Sunday, November 30, 2008

Copper May be Buried But Ain't Dead (Part 2)

Who is the CRTC?
The CRTC is an independent, public authority that regulates and supervises broadcasting and telecommunications in Canada. The CRTC regulates two types of telecommunication services: Retail and Wholesale. As an example, wholesale services are divided into six categories: interconnection, public good, essential, conditional essential,conditional mandated non-essential, and non-essential subject to phase-out.

What is a Tariff?
An incumbent service provider is required to file a tariff with the CRTC for each of their regulated services. A tariff defines the service and the cost of the service, but does not necessarily define the underlaying access technology. A service may be provided using a variety of access technologies such as copper, fibre and wireless. Tariffs are periodically updated by the CRTC to meet the needs of the Canadian citizens.

In order to withdraw a tariffed service an incumbent must do the following: (1). Define the service proposed to be destandardized and/or withdrawn; (2). Proposed date for destandardization; (3). Proposed date for ultimate withdrawal of service; (4). Type of destandardization; (5). Rationale for the application; (6). Availability of a substitute, with rationale as to why it was reasonable in terms of equivalent functionality, availability in the same geographical area, and cost (including the initial outlay and ongoing costs to the customer); (7). Provide a transition plan; (8). Provide relevant information concerning existing customers, such as the number of customers affected; (9). Send a copy of the notice to affected customers; and (10). Provide any other information the applicant believed was relevant.

Local Loop Unbundling (LLU)
Local loop unbundling was introduced by the CRTC in 1997. Unbundling the local loop, as a policy, is built on the recognition that incumbent carriers have a dominant position in the provision of local access by virtue of their control over the local loop which can not be economically replicated by alternative providers. This position of dominance has resulted from many years during which incumbents had a monopoly in the provision of voice services in rural Alberta. The requirement of unbundling loops in lower cost areas, such as large urban areas, was put in place for a period of five years starting from May 1997. A decision was made in 2001 subjecting local loops in rural areas to unbundling requirements on an indefinite basis.

Local loop unbundling can be classified into two types: 1. Full unbundling. The copper pairs are leased by the new provider. The new provider takes complete control over the copper pair and can provide subscribers with services including voice and broadband. The incumbent owns and maintains the copper pair. 2. Line sharing. Line sharing allows the incumbent to maintain control of the copper pair and continue to provide some services to the subscriber such as voice services. The new provider leases part of the pair and provides broadband services. The CRTC has not mandated line sharing.

In order to interconnect the copper pair to the new provider’s equipment the incumbent must provide access to a collocation facility. There are two ways to provide collocation: 1. Caged Collocation. A physically separate space from the rest of the incumbents exchange by a wire mesh or partition. 2. Co-Mingling. Cageless collocation where the new provider’s equipment is placed together with that of the incumbent.

Telecom Decision CRTC 97-8

Telecom Decision CRTC 97-8 requires that essentail facilities, functions, and services in the local loop be unbundled. The local loop must meet three criteria: (1) it is monopoly controlled; (2) a CLEC requires it as an input to provide services; and (3) a CLEC cannot duplicate it economically or technically. Telecom Decision CRTC 97-8 is available at:

TELUS's Application
The CRTC received an application from TELUS dated September 30, 2004 called: "Amalgamation of Analogue private line service". This application algamated many former general items. TELUS stated that the tariff would align and clarify the terms and conditions pertaining to the provision of analogue private line service in Alberta and British Columbia (B.C.). A brief is available at:

The CRTC considered that TELUS's proposal would simplify the application of the tariffs for Analog private lines service in Alberta and BC. The demand for analog private line services that TELUS proposed to grandfather had declined, alternatives to these services are available, and that it received no comments from TELUS's existing customers.

TELUS is positioning its Wholesale DSL service is an alternative. TELUS offers a full end-to-end solution to service providers as well as making available to competitive local exchange carriers (CLECs), Internet service providers (ISPs) and DSL service providers (DSLSPs) individual components of the service architecture. This service is intended for ISPs such as The Internet Centre that want to offer higher speed connections between the end-user device and their point of service. There are a couple of issues with this service: (1) The service is not universally available in Alberta and British Columbia, (2) TELUS is able to control and filter the traffic between the ISPs point-of-precense and the customer's premises.

The Internet Centre's Filing
The Internet Centre states that TELUS's wholesale services are NOT available in rural communities and is not a replacement for the analog private line service. In addition, they state that in its Analogue Private Line Services TELUS masked, under the objective of simplification, a restructuring of local channel services with the intent to prohibit any uses of local channels beyond voice-grade services.

In order for the The Internet Centre to collocate in a TELUS central office, they are required to carry a $68 million dollar insurance policy for each central office. This is not economically feasible when providing services to a rural small community. The Internet Centre is requesting that that their equipment (DSLAM) be located in the SuperNet POP vs the TELUS central office.

What this all mean to a rural community?
(1) TELUS's retail or wholesale ADSL service is probably not available in the rural community becuase the network has not been upgraded.

(2) TELUS is currently installing voice coils on the analogue private line service prohibiting the provisioning of broadband services such as ADSL, ADSL2+, SDSL, and VDSL.

(3) Collocation in a TELUS central office may not be economically feasible.

Current Status
On December 3rd the CRTC sent a letter to TELUS containing an number of interrogatories for TELUS to answer. TELUS has until December 17th to reply back to the CRTC. The Internet Centre will then have until January 6th to comment to TELUS's response. Then TELUS will have to respond by January 16th.

TELUS has submitted that the Internet Centre proposed use of unloaded copper would cause interference and crosstalk that "…can affect other copper facilities adjacent to the one used for xDSL service."

The CRTC wants TELUS to describe in detail the incidence of this interference and crosstalk and the impact it has on adjacent facilities. They want to be provided with specific incidences of such interferences and crosstalk and a description of how they were resolved.

The Commission is asking TELUS to provide details of its own use of unloaded copper and what services they provide now and how they resolve the matter of spectral interferences of crosstalk in those internal situations.

The Commission wants details of any and all unloaded copper access to private line services to any retail or wholesale customers and details on those services are provided.

Stay Tuned
Copper May be Buried but Ain't Dead posting #3 will be posted in either January or Feburary 2009.

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