Re: Lower Rates and Higher Speeds for Xnet High Speed Internet Service

Cable & Wireless Dominica (“C&W”) is pleased to announce a number of proposed changes to our Xnet High Speed Internet Access Service in Dominica. As Xnet internet services are considered as regulated pursuant to the Telecommunications (Retail Tariff) Regulations, 2004, Cable & Wireless is seeking the Commission’s approval to make these reductions.

Proposed Changes

The proposal makes a number of significant changes to C&W’s high speed internet offerings to increase their attractiveness to both residential and business customers and to drive the take-up of these services. These include:

Increasing the speeds of all existing residential with reductions to some of the prices – the minimum speed for any package will be 1 Mbit/s which is significantly higher than C&W’s current packages.
Reducing the prices and increasing the speeds of the business packages.
Introduction of an entry level business package at a significantly lower price to make this service more accessible to small businesses. Many of these businesses currently use residential packages for their business – this package will give these customers the additional functionality of the business service at a price which is very close to that paid for residential service.
Changes to the names of each package to reflect the new speeds.
Additional options for service support and equipment.
Additional value added services.
Rebranding of Xnet High Speed Internet to “Cable & Wireless Broadband”

In each case, existing customers will receive more value for either the same or less money. Further details are set out in the sections which follow.

The specifics of C&W’s current Residential Xnet Internet Access packages, as well as those proposed in this filing are set out in the following tables. Changes are highlighted:

Table 1: Residential XNet packages

Residential XNet Packages
Current Name	Speed (download/upload) (kbps unless noted)	Price	New Name	New Speed (download/upload) (kbps unless noted)	New Price
X128	128/64	$99	Mega	1024/256	$89
X256	256/128	$129	X1544	1544/256	$129
X512	512/256	$199	Mega Plus	2048/512	$169
X768	768/256	$349	Mega Max	3072/768	$259
X1544	1544/768	$379	Mega Max	3072/768	$259
Xnet on Demand	256/128	$45*	Xnet on Demand	1024/256	$45*

*($5 per additional hr. after the initial 12)

Table 2: Business XNet packages

Business XNet Packages
Current Name	Speed (download/upload) (kbps unless noted)	Price	New Name	New Speed (download/upload) (kbps unless noted)	New Price
			Premier	1024/256	$149
			Premier Plus	3072/512	$279
Business X512	512/128	$349	Premier Max	4096/768	$349
Business X768	768/256	$500	Premier Max	4096/768	$349
Business X1544	1544/512	$799	Premier Max	4096/768	$349

In addition to the above changes in speed and rate, a number of additional changes are proposed which will differentiate the services on more than just price or speed. Customers will now receive a different modem based on the package chosen. Residential customers will receive a single port modem (Mega), 4-port modem (Mega Plus) or 4-port plus wireless modem (Mega Max). Business customers will receive a single port modem (Premier) or a 4-port modem (Premier Plus) or 4-port plus wireless modem (Premier Max). Customers of Mega Max, Premier Plus and Premier Max will be entitled to free onsite installation.

C&W will also significantly modify the support it provides for internet customers outside of normal working hours. All customers will continue to be entitled to 24/7 support by phone. However, in the event that a fault cannot be resolved over the phone, or where the customer wishes to have a technician come to their home or office, C&W will now provide for such visits outside of normal working hours. Note that C&W currently does not offer on-site support after normal working hours to all customers. Pursuant to this proposal, customers of Mega Max and Premier Max will receive free after hours on-site support. Customers of Mega Plus and Premier Plus will be entitled to on-site support for a standard fee, and customers of Mega and Premier will be able to access this service for a premium fee. These fees are designed to recover the costs of sending a technician to the home or office, and are paid on a per call-out basis (that is, they are charged based on the resolution of a fault, not by time). C&W uses outside contractors to fix faults and must be able to cover the costs billed by those contractors. Note that this service will not be available after 10:00pm at nights.

Finally, C&W will offer several new value-added services as part of the various packages outlined above. All customers will receive a dial-up account free of charge which they can use either concurrently with or as an alternative to their XNet connection depending on their package. All Premier broadband customers will, in the near future, be given access to security features and online storage.

These various features are summarized in the table that follows

Table 3: Package features

Package	Modem	Installation	After Hours Support	VAS
XNet on Demand	Single port	Self-install	Premium Fee	Backup dialup
Mega	Single port	Self-install	Premium Fee	Backup dialup
Mega Plus	4-port	Self-install	Standard Fee	Backup dialup
Mega Max	4-port + wireless	On-site	Free*	Backup dialup
Premier	Single port	Self-install	Premium Fee	Backup dialup Security 10GB free storage Web page 50MB
Premier Plus	4-port	On-site	Standard Fee	Backup dialup Premium Security 20GB free storage Web page 100MB
Premier Max	4-port + wireless	On-site	Free*	Backup dialup Premium Security 40 GB free storage Web page 150 MB

Security and Online Storage will not be technical feasible by September 1^st and are planned to be implemented by December 1^st 2007.

*Limited to 2 requests per month

After hours support can not be offered on copper line plant quality faults. After hours support charges will not be applied if a fault is not correctly diagnosed as copper line plant quality fault by dispatcher. This service will not be offered after 10:00pm.

C&W believes that these revised packages offer significant additional value to customers. Existing residential customers will receive either the same or better speeds for the same or lower price and will be migrated automatically to the new package that corresponds with their current service (for example, a customer on X128 will be automatically migrated to the Mega (1 Mbps) package at a lower price). Business customers will have much greater choice – small businesses will now have the choice of a lower cost entry plan which gives a full 1Mbps of bandwidth for a price which is much closer to that offered to residential customers. Business customers on this plan will get significant added benefits in the value added services offered to business customers and C&W is hopeful that these added benefits will entice many business customers who currently use residential service to switch to a business plan. At the same time, high bandwidth business users will now have the option of subscribing to Premier Max (4 Mbps) at a price which is significantly less than the current price for X768 and X1544 service. Business customers on the current X512, X768 and X1544 plan will be migrated to the Premier Max (4 Mbps) plan and their rates reduced from $349, $500 and $799 respectively to $349.

C&W notes that the residential X1544 service will not be a general service offering. In order to ensure that customers on the X256 service pay the same after these changes, C&W proposes to migrate them to the X1544 service at the same price. However, this service will not be available to new subscribers.

Given the significant benefits of this proposal to all existing and future C&W internet users, C&W submits that its proposal is clearly in the public interest, and should be approved as quickly as possible.

Regulatory Treatment

C&W notes that Xnet High Speed Internet Access Service is a regulated service, and that this application is an application to change the tariffs for this existing service. Accordingly, pursuant to regulation 16 of the Telecommunications (Retail Tariff) Regulations, 2004, C&W formally applies for approval of its application to make the changes specified above. Consistent with the requirements of regulation 16, by copy of this letter, C&W has notified ECTEL of its application, and will notify the general public.

In accordance with the requirements of Rule 8 of the Price Cap Plan, C&W has attached a Rate Change Compliance Filing which calculates the new Actual Price Index for Basket 3, and indicates that the modifications are consistent with the Price Cap Plan (“PCP”). As noted above, this proposal either decreases or keeps rates the same for existing packages. As such, there can be no issue of the rates exceeding any caps under the PCP. As the rates are in compliance with the Price Cap Plan, the Commission must approve them in accordance with Regulation 20.

The proposal also establishes all new packages under the XNet service; Mega, Mega Plus, and Mega Max and Premier, Premier Plus and Premier Max. As these are new packages, they will not appear in the PCP until the next ACF is filed at the end of this year.

Finally, if approved, this promotion will result in C&W no longer offering the X128, X256, X512, X768 package (business and residential), and the Business X512, X768 and X1544 package. Accordingly, C&W notifies the Commission pursuant regulation 15(3) of the Regulations that it will discontinue these packages effective from October 1^st 2007 provided that the other changes proposed in this filing are approved.

Effective Date

C&W intends to make these changes effective from September 1^st, 2007.

Should you have any questions in relation to this proposal, contact me as soon as possible.

Yours Sincerely,

Nabeel T. Bhatti

Chief Executive

Tel: 255 3116

bmobile: 275 4000

e-mail: nabeel.bhatti@cw.com

c.c. Managing Director, ECTEL

Geoff Batstone, Vice President, Legal and Regulatory, C&W