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September 29, 2010

Via e-pass
Mr. Robert Morin
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario K1A 0N2

Dear Mr. Morin:

Re: Follow-up to Telecom Regulatory Policy CRTC 2010-632; Show Cause


Proceeding Concerning Static IP Addresses for Wholesale High-speed
Internet Business Service – Cable Companies Comments

INTRODUCTION AND OVERVIEW

1. Cogeco Cable Inc., Quebecor Media Inc., on behalf of its affiliate Videotron Ltd.,
Rogers Communications and Shaw Communications Inc. (collectively, the Cable
Carriers) hereby file their comments in response to paragraph 142 of Telecom
Regulatory Policy CRTC 2010-632 (TRP 2010-632) directing the Cable Carriers to
“show cause, within 30 days of the date of this decision, why they should not be
required to provide static IP address allocation for their TPIA services.”

2. The directive addresses the Cable Carriers’ business TPIA services. The
Commission’s reasoning underlying the directive is found in Section B of the
Decision, “Equity of existing wholesale access service obligations for the
ILECs and the cable carriers” subsection (c), iii, “business use” as follows:

Positions of parties
106. The incumbents submitted that there are no constraints on using aggregated ADSL
access and TPIA services for business end-customers where facilities are available. The
competitors submitted that the usefulness of TPIA service for business applications is limited
because the cable carriers are unable to provide static IP addresses[39] for end-customers.
Commission’s analysis and determinations
107. The Commission notes that competitors cannot provide static IP addresses to end-
customers using TPIA service, but they can provide these addresses using aggregated ADSL
access service.
108. Based on the record of this proceeding, the Commission also notes that some cable
carriers offer retail business services that provide static IP addresses to end-customers. The
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 2 of 7
Commission considers that this strongly suggests that it is possible for cable carriers to
provide this capability with their TPIA services.
109. In the Commission’s view, the cable carriers’ inability to provide static IP address
allocation for TPIA service means that the incumbents’ obligations for the aggregated ADSL
access and TPIA services are not equitable. The Commission notes, however, that there is
insufficient information on the record of this proceeding to make a determination on the
matter.
110. In light of the above, the Commission concludes that the cable carriers should show
cause why they cannot provide static IP address allocation for their TPIA services.

3. The Cable Carriers submit that they should not be required to provide static IP
addresses for business TPIA service. The Cable Companies submit that there are
technological issues that need to be assessed before it could be determined
whether the method by which they are able to provide static IP addresses to certain
business retail customers could be made to work with their TPIA service. There are
concerns from a routing and operations perspective how this could operate in a
TPIA environment. No implementation precedents exist and there is no evidence
that a workable solution could be developed.

4. However, should implementation prove to be technically feasible, the Cable


Carriers submit that there is substantial doubt that the development costs of the
service would ever be recovered given the Cable Carriers’ limited business
footprint and the higher rate that would apply for static IP address service. The
Cable Carriers do not believe that there will be sufficient demand for them to
recover their costs. Finally, there are also practical alternatives to static IP
addresses that could be used by the ISPs. For all of these reasons, the Cable
Carriers submit that they should not be required to provide business TPIA service
with static IP addresses.

SERVICES WITH STATIC IP ADDRESSES

5. The major ILECs and cable companies provide static IP addresses for retail
business internet services in Canada as either an option with a significant
surcharge or as an included feature with the higher-priced premium business
services. An overview of current offers is contained in Attachment 1.
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 3 of 7

6. With regard to wholesale business high-speed internet services, Bell’s Gateway


Access Service (GAS) does not offer static IP Addresses. Bell’s more expensive
dedicated HSA wholesale service does provide static IP addresses to businesses
with its single 6Mbps downstream service – at double or more the price for that
GAS speed. 1 The Cable Carriers believe that TELUS’ wholesale business high-
speed internet services are structured in the same fashion. 2 The Cable Carriers do
not offer wholesale business TPIA service with static IP addresses.

THE CABLE COMPANIES SHOULD NOT BE REQUIRED TO PROVIDE STATIC IP ADDRESSES

(i) Technical challenges and uncertainties


7. As TPIA service has not been implemented elsewhere in the world, there is no
technical precedent that can be implemented in Canada to provide static IP
addresses. The Cable Companies submit that it is unclear whether the method by
which they are able to provide static IP addresses to certain business customers
will work with their TPIA service.

8. Typically, cable companies provide Static IP addresses for businesses by installing


a router at the customer premise. This router which includes an embedded cable
modem uses a specific protocol that associates traffic to and from that router with a
pre-assigned set of dedicated IP addresses. 3 Each Managed Router customer is
assigned a unique customer-specific IP subnet with either a /30 or /29 block of IP
addresses. These blocks are not hosted by the DHCP server that assigns dynamic
IP addresses for all other retail and wholesale internet services. This approach,
referred to as a Managed Router solution, involves distinct routing and network
resources that interface with the cable networks in a manner separate from the
routing of traffic for other internet services (retail and wholesale).

1
http://www.wholesale.bell.ca/pdfs/GASDSL.pdf , http://www.wholesale.bell.ca/pdfs/HSADSL.pdf GAS currently
offers three speeds 640 kbps, 1 Mbps and 6 Mbps downstream. HSA offers only one speed – 6 Mbps downstream.
2
http://about.telus.com/publicpolicy/tariffs/docs/CRTC214_6/Carrier_9/Section_18/item226.pdf
http://about.telus.com/publicpolicy/tariffs/docs/CRTC214_6/Carrier_9/Section_18/item227.pdf
3
For example in the case of Rogers, the CPE Managed Router uses Routing Information Protocol (RIP). The
customer-specific subnets are advertised via RIP, from the CPE router into the network, CMTS, routers and routing
tables.
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 4 of 7

9. This Managed Router solution has never been deployed in architectures used by
the cable companies to provide TPIA service. The Cable Carriers do not know if
the solution will work when interfacing with network resources of a third party or if
the solution can be scaled to more widespread use. The Cable Carriers note that
aside from the issue of static IP addresses some the companies are facing
architecture re-design to provide for more centralized POIs arising from CRTC
2010-632.

10. If the solution can be made to work generally, there will still be situations where the
static IP address will not be permanent. When additional segmentation occurs in
the cable networks and customers are moved to a segment still served by the
same Cable Model Terminating System (CMTS) these end-users must be manually
identified and their static IP assignment re-assigned within the CMTS. However, if
the end-user is now served by a different CMTS device the end-user would not be
able to maintain their static IP address. Cable carriers would have to identify these
users and provide notification of the change in IP.

11. The Cable Carriers note that their inability to provide a permanent static IP address
in all circumstances is typical of both the ILEC and cable industries. For example,
TELUS notes on its website that “For service plans with Static IP Addresses, a
computer or device will have a Long Lease IP address; however, it must be
requested via DHCP. TELUS does not support hard coded IP addresses. Static IP
4
addresses are not available in all areas.”

12. The Cable Carriers further note that the use of /29 and /30 blocks for static IP
addresses quickly consumes addresses as they are carved out of larger blocks
assigned to a neighbourhood. Blocks must be reserved for future static IP address
use in each neighbourhood and this reservation quickly reduces the addresses
available for more efficient dynamic assignment. This concern is not insignificant

http://www.telus.com/en_CA/BC/products/Small_Business/Internet_And_Data/Internet_Access/details/bc
SmbHighSpeedInternetAccess.html#tab2
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 5 of 7

given that several ISP’s already have indicated that they encounter issues with
ARIN in obtaining IP blocks given the limited number of remaining IPV4 address
blocks today.

(ii) Significant costs outweigh limited demand


13. In the event that technical challenges to providing static IP addresses with TPIA
service can be resolved, the Cable Carriers submit that there is substantial doubt
that the development costs of the service would ever be recovered given the
significantly higher rates that would necessarily apply to business TPIA service with
static IP addresses. Development costs will first be incurred to explore whether the
Managed Router solution can be used for TPIA. If this work proves to be
successful further development costs will be incurred to establish the new
procedures necessary for the service.

14. In contrast with automated dynamic IP addresses allocation, static IP address


provision involves much greater complexity and resources. In order to provide this
for retail customers, provisioning team interaction is required to review the IP
subnet with the customer at order time, configure the assigned IP subnet into the
customer CPE router, map each customer-specific IP subnet into the routing tables
throughout the network, bind the IP subnet to a physical client endpoint at
installation time, release IP subnets and manage any changes. The cable carriers
will need to manage which static subnets are assigned to which TPIA end-user
cable modem on behalf of the TPIA ISP. These activities will require significant
human resources.

15. The significant costs of providing static IP addresses are seen in the rates charged
either directly for static IP addresses (Bell charges $25 per address) or in the rates
for services that include static IP addresses (typically $70-100 for 1 or 2 static IP
addresses and $170-200 for 5 static IP addresses).
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 6 of 7

16. The rates for Bell’s Bell HSA wholesale service that includes static IP addresses
are double the rates charged for GAS service that does not provide static IP
addresses.

17. Given the much higher rates that would be charged for business TPIA service with
static IP addresses in order to recover the costs, the Cable Carriers submit that
there is likely to be little demand for such a TPIA service. As explained during the
proceeding leading to TRP 2010-632, cable companies have limited network
facilities into business locations. The combination of limited network footprint and
high cost-based rates will result in limited demand that will not allow the Cable
Carriers to recover the expense of developing the service.

(iii) Practical alternatives are available


18. Finally, the cable carriers note that established off-shelf-alternatives to static IP
addresses could be used by ISPs, such as the DDNS-like service offered by
Dyndns.Com. This is an over-the-top functionality which allows a host/gateway to
register with an outside agent which then modifies a third party forward record with
the registered IP. This service is usually built in to most small CPE routers that are
used in the high-speed internet small and medium-sized business marketplace and
is inexpensive. Such a system essentially allows for a known host-names-DNS
record to be associated with the customer’s CPE router. The router with DDNS
capability automatically updates the DNS record with the IP address of the
configured router whenever the IP address changes. These devices in such a
system can be used as a VPN end point or for operation of a server, thus negating
the need for a static IP in most cases.
Cable Carriers Comments
Follow-up to TRP 2010-632-Show Cause
September 29, 2010
Page 7 of 7

CONCLUSION

19. For the reasons described above, the Cable Carriers submit that they should not
be required to provide business TPIA service with static IP addresses.

Yours very truly,

Yves Mayrand Dennis Béland Ken Engelhart Jean Brazeau


Vice President Senior Director, Regulatory Affairs, Senior Vice President Vice President
Corporate Affairs Telecom Regulatory Telecommunications
Cogeco Cable Inc. Quebecor Media Inc. Rogers Communications Shaw Communications Inc.
Tel.: 514.874.2600 Tel.: 514.380.4792 Tel.: 416. 935.2525 Tel.: 905.403.2043
Fax: 514.874.2625 Fax: 514.380.4664 Fax: 416.935.2523 Fax: 905.403.2630
yves.mayrand@cogeco.com regaffairs@quebecor.com ken.engelhart@rci.rogers.com jean.brazeau@sjrb.ca

Copy: Parties to Follow-up to Decision CRTC 2010-632


Attach.
ATTACHMENT 1

Overview of Services Providing Static IP Addresses

 Bell offers static IP addresses as an option to their business internet services at a


rate of $25 per month per address.
http://www.bell.ca/shop/Sb_Customization.page?reset=customizationBasic

 TELUS provides static IP addresses only with their two top end business internet
services. Rates for these services are $97 per month (includes 2 static IP
addresses) and $167 per month (includes 5 static IP addresses.)
http://www.telus.com/en_CA/BC/products/Small_Business/Internet_And_Data/Intern
et_Access/details/bcSmbHighSpeedInternetAccess.html#tab2

 MTS provides static IP addresses as part of part of service on all but entry level
service.
http://www.mts.ca/portal/site/mts/menuitem.a83a3714bf96d1ed0c2d4a10408021a0/?vgnexto
id=a0693487ce191010VgnVCM1000000408120aRCRD

 Rogers offers static IP addresses only with their two top end internet services,
Managed Router service (Rates for these services are $90 per month (includes 1
static IP address) and $165 per month (includes 5 static IP addresses.))
http://your.rogers.com/business/productsservices/internetservices/access/businessin
ternetaccess.asp

 Shaw offers static IP addresses as an option to their business internet services at a


rate of $9.95 per month per address. Business service packages begin at $54.95
per month http://www.shaw.ca/en-
ca/ProductsServices/Business/Internet/AdditionalIPAddresses.htm
ATTACHMENT 1
Overview of Services Providing Static IP Addresses
Page 2/2

 Videotron provides static IP addresses as an option or as part of service on all but


entry level service. Static IP addresses are offered as an option on the $67.95 plan
(High Speed) at a charge of $30 per month for the first static IP address. One static
IP address is included in $99.95 plan (Extreme), $111.95 (Ultimate 30) and $139.95
(Ultimate 50) plans. http://affaires.videotron.com/web/small-medium-companies/internet-
services/internet-access

 Cogeco also offers static IP addresses as part of their two top end business Internet
service packages (the “Business Standard” package offered at $99.95 per month
includes one static IP address while the “Enterprise” package replaced where
available by the “Ultimate 50”, both offered at $209.95, includes 1/5/13 static
addresses.) http://www.cogeco.ca/cable/on/en/business/internet/forfaits.html ]

*** END OF DOCUMENT ***

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