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Davesnothere
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4 edits
reply to resa1983

Re: Cable companies' Review and Vary of 2011-703

said by resa1983:

said by alienzzz:

I love MTS allstream.

Their reply is pretty damned awesome.
quote:
14. Further, to the extent that Bell encounters bridge tap when installing HSI, the cable was likely placed in the 70s or earlier and has been fully depreciated...

 
This is not the 1st time that MTS has accurately and eloquently called BS on B$ELL's costing and other proposals.

I thoroughly look fwd to their submissions and commentaries with the same level of anticipation with which I salivate about JF's.

CNOC too has delivered some great submissions this year.

The next paragraph is also a winner, IMNSHO.
quote:
15. Third, Bell’s application of eligible conditioning costs includes the replacement of terminals at the demarcation point of customer premises or demarcation devices, sometimes known as Network Interface Devices (NIDs).

Bell has been installing NIDs on installations and repair visits for more than twenty years, and the original justification for doing so was the transferal of ownership of inside wiring to customers.

The cost of placing these devices, even if placed during a visit to install HSI, is causal to the provision of primary exchange services (PES), not HSI.

In the event that the Commission determines it is appropriate to include NID placement as a cost causal to HSI, it cannot be double counted in Bell’s cost recovery for PES, and the occurrence rate for NID placement should be reduced going forward compared to the rates claimed in the past.

[Emphasis was added by me. ]

However, I wish that they WOULD replace the not weatherproof by design prehistoric demarc strip on the outside wall of OUR place.

Bell has not fixed ALL of them yet, and ALREADY they are double-dipping on the costs for the first time.

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alienzzz
Kill Bell

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I also *love* how MTS keeps spitting and spitting on Bell. Plus they own a network based on an identical technology so these guys know what they are talking about.

Now we have good incumbents and evil incumbents. It's quite funny that Shaw started in the good league and now they are trying so hard to get in bed with the bad boys, that they are willing to bootlick as much as possible, only so the truly-evil kids would let them in. Such a shame... picking the dark side.


Davesnothere
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said by alienzzz:

I also *love* how MTS keeps spitting and spitting on Bell.

Plus they own a network based on an identical technology, so these guys know what they are talking about....

 
MTS does not need to see what's behind B$ELL's ####s - they already KNOW.

Actually, PShaw only agreed with ONE point of B$ELL's R&V of 703, and said that they were not commenting on the rest.

And I've said before that MTS has a crackerjack legal/regulatory team.

This is just their latest 'WRinging of the B$ELL'.


Very true

@videotron.ca
reply to Davesnothere
said by Davesnothere:

quote:
15. Third, Bell’s application of eligible conditioning costs includes the replacement of terminals at the demarcation point of customer premises or demarcation devices, sometimes known as Network Interface Devices (NIDs).

Bell has been installing NIDs on installations and repair visits for more than twenty years, and the original justification for doing so was the transferal of ownership of inside wiring to customers.

Actually, this is very true.

about 15 years ago, maybe a bit more, Bell had kids (people in training or summer students) going house to house to install these. Everyone on the street I lived on had one installed. The kids said this is Bell's new terminal which was both safer and has easy disconnects that everyone requires now. So I had them put it on the inside of the house. Mine had two test ports for two different phone lines.

So the NID thing is very true and again total bullshit. I didn't think of this. Good point.


Davesnothere
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said by Very true :

....So the NID thing is very true and again total bullshit. I didn't think of this. Good point.

 
Aw shucks ! [Dave shrugs and grins ]

It was not my own observation, but I felt that it needed to be repeated here.

And another thing (which IS my observation) :

Why did we even NEED to make part of the wiring the responsibilty of the subscriber in the first place ?!

Cablecos (at least Cogeco) will wire all the way to your computer room and charge no extra, nor do they quibble about whose wiring is whose.

The whole CONCEPT of demarc points is a grandfathered CASH COW of B$ELL's, and it ought to be dismantled.

NIDs or not, it should be up to Bell to send qualified techs who know what to do and how to test. - Cablecos do that.


Ott_Cable

@teksavvy.com
I don't think house wiring for phone jacks are so important anymore. With DECT 6.0 cordless phones that cost no a lot more than a corded one and support multiple handsets, there is almost no point about maintaining or even having internal phone wiring. If anything, a network jack in place of a phone outlet is more useful in the long run.


Davesnothere
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4 edits
reply to jfmezei

CNOC's Comments about Bell's R&V

quote:
The Commission did not err in adjusting the Bell Companies' FTTN DSLAM costs.

31. When it comes to labour and DSLAM costs, the Commission decided to cap the labour component of the cost at 40%, and used a longer life of 18 years for the civil work portion of the Bell Companies' labour costs.

These are different factors than what the Bell Companies had proposed, which the Commission arrived at by examining all of the relevant evidence, including comparing the evidence tendered by other ILECs. (MY emphasis here)

 
CNOC is echoing what MTS said, but not quoting specific costing figures.

However, MTS of course has internal access to their OWN equivalent costing figures, to yield such pretty graphs for us to embellish.

Given that CRTC has ALL of the various providers' #### costing info in front of them at once, they are perfectly justified in limiting B$ELL's numbers if those numbers seem too far towards the right side of the (yes, wait for it.........) the 'B$ELL Curve' !

And in doing so, CRTC has unwittingly given the public a peek into what might be behind some of the ####s, as also has Bell by whining about it in an R&V.

In essence, what the CRTC has done is to tell Bell that they are paying too much for their outsourced labour and such, and Bell doesn't like being told that they are wasting money.

Looks like Cope needs to ask some internal questions as to why some of this stuff seems to cost this much - unless of course the figures are total BS, in which case - GOTCHA, B$ELL !


Davesnothere
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Part of Bell's whining was to allege that CRTC had ignored parts of their costing info which had been filed in ####.

CNOC said :
quote:
35. The Commission did not ignore the cost information placed on the record of the proceeding by the Bell Companies; the Commission simply disagreed with it in the end, based on a number of relevant considerations, which is something the Commission was entitled to do. (MY emphasis)

 
How VERY true !

jfmezei
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reply to Davesnothere

Comments about the Rogers R&V

Click for full size
downloadMTS Rogers T···-703.pdf 179,764 bytes
MTS
Click for full size
downloadShaw Comment···inal.pdf 98,584 bytes
Shaw
Click for full size
downloadCogeco Comme···-703.pdf 104,528 bytes
Cogeco
Click for full size
downloadQuebecor com··· R-V.pdf 53,178 bytes
Quebecor
Click for full size
downloadLetter to Jo···inal.pdf 69,965 bytes
CNOC
Here are the comments submitted about the Rogers R&V


Davesnothere
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1 edit
reply to Davesnothere

Primus' Comments about Bell's R&V

 
Primus is basically taking the same view as CNOC and MTS did - that Bell's R&V does not meet the qualifications of an R&V, since its contents are merely a restatement of arguments made prior to the CRTC's 2011-703 decision.

Although they take 17 pages to say it, their summary at the outset is pretty clear :
quote:
6. For example, while Bell may not agree with the Commission's determinations to exclude network developing and conditioning costs incurred prior to July 2011, Bell's disagreement does not cast doubt on the application of an established basic costing principle by the Commission.

Similarly, while Bell may not agree with the results of the adjustment, the Commission fully and appropriately acted within its discretion in making the adjustments to the capital unit costs.

Nor does Bell's disagreement bring into question the appropriateness of adjustments made by the Commission that are consistent with those made in other proceedings, such as the utilization of a 10 year study period and the consideration of other ILEC costs in setting DSLAM labour costs.

7. It is also clear that Bell’s R&V application also relies on arguments that are largely facsimiles of the arguments put forward in the process that led to TRP 2011-703.

Accordingly, the adjustments disputed by Bell received full and explicit consideration in that proceeding.

8. Accordingly, for all of the reasons set out herein, Primus requests that the Commission deny Bell’s R&V application in its entirety.



it is

@videotron.ca
reply to bt

Re: Cable companies' Review and Vary of 2011-703

said by bt:

said by More LOLs :

This is getting better and better the more I read.

MTS even drew the CRTC a picture! I can't stop laughing at Bell.

I was somewhat disappointed that the commentary on the right margin wasn't actually in the filing.

Oh, it is. It may not be labelled as such in those exact words, but that is basically what they said.


elwoodblues
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reply to Davesnothere

Re: Primus' Comments about Bell's R&V

But does MTS golf as well as Mirko? That's far more important.


Davesnothere
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1 edit
reply to Davesnothere

Primus - More Highlights about Bell's R&V

 
The Primus legal department definitely took this one seriously, picking apart Bell's R&V app line-by-line, quoting dozens of past CRTC proceedings and submissions where Bell has corporately contradicted themself (compared to what they currently seem to want), and taking this process even further than CNOC did, which was quite far in itself.

If I was taking on Bell in a courtroom environment, I absolutely would want that/those lawyer(s) on my team.

Some other highlights are paragraph 14, and then 17 thru 20 or further, beginning "Bell also makes disingenuous assertions...."

And paragraph 46 is a superb zinger :
quote:
46. Bell's real complaint appears to be that their 'detailed cost information' was not compelling enough to be accepted by the Commission. (MY emphasis)

 
Bell sounds rather like an whining child to me.


Ott_Cable

@teksavvy.com
May be if the detailed costing were all in ####, then someone else e.g. the other telco/cableco or even CNOC could have help them out. Bell is so insecure.


Davesnothere
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said by Ott_Cable :

May be if the detailed costing were....

 
Huh ?

Did you not mean "were not" ?


Ott_Cable

@teksavvy.com
Yeah. It was meant to be "weren't".

One of the draw back of being anon is no editing... That's also something I am trying to force myself not to do as otherwise I would edit a lot.


Davesnothere
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reply to jfmezei

JF's Comments about Bell's R&V

 
On this one, JF has taken a different approach than MTS, CNOC, and Primus, who each in their own way have offered the CRTC very clear and compelling reasons to refuse Bell's R&V of 2011-703.

JF has not suggested yea or nay on Bell's R&V, but instead has submitted some glossaries of terms, a series of questions which would need to be asked of Bell, and some suggestions as to alternatives, which, as finely honed as the other 3's negative comments about Bell's submission were, they did not do much of this, if any at all.

The answers to some of JF's questions will serve to reinforce in the CRTC's collective minds that Bell's R&V submission is bogus, but he is leaving it up to the CRTC to reach said conclusion on their own.

jfmezei
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Before startig to write that submission I had plenty of ideas and was ready to forge ahead at full speed.

Once I got started, I came to realise that it wasn't as black and white as I had thought because I kept thinking of the high installation costs and wondering how the costs of the copper plant should be paid for and to be honest, I realised I didn't really know. So the est I could do was to ask questions and explain the whole bridge tap thing which the commisioners would't know about.


Davesnothere
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1 edit
reply to Ott_Cable

Re: Primus - More Highlights about Bell's R&V

said by Ott_Cable :

One of the draw back of being anon is no editing....

 
Another is that I could not IM/PM you about it.

But, registering is still an option.


Davesnothere
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reply to jfmezei

Re: JF's Comments about Bell's R&V

 
But you covered something that the others seemed to miss, at least this time they did.

You suggested alternative actions and behaviours, and explained some of the likely benefits if adopted.

Somebody needs to do that in EVERY situation.

This time it was you.

Let the others cast the stones sometimes.

InvalidError

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1 edit
reply to jfmezei

Re: Comments about the Rogers R&V

Humm, Rogers' Quebecor's response implies that Rogers intends to charge SEPARATELY for upstream and downstream 100Mbps increments...

3. In addition, in its application, Rogers addresses the matter of the appropriate measure of 100 Mbps increments to which the new TPIA capacity charge is applied. Rogers asserts that the charge must be applied to upstream and downstream increments in order for Rogers to fully recover its costs given the arithmetic manner in which the Commission derived the capacity charge. Alternatively, should it be the case that TRP 2011-703 was not intended to create separate upstream and downstream 100 Mbps increments, then Rogers asserts the capacity charge must be varied so that it recovers total costs only on downstream increments.

Wonder how many other incumbents are swinging that way, I don't remember seeing any mention of that anywhere before.

And of course, as part of Quebecor's support for Rogers, they are asking to charge separately for upstream 100Mbps as well since they suffer from the same rate-setting error.


Davesnothere
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said by InvalidError:

Humm, Rogers' Quebecor's response implies that Rogers intends to charge SEPARATELY for upstream and downstream 100Mbps increments....

 
I see you made an edit to who said it.

But regardless of that, we are looking at the proverbial 'thin edge of the wedge' of a dangerous precedent, if ANY provider convinces CRTC to allow THAT to happen, no matter what the alleged justification for doing so.

Ultimately, it would be just one more way to :
(1) make the IISPs' margins even thinner, and
(2) to gouge the consumer.


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MaynardKrebs
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reply to Davesnothere

Re: Primus - More Highlights about Bell's R&V

said by Davesnothere:

Some other highlights are paragraph 14, and then 17 thru 20 or further, beginning "Bell also makes disingenuous assertions...."

Call it what it is, rather than couching it in euphemism - THEY'RE F!CKING LYING!!


Davesnothere
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said by MaynardKrebs:

Call it what it is, rather than couching it in euphemism - THEY'RE F!CKING LYING!!

 
Yeah, but what if one day the lawyer who wrote the paragraph ends up working for Mirko's team, or if B$ELL buys Primus, or some other permutational variation of subordinate/superior relationship happens between the 2 companies or some of their depts ?

It's like when a lawyer/politician says "My learned colleague...."

InvalidError

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reply to Davesnothere

Re: Comments about the Rogers R&V

said by Davesnothere:

But regardless of that, we are looking at the proverbial 'thin edge of the wedge' of a dangerous precedent, if ANY provider convinces CRTC to allow THAT to happen, no matter what the alleged justification for doing so.

Well, unlike xDSL where first-mile downstream and upstream functions of each port are dedicated to a single line regardless of what the speeds are, provisioning of upstream and downstream capacity on cable nodes are almost completely independent activities so on cable, there certainly is a potential to prove the need for differentiated billing between upstream and downstream due to the fundamental technical difference between cable and DSL in that regard.


Ott_Cable

@teksavvy.com
reply to Davesnothere

Re: Primus - More Highlights about Bell's R&V

>It's like when a lawyer/politician says "My learned colleague...."

Both of these "professions" are hated by the common folks, so may be that's the only time they get to be addressed in a polite manner?

Lawyers are hired guns. Off the clock, those guys might even went to the same law schools or worked together previously or best buddies for all we know.


Davesnothere
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reply to InvalidError

Re: Comments about the Rogers R&V

said by InvalidError:

....there certainly is a potential to prove the need for differentiated billing between upstream and downstream, due to the fundamental technical difference between cable and DSL in that regard.

 
I see.

So it's unique to Cable Topology.

Still, Bell has never been bashful, nor lacking in resourcefulness at conjuring up new ways to soak us for SOMETHING, any chance that they get.

The one thing which I could safely say that I would 'trust' Bell to do would be THAT.

InvalidError

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said by Davesnothere:

The one thing which I could safely say that I would 'trust' Bell to do would be THAT.

At the very least, I would "trust" Bell to argue that they should get to bill both ways separately just because cablecos might get to do so... all in the name of regulatory symmetry!

If things get there, it will be important to remind the CRTC that some exceptions to symmetry are required due to some fundamental technical difference that may justify them... perfect symmetry between fundamentally dissimilar technologies is impossible.

jfmezei
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It doesn't cost the cable companies more to carry upload on the coax. It is just more rationed via the low upload speeds.

And from the CMTS to the ISP, the networks would be symmetrical, and provisioned to handle the far greater download traffic , so the upload fits very comfortably in existing capacity.


elwoodblues
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said by jfmezei:

It doesn't cost the cable companies more to carry upload on the coax. It is just more rationed via the low upload speeds.

And from the CMTS to the ISP, the networks would be symmetrical, and provisioned to handle the far greater download traffic , so the upload fits very comfortably in existing capacity.

Of course it does, Rogers said so, they wouldn't lie would they?
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