The Canadian Network Operators Consortium, which represents two dozen independent ISPs, has asked the CRTC to expand the scope of its usage based billing consultation. Rather than limit the review primarily to UBB, CNOC says the review should:

include a comprehensive review of the regulatory framework applicable to all wholesale high-speed access services (â€œWHSASâ€) provided by incumbent local exchange carriers and cable carriers (collectively â€œincumbentsâ€) to their competitors and to include from the outset, in the expanded proceeding, an online consultation and a public hearing, and certain additional procedural steps.

The letter makes it clear that CNOC is seeking nothing less than a complete overhaul of the regulatory framework for broadband competition in Canada. The organization argues that “incumbent wholesale high-speed services, including the last-mile access, constitute the broadband platform that competitors need to offer almost all telecommunications and broadcasting services to consumers.” It adds:

If the Commission does not ask the right questions, it cannot possibly hope to get the right answers. If it limits this proceeding to a review of billing practices for WHSAS employed in the provision of residential services by competitors, the situation will be analogous to a rearrangement of deck chairs on the Titanic before it sank. In the absence of a proper regulatory framework, any solution to the issues raised in the current proceeding will only delay the inevitable sinking of the competitive ship.

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CNOC proposes several broad questions including the prospect of revisiting the ADSL-CO service. Moreover, CNOC asks the CRTC to move quickly to include an online consultation and oral public hearing, with the goal of reaching its determination by the end of the year.