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February 22, 2011

Mr. Robert A. Morin


Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, ON K1A 0N2

Re: Telecom Notice of Consultation CRTC 2011-77 – Requests for modifying the scope and
terms of the proceeding

Dear Mr. Morin:

1 The British Columbia Broadband Association (“BCBA”) is in receipt of a letter dated 15 February
2011 from the Commission (Ref.: 8661-C12-201102350) regarding submission of comments to the
request from the Public Interest Advocacy Centre (“PIAC”) on its own behalf and as counsel to the
Consumers' Association of Canada (“CAC”), and from the Canadian Network Operators Consortium
Inc. (“CNOC”).

2 BCBA is also in receipt of a letter dated 10 February 2011 from the PIAC / CAC challenging both the
intended scope of this proceeding and the wording of the issues. In addition, BCBA also received a
letter dated 11 February 2011 from the CNOC requesting that the Commission for broadening the
scope of the proceeding.

3 BCBA is also in receipt of a letter dated 17 February 2011 from JF Mezei / Vaxination which reminds
the Commission that the issues being raised for consideration under this new proceeding are wide
ranging and include suggestions that fundamental changes to the current regulatory regime are
under review. Under the current regulatory framework, Retail Internet pricing is unregulated. Any
proceeding that reviews this framework is likely to be a process that will take several years to
complete.

4 Our members are very aware that the issues of speed matching and access to reasonably priced
wholesale aggregated ADSL services that were the goals of proceeding 2009 – 261 have not been
resolved in a timely fashion. Under the Commission’s current timetable there is some hope that
these issues may be resolved by April of this year.

5 The BCBA is extremely concerned that expanding the scope of 2011-77 may further delay the
implementation of speed matching opportunities at reasonable wholesale pricing. Telecom
Regulatory Policy CRTC 2010-632 should stay on track regardless of the ultimate decision on the
scope of 2011 -77. Our members believe that it is the Commission’s role to issue and enforce its
rulings in a timely fashion. We strongly urge the Commission to complete its review of the TELUS

248 Reid St. Quesnel, BC, V2J 2M2


P 250.992.1230 / F 250.992.3930
info@bcba.ca
speed matching Tariffs and issue final pricing for these services. The goals of 2011-77 should not
prevent timely access to these regulated services.

6 We would like to thank the Commission for the opportunity given to our group to present our
perspective on these issues

Sincerely,

Bob Allen
President - BC Broadband Association
Bob.Allen@abccomm.com

*** End of Document ***

248 Reid St. Quesnel, BC, V2J 2M2


P 250.992.1230 / F 250.992.3930
info@bcba.ca

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