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

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

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Published by: Mark Goldberg on Jan 10, 2012
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Bell Aliant/Bell CanadaResponse to Request9 January 2012The Companies(CRTC)4Jan12-1 TNs BA392-BC7339Page 1 of 3Abridged
Q.
Provide a detailed explanation of how, in the Bell Companies' view, a wholesalecustomer of the Bell Companies' GAS service could divert the traffic of itsresidential end-customers to a business interface (i.e. a business AHSSPI or thebusiness domain in the case of a shared IP AHSSPI).
A.Certain information contained in this response is filed in confidence with the Commissionpursuant to section 39 of the
Telecommunications Act 
. This information isdisaggregated and the Companies consistently treat such information as highlyconfidential. Release of this information on the public record would provide existing or potential competitors with invaluable competitively-sensitive information that would nototherwise be available to them, and which would enable them to develop more effectivebusiness strategies as well as circumvent Capacity Based Billing (CBB) charges bydiverting residential traffic to a business interface. Release of such information couldprejudice the Companies' competitive position, result in material financial loss and causespecific direct harm to the Companies. An abridged version of this response is providedfor the public record.The Companies answer this response with the assumption that the capacity charges willbe 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associated tariff pages issued on the same day (with the exception of the proposedpenalty clause which was subsequently withdrawn and is now filed for approval and isthe subject of the present proceeding).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 dated4 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 theintroduction of CBB.The Companies believe there are at least three methods the ISPs could use to divert thetraffic of residential end-customers to a business interface in order to avoid capacity
 
Bell Aliant/Bell CanadaResponse to Request9 January 2012The Companies(CRTC)4Jan12-1 TNs BA392-BC7339Page 2 of 3Abridged
charges. As the Companies do not want to explain on the public record how to bypassCBB charges, the Companies are providing the following detailed explanation of howISPs could divert residential traffic to business interfaces in confidence. In order toreduce or avoid capacity charges, ## Filed in confidence with the CRTC.

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