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  • 120109-The - Comp-CRTC-4Jan12-1 TNs BA392-BC7339 - ABR

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    Mark Goldberg
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    A wholesale customer of the Bell Companies' GAS service could divert the traffic of its residential end-customers to a business interface. Release of this information on the public record would provide existing or potential competitors with invaluable competitively-sensitive information.

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    120109-The_Comp-CRTC-4Jan12-1 TNs BA392-BC7339_ABR

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    A wholesale customer of the Bell Companies' GAS service could divert the traffic of its residential end-customers to a business interface. Release of this information on the public record would provide existing or potential competitors with invaluable competitively-sensitive information.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
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    25 views3 pages

    120109-The - Comp-CRTC-4Jan12-1 TNs BA392-BC7339 - ABR

    Uploaded by

    Mark Goldberg
    A wholesale customer of the Bell Companies' GAS service could divert the traffic of its residential end-customers to a business interface. Release of this information on the public record would provide existing or potential competitors with invaluable competitively-sensitive information.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Flag for inappropriate content
    of 3

    Bell Aliant/Bell Canada 9 January 2012 Page 1 of 3

    Response to Request The Companies(CRTC)4Jan12-1 TNs BA392-BC7339 Abridged

    Q.

    Provide a detailed explanation of how, in the Bell Companies' view, a wholesale customer of the Bell Companies' GAS service could divert the traffic of its residential end-customers to a business interface (i.e. a business AHSSPI or the business domain in the case of a shared IP AHSSPI). Certain information contained in this response is filed in confidence with the Commission pursuant to section 39 of the Telecommunications Act. This information is disaggregated and the Companies consistently treat such information as highly confidential. Release of this information on the public record would provide existing or potential competitors with invaluable competitively-sensitive information that would not otherwise be available to them, and which would enable them to develop more effective business strategies as well as circumvent Capacity Based Billing (CBB) charges by diverting residential traffic to a business interface. Release of such information could prejudice the Companies' competitive position, result in material financial loss and cause specific direct harm to the Companies. An abridged version of this response is provided for the public record. The Companies answer this response with the assumption that the capacity charges will be implemented in the manner described in their 19 December 2011 letter and their associated tariff pages issued on the same day (with the exception of the proposed penalty clause which was subsequently withdrawn and is now filed for approval and is the subject of the present proceeding). For clarity, the Companies do not address any of the comments or proposed implementation solutions CNOC has made in its Part 1 dated 4 January 2012. At the outset, the Companies note that ISPs are presently allowed to co-mingle their traffic from business and residential end-users on their AHSSPI interfaces. Therefore, the terms "business interfaces" and "business domains" are new terms with the introduction of CBB. The Companies believe there are at least three methods the ISPs could use to divert the traffic of residential end-customers to a business interface in order to avoid capacity

    A.

    Bell Aliant/Bell Canada 9 January 2012 Page 2 of 3

    Response to Request The Companies(CRTC)4Jan12-1 TNs BA392-BC7339 Abridged

    charges. As the Companies do not want to explain on the public record how to bypass CBB charges, the Companies are providing the following detailed explanation of how ISPs could divert residential traffic to business interfaces in confidence. In order to reduce or avoid capacity charges, #

    # Filed in confidence with the CRTC.

    Bell Aliant/Bell Canada 9 January 2012 Page 3 of 3

    Response to Request The Companies(CRTC)4Jan12-1 TNs BA392-BC7339 Abridged

    # These are just three of the most obvious means the ISPs could use to divert traffic from their residential end-users to business domains or interfaces.

    # Filed in confidence with the CRTC. *** End of Document ***

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