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Ottawa, 22 July 1992
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Telecom Decision CRTC 92-14
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BELL CANADA - INTRODUCTION OF MICROLINK SERVICE
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I INTRODUCTION
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On 19 November 1991, Bell Canada (Bell) filed Tariff Notice 4166 covering tariff revisions providing for the introduction of Microlink Service. Bell stated that Microlink would be its Integrated Services Digital Network (ISDN) Basic Rate Interface (BRI) offering.
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On 12 December 1991, the Commission issued CRTC Telecom Public Notice 1991-88, calling for comment on Bell's application. By letter dated 16 December 1991, Unitel Communications Inc. (Unitel) addressed a number of questions to Bell. Bell provided its responses, with copies to the Commission, on 20 December 1991. Interrogatories were subsequently addressed to Bell by the Association of Competitive Telecommunications Suppliers (ACTS), Call-Net Telecommunications Ltd. and Fonorola Inc. Bell filed its responses on 10 February 1992.
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In addition to addressing interrogatories, ACTS requested disclosure of information in Bell's application for which the company had claimed confidentiality. By letter dated 13 February 1992, the Commission issued its decision on ACTS' disclosure request, upholding Bell's claim of confidentiality. On 2 March 1992, ACTS filed requests for further responses to its interrogatories. Bell responded to this request on 12 March 1992. By letter dated 25 March 1992, the Commission directed Bell to file further responses by 30 March 1992.
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Comment was filed by Telecentre Consulting Services (TCS) on 29 January 1992, by Unitel on 10 March 1992 and by ACTS on 6 April 1992. Bell filed its reply on 24 April 1992.
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II THE APPLICATION
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In its application, Bell stated that Microlink is based on the ISDN BRI standard as defined in its Interface Disclosure Document ID-0011. Bell stated that Microlink would provide the customer with two 64 kbps bearer (B) channels, which would carry packet data or circuit switched voice or data, and a 16 kbps delta (D) channel, which would be used for signalling or for packet data.
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Bell stated that the Microlink monthly access charge would be roughly double the charge for a Centrex III local. The bill minimum would be one access charge. Payment options would be the same as for Centrex III Service or for Enhanced Exchange Wide Dial Service, specifically, one month, three year and five year terms would be available, with single and multiple wire centre connections. Monthly link charges would apply for Datapac connections, with one rate for dedicated B channel connections andthree for D channel connections, depending on the speed of service.
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III CONNECTION TO COMPETING CARRIER SERVICES
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Bell stated that any service provided by another carrier that is currently accessible from a Centrex III voice or data local would be accessible from a Microlink access.
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Unitel and TCS submitted that Microlink fails to provide for the existing level of interconnection to competing carrier services. Unitel stated that this would force its customers to acquire separate local accesses specifically for Unitel's competing services, thus allowing Bell to confer upon itself an undue preference. Unitel submitted that the Commission should approve Microlink without connection to Bell's competitive services until there is provision for Microlink connection to competing carrier services.
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In reply, Bell stated that Microlink does not change existing arrangements and that both Bell and Unitel services would be accessible via Microlink, with one exception, i.e., there would be no provision for dedicated access to Unitel's packet network. Bell stated that, in light of the Commission's determinations in Bell Canada - Introduction of Megalink Service, Telecom Decision CRTC 92-5, 3 April 1992 (Decision 92 5), it would resume negotiationswith Unitel for provision of dedicated packet access, but that in the interim it would implement Microlink without dedicated access to Unitel's or its own packet network.
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In Decision 92-5, the Commission determined that Megalink tariffs should provide for access to Unitel's network services under the same conditions, including technical conditions, that would apply for Megalink access to comparable Bell services. The Commission notes Bell's submission that any facility provided by another carrier that is accessible from a Centrex III voice or data local would be accessible from a Microlink access. Thus, in the Commission's view, the record indicates that there are no differences in the technical conditions of the connection of Microlink to Bell's and Unitel's competitive services, except for the issue of dedicated packet access. Accordingly, the Commission considers that Microlink tariffs should exclude dedicated access to Bell's packet network, so that Bell does not confer upon itself an undue preference in contravention of section 340 of the Railway Act.
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IV RATES
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ACTS and TCS submitted that, since Microlink allows for simultaneous voice and data transmission, the rate should match the individual line rate plus the information system access line (ISAL) rate.
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In reply, Bell stated that its application demonstrates that the proposed rates are compensatory and maximize contribution. Bell also referred to General Tariff item 4650.8(b), which governs the provision of ISALs and which provides that the ISAL rate does not apply to single-user computers. Bell stated that, when Microlink is terminated on computers other than single-user computers, ISAL rates would apply.
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The Commission's policy with respect to competitive and optional services is to approve rates that yield the maximum contribution over the study period. The Commission notes that Bell's rate sensitivity evidence indicates that increasing the rate to the extent proposed by ACTS would have an adverse effect on the contribution generated by Microlink. In the Commission's view, the proposed Microlink rates were derived in a manner consistent with Commission policy.
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V OTHER ISSUES
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ACTS and TCS submitted that Microlink should be offered as a primary exchange service so that more subscribers would have access to it.
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In reply, Bell stated that it would not be cost effective to equip all central offices with the hardware and software required to offer Microlink as a primary exchange service. Bell submitted that, currently, the most cost effective manner for providing Microlink Service to as wide a customer base as possible is toprovide the service out of central offices equipped for Centrex III.
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The Commission notes that primary exchange services, defined and listed in the General Tariff, are services that are furnished throughout the exchange area and that provide facilities essential to exchange service. In light of the nature of the proposed Microlink Service, the Commission does not consider that ACTS and TCS have advanced sufficient justification to warrant requiring Bell to amend the service to meet these criteria.
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ACTS also submitted that the proposed tariffs show that Microlink Service would only be available to Centrex III customers. ACTS submitted that the service would thus discriminate against those who might wish to subscribe to Microlink, but not to Centrex III.
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In reply, Bell noted that Microlink would be available in as small a quantity as a single access arrangement. Bell stated that a customer would not need to convert from basic service to Centrex in order to acquire Microlink.
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The Commission notes that the Microlink bill minimum is one access and that a subscriber may obtain Microlink while retaining basic individual line service. Thus, in the Commission's view, the proposed tariff would not result in discrimination against those who might wish to subscribe to Microlink, but not to Centrex III.
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ACTS submitted that only Northern Telecom Ltd. (Northern Telecom), hadadvance knowledge of the Microlink specification. ACTS also submitted that, as only Northern Telecom equipment would be tariffed with Microlink, Bell would confer an undue preference on itself over other terminal equipment suppliers in the BRI market.
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In reply, Bell submitted that, through its "Alliance" program with other terminal equipment suppliers, a significant effort is being made to bring a wide variety of terminal products to the market place. Bell also submitted that, by disclosing the specifications, it has fostered and not discouraged competition among terminal equipment suppliers.
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The Commission notes that, in response to interrogatory Bell(ACTS)10Jan92-19, Bell stated that it provided Northern Telecom with the specification one week prior to release, for technical verification purposes. The Commission is satisfied that, in this case, the provision of the specifications one week in advance is not a contravention of section 340 of the Railway Act. In addition, the Commission is satisfied that the public disclosure of the specification ensures no violation of section 340 of the Act with respect to the provision of terminal equipment.
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ACTS also submitted that Bell should be ordered to disclose its T-interface specification, its engineering rules for the U-interface and its engineering rules for the NT-1 interface.
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In reply, Bell stated that theTerminal Attachment Program Advisory Committee (TAPAC) requires disclosure for the terminal-to-monopoly network interface where the supply of terminal equipment is competitive. Bell submitted that, since the T- interface is between pieces of terminal equipment, disclosure of it is not required.
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The Commission notes that Bell must provide for the attachment of customer provided equipment. In Bell's disclosure document ID-0011, the customer equipment is connected to the network at the U-interface. In the Commission's view, this satisfies the conditions for the attachment of customer provided equipment. The Commission is also of the view that it is sufficient for regulatory purposes that Bell has disclosed its specification, which is based on the Canadian Standards Association's CSA T-451, to which terminal equipment suppliers can build.
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Finally, ACTS noted that Bell has specified that terminal gear must comply with CS-03 requirements for network connection. ACTS suggested that it is likely that Part 6 of that standard applies. ACTS submitted that Part 6, although applicable with respect to analogue channel connection, has been opposed by many as being too onerous in the digital environment.
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In reply, Bell stated that CS-03 compliance is required for all terminal gear connection to the network, whether Bell or customer provided.
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The Commission notes that CS-03 is the standard for the attachment of terminal equipment.
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V DISPOSITION OF THE APPLICATION
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In light of the above, the Commission approves Bell's application, modified to eliminate dedicated B channel access to its packet network. The Commission directs Bell to issue final tariff pages, effective 2 November 1992, by 23 October 1992.
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Allan J. Darling
Secretary General
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