.
c) Describe which components (e.g. network elements or links) of the company‟s
networks, used to provide broadband Internet services, are provisioned based on
Internet traffic volumes. The discussion should include a general description of
the architecture of the company‟s networks.
d) If congestion is currently present in the company‟s network, provide quantitative
evidence of such congestion. Using the components identified in the response to
part c) above, specify when this congestion occurs, how many components by
type are affected, what proportion of the total components by type are affected, as
well as how often congestion is being experienced (i.e. what % of the time
elements are experiencing congestion).
3. In Public Notice 2008-19 - Review of the Internet traffic management practices of
Internet service providers, the Commission posed a series of questions related to
network provisioning of the ISP operator‟s networks. As such, questions a) and b)
and c) below explore the same subject matter .
a) For each component identified above in question 2 c), describe the practices that
the company employs to provision its networks. The answer should include a
description of the conditions under which the company would augment its
network capacities to address congestion. Describe in detail the process used to
identify when and where additional network capacity is required and how the
additional capacity requirements are determined.
b) For each component identified in question 2 c), specify the amount of time
required to increase capacity of the component in the company‟s network, taking
into account the time that elapses between identification of a need to add capacity
for the component and the subsequent ordering, provisioning, installation, testing
and activation of the additional capacity.
c) Describe any major changes to the company‟s provisioning practices for the years
2008 to 2011. The response should include details on any changes in
provisioning assumptions.
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d) With respect to other company services being offered using a common network
(e.g Cable television services over HFC networks),
i. describe the differences between the company‟s managed services
and Internet services that have led the company to separate them.
Clearly define the parameters used to distinguish its managed
services from its Internet services,
ii. explain how the company separates its managed services from its
Internet services,
iii. explain how such services are planned and provisioned for in a
common manner. Explanations should include a description with
diagrams identifying which elements of the networks share
common capacity, as well as identifying elements of the network
where capacity is provisioned in a separate manner. For elements
of the networks that share capacity specify how much capacity is
allocated to managed services and how much capacity is allocated
to Internet services.
e) With reference to the responses provided in question 2 d) and question 3 d),
explain why other services which are provisioned over the same network elements
do or do not contribute to network congestion, as well as how the company
determines whether to allocate additional capacity to either the Internet services
or the other services sharing the capacity.
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Interrogatories to the Canadian Network Operators Consortium (CNOC)
1. Refer to CNOC‟s intervention dated 28 March 2011, regarding its proposed
restructured pricing model for aggregated ADSL access and third party Internet
access (TPIA) services. Provide details on how a service provider that is a member of
CNOC would measure, for billing purposes, the total monthly peak traffic that its
users cause i) on an ILEC‟s network, ii) on a cable carrier‟s network. The response
should indicate where the measurement takes place and what additional equipment or
software would be required to support the ongoing monthly measurement.
2. If CNOC‟s proposed restructured pricing model was implemented for aggregated
ADSL access and TPIA services,
a. describe how CNOC‟s proposed model will address the problem of network
congestion during peak periods;
b. specify the effect of CNOC‟s proposed model on end-user usage. The
response should provide five year forecasts starting at 2011 for i) average
monthly per end-user usage for services provided by CNOC‟s members using
the current pricing models for aggregated ADSL access services and TPIA
services ii) average monthly per end-user usage under CNOC‟s proposed
model;
c. explain how CNOC‟s proposed model takes into account the impact of
ongoing changes in end-user behaviour (e.g. increased monthly traffic
volumes, increased traffic during peak periods, changes in the ratio of total
traffic volume to peak traffic). The response should address any requirements
for ongoing adjustments to rates, with supporting rationale.
3. Refer to the Bell companies‟ intervention dated 28 March 2011, where they proposed
the introduction of Aggregated Volume Pricing (AVP) for their residential Gateway
Access service. If the AVP proposal was implemented,
a. explain how a wholesale customer of GAS that is a member of CNOC would
measure the aggregated monthly volume that its end-users cause on the Bell
companies‟ network,
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b. explain how a wholesale customer of GAS that is a member of CNOC would
determine its monthly traffic volume requirement that it would pre-purchase
from the Bell companies,
c. describe to what degree the measurement of the aggregated monthly volume
can be duplicated by the Bell companies to facilitate billing reconciliation.
4. In their intervention dated 28 March 2011, Cogeco, Videotron and Rogers provided
Chart B3 entitled “Internet Usage by Time of Day – North America 2010”. The chart
provided i) the level of traffic per end-user as a percentage of the maximum level of
traffic per end-user by time of day and ii) the number of end-users that are connected
as a percentage of the maximum number of end-users that are connected by time of
day.
Indicate whether this chart is representative of the daily Internet usage of end-users
served by members of CNOC. If it is not, provide equivalent charts for the Internet
usage by time of day for end-users served by members of CNOC.
5. Refer to paragraph 39 of CNOC‟s intervention dated 28 March 2011, where CNOC
stated that
“Under this approach there should also be no concern that ordinary consumers
served by Independent ISPs would fund the bandwidth used by the heaviest retail
IS consumers”
Explain how the implementation of CNOC‟s proposed model for aggregated ADSL
access services and TPIA services would ensure that the above statement would be
valid.