CCTA questions need to broaden access to inside wiring

The Canadian Cable Telecommunications Association (CCTA) tells the CRTC that Bell ExpressVu’s attempt to expand third-party access to inside wiring goes beyond the original intent of the regulations. The direct-to-home (DTH) satellite TV distributor would like current CRTC rules that set the lease rate for inside wiring at 52 cents per subscriber per month to be extended to properties such as hotels, hospitals, nursing homes and other institutional multi-unit premises (CCR, Aug. 19/05). Below is an excerpt from the CCTA’s comments to the commission on the matter. The CCTA submits that Bell ExpressVu’s proposed definitions of "customer" and "demarcation point" subvert the original intent of the inside wire regime. Contrary to what Broadcasting Public Notice 2005-83 would suggest, there is no "gap" to fill. When establishing the inside wire regime, the commission deliberately chose to exclude commercial properties from the requirements of the inside wire regime. The current definitions of "customer" and "demarcation point" are reflective of this intent. As such, any substantial reworking of the inside wire regime to apply to commercial establishments should not be dealt with by way of cursory amendment to the Broadcasting Distribution Regulations. The proposed amendments go far beyond "expanding competitive access to inside wire" as the commission’s PN 2005-83 would seem to suggest. In fact, this proceeding has less to do with access to inside wiring than with access to in-building wire. There is no evidence before the commission regarding the costs associated with providing and installing commercial or institutional in-building wire. In the absence of such evidence, CCTA submits that it is entirely inappropriate for the commission to mandate access to in-building wire on the same terms and conditions as access to residential inside wire. …In examining section 10 of the 1997 (Broadcasting Distribution Regulations, Public Notice 1997-150) and the policy documents which explain that section, it is apparent that the commission expressly intended to provide end-user choice to all residential customers, and not necessarily to all subscribers. For example, as stated by the commission...As explained by the CCTA in its original comments, the technical and market realities of commercial buildings do not lend themselves to the requirements of the inside wire regime. It is for these reasons that the commission expressly chose the term "customer" when establishing the inside wire regime in section 10 and then explicitly carved out from the definition of customer "the owners/operators of a hotel, hospital, nursing home or other commercial or institutional premises to which service is provided by a licensee." Similarly, the definition of "demarcation point" was expressly designed to apply only to single and multiple unit dwellings, or residences. Clearly, there was never any intent to provide for transfer of inside wire in the commercial or institutional context. Instead, there is now only a reference to "subscriber" (after amendments were made to section 10 in 2000). The CCTA submits that this change in language did not change the intent of the section and does not change the commission’s long-standing policy of extending end-user choice to "customers" as expressed in original policy documents…The CCTA submits that the commission should not mandate access to in-building wire by simply extending the inside wire regime to commercial buildings. This approach is both contrary to the commission’s original intent when establishing the inside wire regime and introduces a significant inconsistency in the definition of inside versus in-building wiring. In other words, there is no "gap" or "oversight" in the regulations that require the commission to revisit its inside wire policy. Furthermore, expanding the scope of the inside wire regime to commercial buildings would allow competing service providers to access a significant amount of cabling infrastructure well below cost.

CCTA questions need to broaden access to inside wiring

News | 10/24/2005 4:00 am EDT

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