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Telecom Decision
CRTC 93-17
Ottawa, 29 October 1993
AGT LIMITED - INTERCONNECTION OF INTEREXCHANGE CARRIERS AND RELATED RESALE AND SHARING ISSUES
Table of Contents
I INTRODUCTION
II GENERAL ISSUES
A. Concerns Related to Ed Tel
B. Applicability of Terms of Decision 92-12
1. Changed Circumstances Since Decision 92-12
2. Concerns About the Original Decision
III RUNK SIDE ACCESS FOR RESELLERS
IV SPECIFIC TERMS OF INTERCONNECTION
A. General
B. Ed Tel Originated Traffic
C. Discount Schedule For IXCs
D. Discount Schedule For Resellers
E. Contribution Rates For 1993
F. Identification and Recovery of Start-Up Costs
G. Interconnection Arrangements
1. Network Interconnections
2. Access to Other Services and Facilities
H. Recovery of Ongoing Costs
V THE ORDER
I INTRODUCTION
In Competition in the Provision of Public Long Distance Voice Services and Related Resale and Sharing Issues, Telecom Decision CRTC 92-12, 12 June 1992 (Decision 92-12), the Commission concluded that increased competition, subject to certain terms and conditions, was in the public interest in the territories of Bell Canada (Bell), BC TEL, The Island Telephone Company Limited, Maritime Telegraph and Telephone Company Limited, The New Brunswick Telephone Company Limited and Newfoundland Telephone Company Limited (Newfoundland Tel) (collectively, the respondents). The Commission's conclusion was based on an extensive examination of the advantages and disadvantages associated with a wide range of issues. While AGT Limited (AGT) was an active participant in the proceeding leading to Decision 92-12, it was not a respondent. Therefore, Decision 92-12 does not apply to it. As well, the specific circumstances of the company and the particular characteristics of its operating territory were not examined in the proceeding in the same detail as was the case for the respondents.
In Resale and Sharing in the Territory of AGT Limited, Telecom Public Notice CRTC 92-66, 19 November 1992 (Public Notice 92-66), the Commission established a proceeding to consider allowing the resale and sharing of the telecommunications services of AGT under the terms and conditions established in Decision 92-12. That proceeding was established, in part, in response to an application from Cam-Net Telecommunications Inc. (Cam-Net) for orders permitting such resale and sharing.
On 11 December 1992, Unitel Communications Inc. (Unitel) applied to the Commission for the interconnection of its network with the public switched telephone network (PSTN) of AGT for the purposes of providing public long distance voice telephone services. Unitel requested that the interconnection be granted on terms and conditions in accordance with those established in Decision 92-12.
On 8 January 1993, the Commission issued AGT Limited - Interconnection of Interexchange Carriers and Related Resale and Sharing Issues, Telecom Public Notice CRTC 93-1 (Public Notice 93-1), superseding Public Notice 92-66 and initiating a proceeding to consider allowing the interconnection of interexchange carriers (IXCs) to AGT's network and the resale and sharing of the telecommunications services of AGT, under the terms and conditions established in Decision 92-12. Public Notice 93-1 also requested comment on whether resellers should be permitted trunk-side access to AGT's network. Parties to the proceeding established in Public Notice 92-66 were made parties to the new proceeding.
The Commission received submissions from AGT and Unitel, and from the following: BC TEL, Bell, Cam-Net, City of Calgary (Calgary), Competitive Telecommunications Association (CTA), Edmonton Telephones Corporation (Ed Tel), Newfoundland Tel and the Government of Saskatchewan.
AGT does not oppose interexchange competition or resale and sharing. However, it has proposed certain modifications to the regime established in Decision 92-12 to account for: (1) the presence of Ed Tel within its operating territory; (2) changes in circumstances since Decision 92-12, in particular, the alliance between Unitel and AT&T and its impact on Unitel's financial position and market share; and (3) concerns over the methods and reasoning underlying certain of the Commission's conclusions in Decision 92-12, particularly concerns related to contribution avoidance using direct access lines (DALs), estimated minutes per trunk and the need for a true-up or reconciliation mechanism for contribution charges.
In order to reflect its concerns, AGT proposed that:
(1) the contribution calculation reflect foregone revenue for toll traffic originated/terminated in Ed Tel territory;
(2) the contribution surcharge to reflect the use of DALs be increased significantly;
(3) no explicit contribution discount be granted to IXCs like Unitel;
(4) resellers not be granted transitional discounts;
(5) an annual contribution true-up mechanism be implemented;
(6) IXCs and resellers pay their share (35% rather than 30%) of start-up costs within 30 days (rather than amortized over 10 years); and
(7) resellers obtain trunk-side access under the same terms and conditions established for IXCs.
II GENERAL ISSUES
A. Concerns Related to Ed Tel
1. Positions of Parties
AGT contended that the presence within its operating territory of Ed Tel, Canada's largest municipally-owned telephone company, raises issues that were not contemplated in Decision 92-12. According to AGT, Ed Tel operates under the legislative authority of the Alberta Telecommunications Act (the Alberta Act). AGT stated that this Act establishes Ed Tel as the exclusive provider of local services in Edmonton, and AGT as the exclusive provider of long distance services in Alberta, including Edmonton. As well, AGT stated that the Alberta Act requires Ed Tel to provide funds to finance telephone services in Alberta that are not self-supporting.
In light of the above, AGT submitted that all competitor traffic in Edmonton should be routed through an AGT switch and be subject to contribution payments towards non-self-supporting services in Alberta. In order to prevent contribution bypass, AGT also proposed to prohibit line-side connections to switches in the Edmonton core area or which have Extended Flat Rate Calling (EFRC) arrangements with the core.
Ed Tel was of the view that the Alberta Act is not an impediment to its interconnection with companies other than AGT. It noted that it currently has interconnection agreements with such companies as Unitel and Telesat Canada.
Ed Tel, Unitel and Cam-Net took exception to AGT's position that Edmonton traffic carried by competitors must be routed through the AGT switch in Edmonton and be subject to contribution payments. Ed Tel argued that AGT should not receive payment for Edmonton traffic that is carried by another carrier. Ed Tel took the position that there are two separate markets in Alberta (Edmonton and the rest of Alberta) and that AGT is attempting to thwart the benefits of competition by treating Edmonton toll traffic as if it was entitled to it.
Ed Tel, Unitel and Cam-Net also opposed AGT's position that resellers should not be permitted to have line-side connection to Ed Tel's network or to AGT's switches in communities surrounding Edmonton in order to prevent contribution avoidance through EFRC links between AGT and Edmonton.
AGT submitted that, should direct interconnection between Unitel and Ed Tel be permitted, the contribution mechanism should be modified to establish a surcharge for Edmonton-originated toll traffic. AGT proposed that its contribution requirement (i.e., its shortfall) be based on Alberta as a whole, specifically, that its net revenues from Edmonton-generated toll traffic be included in its overall contribution target, and that the target be divided by total AGT and entrant minutes in AGT and Ed Tel territories. AGT's proposal is based on the premise that all toll minutes in Alberta are currently AGT minutes and make a contribution to the local/access shortfall. AGT argued that, to be consistent with Decision 92-12, competitors have to make up on all eroded minutes.
Ed Tel suggested that all originating and terminating minutes in Edmonton be excluded from any calculation of contribution and that only AGT's net toll contribution from the Edmonton market be included.
Unitel stated that, in Decision 92-12, the Commission noted Unitel's intention to commence negotiations with independents and to compensate them at the same level as would apply to their existing connecting carriers. Unitel argued that, since it and AGT fully compensate Ed Tel for Edmonton traffic, these minutes should not enter into the AGT calculation. Furthermore, Unitel argued that surplus revenues associated with AGT's Edmonton traffic should be removed from the calculation. Otherwise, Unitel argued, its contribution obligation under Phase III would be artificially inflated if Unitel originates very little or no traffic in Edmonton. Unitel noted that its proposal would still reflect contribution required on traffic originated in AGT's territory that terminates in Edmonton.
Calgary was of the view that an equitable contribution from subscribers in Edmonton must be maintained and that the Unitel proposal should be rejected as it did not achieve this objective.
AGT argued that, under Decision 92-12, respondent telephone companies are entitled to compensation for any foregone contribution revenues that migrate from their networks to those of competitors. In response, Ed Tel and Unitel noted that Decision 92-12 also states that respondents are not entitled to be compensated for lost contribution arising from competition in another company's territory.
2. Conclusions
The relationship between AGT and Ed Tel in respect of the carriage of long distance traffic and the subsidization of non-self-supporting services in Alberta raises issues that did not arise in the proceeding leading to Decision 92-12.
In particular, AGT argued that the Alberta Act precludes Unitel's interconnection with Ed Tel. In Telecom Order CRTC 93-774, 20 September 1993 (Order 93-774), the Commission approved an interconnection agreement between Unitel and Ed Tel, effective 28 October 1993. In so doing, the Commission noted that it does not regulate Ed Tel and has no legal responsibility to interpret and apply the Alberta Act.
In Order 93-774, the Commission also stated that all interexchange traffic originated in Edmonton should contribute to offsetting the costs of providing basic service throughout Alberta, and that it would address the contribution issue more fully in the present Decision.
In regard to that issue, the Commission notes that it is not bound by law to compensate AGT for the loss of traffic associated with a decision by Ed Tel to allow its customers to choose their long distance carrier. However, the question arises as to whether, as a matter of regulatory policy, revenues associated with Edmonton toll traffic, regardless of the toll carrier, should contribute to the support of local/access services throughout Alberta and on what basis. To address this question, the Commission has taken into account (1) the settlement principles established by the Arbitration Decision of 1987, and (2) the principles established by the Commission in Decision 92-12.
With reference to the first point, the Commission notes that, under the Arbitration Decision, which is based on the premise that AGT is the only provider of long distance service in the province, (1) AGT and Ed Tel are entitled to a share of toll revenues generated in Edmonton, and (2) AGT and Ed Tel accept the obligation to provide funds to finance Alberta telephone services that are not self-supporting.
With reference to the second point, the Commission notes that, until now, all toll calls originated or terminated in Edmonton have been carried on AGT's network and have resulted in contribution to AGT. When toll traffic is carried on Unitel's network, the contribution associated with that traffic will be lost to AGT. In Decision 92-12, the Commission found reasonable Unitel's proposal to pay contribution based on the amount of foregone contribution arising as a result of its entry.
Thus, both the terms of the Arbitration Decision and the principles underlying the contribution regime established in Decision 92-12 are consistent with the concept that toll traffic originating in Edmonton should continue to contribute towards local/access services elsewhere in Alberta on the basis of foregone contribution. Further, the Commission is of the view that all subscribers in Alberta should contribute equitably to the support of local/access services in the province.
The Commission finds the proposals of Ed Tel and Unitel to be inappropriate as they would not attain the objectives set out above. Rather, the Commission finds that contribution to be paid to AGT shall be calculated by including AGT's net revenues from Edmonton-generated toll traffic in its overall contribution target, and dividing that target by total AGT and entrant minutes in AGT and Ed Tel territories.The Commission notes Ed Tel's concern that, under the settlement agreement with AGT, subscribers in Edmonton may be paying more towards the subsidization of non-self-supporting services in Alberta than AGT subscribers, due to the fact that whatever AGT keeps after its initial settlement with Ed Tel is used solely to reduce AGT's shortfall. However, Ed Tel's evidence on this matter was not submitted until it filed final argument and therefore it was never tested.
Finally, the Commission must determine whether, as suggested by AGT, resellers should be denied line-side connections to AGT switches in exchanges with EFRC to Edmonton and line-side connections to the Ed Tel network. AGT's suggestion is based on the concern that resellers might use EFRC arrangements in the Edmonton area to avoid contribution, specifically, that a reseller in the territory of one company could be accessed through EFRC over the local network of the other, thus bypassing the payment of contribution to the company to which it is due.
AGT indicated in response to a Commission interrogatory that it could mitigate the impact (on AGT) of line-side access in Edmonton if Ed Tel provided a list of local access numbers assigned to competitors in Edmonton so that AGT could programme its switches to screen and block access to these numbers.Ed Tel argued that such restrictions are unnecessary, since it has the technical capacity to block access and egress to its network and has Unitel's agreement not to bypass.
The Commission finds that both AGT and Ed Tel have adequate ability to control contribution bypass and thus finds it unnecessary to prohibit resellers from obtaining line-side access to switches in AGT exchanges with EFRC into Edmonton.
B. Applicability of Terms of Decision 92-12
1. Changed Circumstances Since Decision 92-12
a. Positions of Parties
As noted earlier, AGT argued that circumstances have changed since Decision 92-12, and that the regime established in that Decision should therefore be modified as it would apply to AGT. In particular, AGT cited the alliance between Unitel and AT&T, noting statements in the press by Unitel President George Harvey as to the increased benefits to Unitel as a result of the alliance. AGT argued that, as a result of the alliance, Unitel is now in a better position than the Commission had assumed it would be in when it issued Decision 92-12. Among the key points noted by AGT are that Unitel's financial position is more stable, its access to new service technology and research and development is enhanced and its access to larger customers will be facilitated. AGT contended that, as a result, Unitel's market share will be greater and (1) it no longer requires a contribution discount to establish itself in the market, (2) it can afford to pay start-up costs up front, and (3) the DAL surcharge should be increased because Unitel's share of large customers will increase and more DALs will therefore be in use.
AGT also raised arguments related to assumptions, used in the calculation of contribution charges, as to the number of minutes carried over an interconnecting trunk. Specifically, AGT argued that, because Unitel's penetration in the residential market has been higher than anticipated, its off-peak minutes will be higher. AGT submitted that, if the assumed minutes per trunk used in the contribution calculation set out in Decision 92-12 are not increased, Unitel will obtain greater contribution discounts than contemplated.
Finally, AGT argued that, since Unitel will be able to compete in Alberta and likely in Manitoba, one reason for granting it a contribution discount, i.e., lack of geographic coverage, will disappear.
Unitel disagreed that the terms of Decision 92-12 should be altered. It argued that its alliance with AT&T is a response to the alliance between Stentor and MCI. Second, it noted that its alliance with AT&T does not alter the underlying cost of competing or change the fact that equal access is still not available. Finally, Unitel noted that the primary reason for a contribution discount is the advantage arising from the telephone companies' historical dominance in the long distance market. Unitel submitted that AGT is the dominant carrier in Alberta and that there are no advantages associated with the alliance with respect to Unitel's ability to offset the telephone company's dominance.
Unitel also argued that it is too early to alter the assumed trunk-loadings. In addition, absent equal access, non-conversation time on trunks will be higher. It noted that, with line-side connection, it is not possible to estimate the number of minutes per trunk accurately. Further, Unitel submitted that its earlier entry into smaller communities will mean fewer minutes per circuit.
In response to AGT's arguments with respect to geographic coverage, Unitel noted that it will take time for it to roll out its services and provide universal origination, particularly absent equal access.
b. Conclusions
In Decision 92-12, the Commission found that the respondents to that proceeding held a market advantage over all competitors in the long distance voice market as a result of their control of the local networks and their historically dominant positions. Primarily because of those advantages, but also in recognition of the fact that unequal ease of access and market coverage would further limit competitors in the early years, the Commission found that a contribution discount of limited duration would be appropriate. The Commission found the discount schedule proposed by Unitel to be reasonable. Under that proposal, the discount is phased out as the competitive disadvantages are reduced and competitors have an opportunity to capture greater market share. In addition, the potential for contribution erosion is minimized because the greater discounts apply in the early years when competitors are expected to have relatively small market shares.
Further, in Decision 92-12, the Commission found it appropriate to allocate start-up costs on the basis of estimates of the long-run market share of all competitors, including the respondents. The Commission estimated that the respondents' market share loss would be approximately 30% by the year 2002. Accordingly, the Commission determined that IXCs would pay 30% of the start-up costs through tariffed charges and that the remaining 70% would be allocated to the respondents. In addition, the Commission recognized that a transition period was needed to arrive at a fully competitive marketplace and that IXCs might be handicapped by assigning an excessive level of start-up cost recovery to the early years of competition. The Commission concluded that, in order to avoid over-burdening initial entrants, a fair and reasonable period for the amortization of start-up costs was 10 years.
In this proceeding, AGT based its expected long-run market share loss on the Choice Demand Model used in the proceeding leading to Decision 92-12. However, AGT argued that the Model underestimates its market share loss because it assumes that the market share loss will be the same in Edmonton as in the rest of the province and that customers not specifically choosing a new entrant will automatically default to the incumbent carrier. AGT predicted a long-run market share loss of 35%. AGT's estimate is based on a 30% long-run market share loss in those parts of Alberta where AGT is the local service provider and a 50% long-run market share loss in Edmonton, where it maintains "only a limited market presence."
Unitel found it difficult to accept AGT's estimate of a 50% market share loss in Edmonton, stating that AGT is well known in the Edmonton market and has provided long distance telephone service to that community for decades.
In the Commission's view, 12 months of competition is not sufficient time to predict whether long-run market share loss to competitors will be significantly different from that foreseen in Decision 92-12 for the respondents to that proceeding. This is particularly so given that equal access has not yet been implemented and in light of the various market strategies adopted by the telephone companies and by entrants.
While the alliance with AT&T is likely to prove beneficial to Unitel, particularly in terms of its ability to attract large customers, any advantages achieved through the alliance may be offset by Stentor's alliance with MCI. Further, even with the alliance, Unitel must still prove itself in the market place through the delivery of high quality service. Finally, Stentor has ubiquitous origination and, as noted above, equal access has not yet been implemented.
In brief, the Commission is not persuaded that Unitel's alliance with AT&T is sufficient to obviate AGT's historical advantage as a monopoly provider of toll services, an advantage which underlies the Commission's findings in Decision 92-12 as to the need for contribution discounts, the level of start-up costs to be paid and the period over which those costs should be recovered from entrants. With regard to AGT's more specific estimates of long-run market share loss, the Commission is not persuaded that AGT's market share loss in Edmonton will be as significant as predicted by the company.
Further, the Commission notes that the method for calculating start-up charges takes into account the time value of money and the time at which the market share is attained. The recovery method corrects for an error in estimation of market share and, to some extent, for the timing of market share loss. If the loss is greater than estimated, the recovery will be greater than 30% of the estimated costs.
In light of the above, the Commission considers it appropriate that contribution discounts remain in place for Unitel, as well as for other competitors, and that the portion of start-up costs to be recovered from IXCs and the amortization of those costs be established on the basis set out in Decision 92-12.
Based on adjustments to the Choice Demand Model to reflect, among other things, Unitel's alliance with AT&T, AGT estimated its short-term market share loss at 1.6% in 1993 and 15.5% in 1994. As discussed in detail in AGT Limited - Revenue Requirements for 1993 and 1994, Telecom Decision CRTC 93-18, 29 October 1993, the Commission considers that AGT has overestimated the market share that it will lose both to Unitel and to resellers, and that adjustments to the company's estimates are warranted. The Commission estimates AGT's market share losses at 1.4% for 1993 and 12.1% for 1994, and has incorporated these estimates into its calculation of the appropriate contribution charges.
With regard to trunk loading, the Commission considers that there is insufficient evidence available at this time to justify a departure from Decision 92-12. Once equal access is available in high and low density markets, however, the Commission will be able to measure actual average minutes per trunk in each telephone company's operating territory. While some adjustments to take account of call completions and set-up times may still have to be factored in, the Commission considers that the additional information will make it feasible to further refine the trunk loading factors applied.
The Commission's views as to appropriate DAL surcharges are set out below.
2. Concerns About the Original Decision
a. DAL Surcharges
In Decision 92-12, the Commission recognized that difficulties would arise from attempts to identify the specific numbers of DALs carrying traffic eligible for contribution payments. Accordingly, the Commission did not consider it feasible to levy a direct contribution charge on DAL traffic. Rather, the Commission considered it preferable to increase the contribution charge for switched access in order to compensate for the use of such facilities. In light of concerns that the use of DALs would increase if the surcharge were too high and its view that the average amount of traffic travelling over DALs was likely to be significantly less than over switched lines, given the dedicated nature of such access, the Commission concluded that the application of a 2% contribution surcharge would be appropriate.
In this proceeding, AGT argued that the DAL surcharge should be set at the same level as the DAL loading factor. Specifically, AGT proposed a surcharge of 24%. It is AGT's position that, since Decision 92-12 does not require that a direct contribution charge be applied to traffic carried on DALs, competitors would have an incentive to use DALs, not only where they are more efficient from a network point of view, but also where contribution can be avoided. The application of a surcharge set at the level of the traffic carried on DALs would avoid this distortion of the economics of using switched versus dedicated access. AGT also considered that Unitel's estimate of minutes of traffic carried on DALs was too low, given its view that Unitel would likely focus on large customers as a result of its alliance with AT&T, and that the surcharge should therefore be increased.
Calgary and Newfoundland Tel supported DAL surcharges that reflect usage levels.
Unitel argued that a higher charge on switched access to account for DALs would only increase the incentive to use them. Moreover, Unitel argued that AGT's analysis failed to take into account many of the costs of constructing or leasing DALs. Unitel argued that, in the early years, there is an incentive to carry more traffic over its switched network in order to gain more efficiency from under-utilized circuits and reduce fixed costs.
Bell submitted that entrants have a strong incentive to reduce contribution payments and that DAL bypass will be a key element in entrants' strategies. Bell noted that Unitel's own estimates (Market Rollout Plan, Revised Unitel Evidence, 17 May 1993) indicate that 23% of originating and 6% of terminating minutes would be associated with DALs in 1994. Bell submitted that it may be in Unitel's interest to down-play the significance of DAL bypass, and that its estimates should therefore be closely scrutinized and regarded as conservative. Bell also submitted that the DAL surcharge of 2% is not just or sufficient compensation for competitors' DAL use; rather, the appropriate DAL surcharge should be commensurate with the proportion of minutes associated with DALs.
Cam-Net stated that, currently, only 3.5% of its traffic originates on DALs, which is considerably less than the 24% predicted by AGT.
In reply argument, AGT stated that, based on Cam-Net's evidence, the 2% surcharge should be retained for resellers.
The Commission notes that Unitel's estimates of DAL usage are consistent with forecasts filed in the proceeding leading to Decision 92-12. The Commission is not persuaded on the basis of AGT's arguments that the 2% DAL surcharge should be changed. Rather, it considers that the reasons set out in Decision 92-12 for establishing the surcharge at that level remain valid; specifically, that the use of DALs may increase if the surcharge is set too high. Further, a higher DAL surcharge would be punitive for any IXC or reseller with a low ratio of DAL to switched access traffic.
Accordingly, in AGT's territory, the Commission will maintain the DAL surcharge at 2%.
b. Route-Averaged Pricing For Resellers
AGT was of the view that resellers should route-average their prices across all markets they serve.
Cam-Net and CTA submitted that route-averaged pricing for resellers is not required, as determined by the Commission in Decision 92-12. Cam-Net further stated that the mix of underlying facilities costs across the country makes it very difficult to offer route-averaged pricing.
Decision 92-12 requires Unitel and other IXCs to route-average their rates across the territory of a particular respondent. However, in Decision 92-12, the Commission stated it had not imposed route-averaging on resellers, and that it did not intend to do so after facilities-based entry. The Commission considered that such a policy would unduly limit the benefits associated with resale. Further, under the new Telecommunications Act, resellers that are not Canadian carriers are not regulated and thus cannot be required to use route-averaged pricing (see Exemption of Resellers from Regulation, Telecom Public Notice CRTC 93-62, 4 October 1993).
c.Contribution True-Up Mechanism
AGT submitted that the contribution mechanism established by the Commission in Decision 92-12 does not ensure that the entire loss of contribution to the telephone company will be paid. AGT submitted that an annual "true-up" mechanism, whereby the company would receive the difference between the contribution actually required and that actually paid, would protect carriers, subscribers and competitors.
This issue was considered in the proceeding leading to Contribution Charges Effective 1 April 1993, Telecom Decision CRTC 93-11, 29 July 1993 (Decision 93-11), in which several parties submitted that the process for determining appropriate contribution charges should be modified to allow for the reconciliation of forecasted contribution rates to actuals. In Decision 93-11, the Commission rejected this suggestion, noting (among other things) that it had adopted a contribution mechanism with the intention of keeping ongoing regulatory intervention and involvement to a minimum and concluding that the various reconciliation processes proposed would serve to undermine that objective. Rather, the Commission stated that, in future proceedings to determine contribution charges, it would include an examination of historical variances in the forecasting of those charges and would require parties to file evidence regarding their forecasting accuracy. In addition, the Commission stated that it would require competitors having at least 0.5% market share in the previous year to file historical and forecasted demand information.
The Commission remains of the view that the process of establishing contribution charges should not be further complicated. Accordingly, the Commission does not consider it necessary to modify the current process to include the establishment of a "true-up" mechanism.
The Commission notes that AGT will, in future, be made a party to the annual proceeding for establishing contribution charges.
III TRUNK SIDE ACCESS FOR RESELLERS
Public Notice 93-1 invited comment on whether resellers should be granted trunk-side access to AGT's PSTN and, if so, the terms and conditions that should apply and the regulatory obligations that should be imposed.
AGT did not object to providing resellers with trunk-side access, provided that such resellers met all of the constraints and obligations imposed on IXCs. Specifically, such resellers should be required (1) to pay start-up costs on the same basis as Unitel, (2) to pay contribution charges at the same level as Unitel, and (3) to route-average their prices.
In Trunk-Side Access by Resellers to the Public Switched Telephone Network, Telecom Decision CRTC 93-8, 23 July 1993 (Decision 93-8), the Commission approved trunk-side access for resellers in the territories of the Decision 92-12 respondents. The Commission approves trunk-side access for resellers operating in AGT's territory under the terms and conditions set out in Decision 93-8. Specifically, resellers are to pay the transitional reseller contribution on line-side connections and on Canada-U.S. and Canada-Overseas traffic, and the IXC level of contribution on trunk-side connections. Such resellers are also to pay the rates set for IXCs for the recovery of start-up costs and for switching and aggregation.
In Decision 93-8, the Commission stated that no service provider whose rates are not subject to regulation should be permitted to connect pay telephones. The Commission remains of this view. The Commission also stated in Decision 93-8 that mechanisms to take the place of tariff provisions related to customer confidentiality and to the provision of operator services would have to be developed before unregulated service providers could be granted access to billing and collection services and related databases. As indicated in that Decision, the Commission will issue a public notice inviting comment on the form those mechanisms might take and what, specifically, they should provide for. As also stated in Decision 93-8, the Commission considers that, without such mechanisms, resellers with trunk-side access should not be permitted to have access to billing and collection services and related databases.
In Decision 93-8, the Commission did not depart from the position that resellers should not be required to route-average their prices. Further, as noted above, under the new Telecommunications Act, resellers that are not Canadian carriers cannot be required to use route-averaged pricing.
IV SPECIFIC TERMS OF INTERCONNECTION
A. General
The terms and conditions of interconnection in AGT's territory are detailed below. To the extent that there is no mention of matters addressed in Decision 92-12, the terms and conditions of that Decision will apply.
B. Ed Tel Originated Traffic
As stated in Part II of this Decision, the Commission considers that toll traffic originating in Edmonton should contribute towards non-self-supporting services elsewhere in Alberta on the basis of foregone contribution. In the Commission's view, the most efficient means of accomplishing this objective is to recover contribution directly from Unitel based on its interconnecting circuits in Edmonton and from resellers using AGT or Unitel interexchange facilities based on the number of interexchange circuits originating or terminating in Edmonton.
Accordingly, Unitel and other IXCs will pay contribution directly to AGT based on the number of their interconnecting circuits with Ed Tel. Reseller contribution for Edmonton originated and terminated traffic will be a flat rate for each interexchange circuit leased from AGT, Unitel or other IXC. Unitel and other IXCs will pay AGT the contribution collected from resellers for the use of their circuits.
The Commission notes that arrangements for the settlement of revenues under the agreement between Unitel and Ed Tel approved in Order 93-774 function independently from the above.
C. Discount Schedule For IXCs
Given AGT's commitment to provide equal access at approximately the same time as the 92-12 respondents, AGT should be put on the same discount schedule as those respondents.
For IXCs in Alberta, the Commission approves the modified discount schedule established for Bell, BC TEL, Island Tel and MT&T in Unitel Communications Inc. - Application for the Extension of the Contribution Discount Period and Other Matters, Telecom Decision CRTC 93-5, 19 April 1993. Specifically, a 25% discount will apply to 30 June 1996, a 15% discount will apply from 1 July 1996 to 30 June 1997, and a 10% discount will apply from 1 July 1997 to 30 June 1998.
D. Discount Schedule For Resellers
In Decision 92-12, the Commission provided a discount to resellers in order to allow them to adjust their activities for the increase in contribution charges over those payable under the regime established in Resale and Sharing of Private Line Services, Telecom Decision CRTC 90-3, 1 March 1990 (Decision 90-3). Specifically, resellers were given an initial 20% discount over and above the 15% discount applicable to line-side interconnection. This 20% discount is to be reduced by 5% a year until it is eliminated entirely in 1997.
It is AGT's position that, since Decision 90-3 did not apply to Alberta, there is no need for a special discount to allow resellers to adjust their activities.
AGT argued that immediately establishing resellers' contribution at 85% of the applicable contribution charge for equal access toll office interconnection would limit uneconomic entry by new resellers.
CTA and Cam-Net noted that the situation in Alberta is no different from the situation that existed in Atlantic Canada prior to Decision 92-12. Despite the absence of resellers there, the Commission found it appropriate to grant a contribution discount to resellers in the Atlantic provinces. As well, they noted that there are some resellers already operating in Alberta, under a limited resale regime.
The Commission is of the view that there is a requirement for transitional contribution discounts for resellers in Alberta. The Commission notes that many resellers operate in more than one province, and considers it desirable that the basic condition under which they operate be relatively consistent from one area of the country to another. Further, the Commission considers that AGT is currently in exactly the same position as were the Atlantic telephone companies prior to Decision 92-12, since those companies were also not subject to Decision 90-3.
Accordingly, the transitional discount schedule approved in Decision 92-12 will apply to resellers with line-side access in Alberta, as set out below:
Portion of Contribution Rate Payable
65%
70%
75%
80%
85%
Year
1993
1994
1995
1996
1997
E. Contribution Rates For 1993
Consistent with the methodology established in Decision 92-12, the Commission sets the following per-minute, per-end contribution rates for 1993:
IXCs (trunk-side) $0.0679
Resellers (line-side) $0.0441
For the detailed calculations, see the Attachment to this Decision.
F. Identification and Recovery of Start-up Costs
AGT estimated that its start-up costs would be $37.9 million. Unitel considered that AGT's estimates should be adjusted by the same proportion as the respondents' estimated start-up costs were reduced in Decision 92-12.
The Commission has examined the estimates provided by AGT and finds that the company has included some costs that should not have been included and that some estimates are somewhat high. For example, the Commission considers that costs for Feature Group A (FGA) access should be excluded, as this type of interconnection is similar to one currently available. Also, AGT has not, in the Commission's view, fully justified estimates for Feature Group B (FGB) and Feature Group D (FGD) software greater than those filed by the respondents in the proceeding leading to Decision 92-12. The Commission has therefore reduced these estimates. In light of the above, the Commission finds $29.2 million to be a reasonable estimate of start-up costs for AGT.
As indicated previously, the Commission has reviewed the submissions regarding the apportionment and recovery of start-up costs, and finds that the conclusions reached in Decision 9212 proceeding are appropriate with respect to AGT. On that basis, and on the basis of the determination in the preceding paragraph, the Commission finds that the rate for the recovery of start-up costs is appropriately set at $0.00081 per minute of switched originating and terminating traffic.
G. Interconnection Arrangements
1. Network Interconnections
Unitel requested interconnection arrangements with AGT similar to those requested from the respondents in the 92-12 proceeding. AGT generally agreed to provide the arrangements requested by Unitel. As in the proceeding leading to Decision 92-12, Unitel requested interconnection arrangements for access to its 800 Service, but, in this case, Unitel stated its intention to also use these arrangements for access to its long distance services. AGT did not comment on this proposed use of 800 Service access.
AGT projected the following access availability dates assuming a Commission decision in the third quarter of 1993:
a. Line-Side Access (FGA) - Available upon entry;
b. Trunk-Side Access (FGB) - March 1994;
c. Trunk-Side Access (FGD/MF) - October 1994; and,
d. Trunk-Side Access (FGD/CCS-7) - October 1994.
The Commission finds AGT's projected availability dates appropriate.
2. Access to Other Services and Facilities
Unitel requested access to AGT's Wide Area Telephone and 800 Services, access to its network from AGT pay telephones, directory assistance, and billing and collection services. The formation of a Joint Technical Committee was also requested.
Unitel requested that these accesses and services be provided on the same terms as in Decision 92-12. The Commission finds that the provisions of Decision 92-12 are appropriate.
H. Recovery of Ongoing Costs
The Commission considers that the interim use of the $0.011 per minute switching and aggregation charge specified in Decision 92-12 is appropriate. The charge will apply for each switched minute of originated and terminated traffic and, as stated in Part VI of Decision 92-12, is related to all associated functions performed by AGT.
V THE ORDER
Based on the findings in this Decision and in Decision 92-12, the Commission sets out below the requirements applicable to AGT and Unitel.
AGT
1. AGT is directed to issue tariff pages forthwith incorporating Appendices I and II, modified as necessary to reflect the specific services offered by the Company.
2. AGT is directed to file proposed availability intervals by switch type for the implementation of 1+ and 1+950 access, indicating any specific exemptions, within 30 days of the date of this Decision.
3. AGT is directed to file proposed tariffs for overflow routing, consistent with the findings of Decision 92-12, within 120 days of the date of this Decision.
4. Unitel may file with AGT a request for interconnection, serving a copy on the Commission.
5. (a) AGT is directed to establish a Joint Technical Committee with Unitel, as described in Decision 92-12, within 15 days of the receipt of Unitel's request for interconnection; alternatively, upon request from Unitel, AGT is to participate in JTCs established through Stentor.
(b) AGT is directed to negotiate the technical details of the interconnection arrangements, consistent with the findings in this Decision and in Decision 92-12, within the forum of the Joint Technical Committee.
(c) AGT is directed to file proposed tariffs specifying the technical terms and conditions of the arrangements within 60 days of the receipt of the request.
6. (a) AGT is directed to establish an Interexchange Carrier Group, as described in Decision 92-12, within 30 days of the receipt of Unitel's request for interconnection.
(b) AGT is directed to negotiate an agreement with Unitel specifying the procedures of the Interexchange Carrier Group.
(c) AGT is directed to file a proposed agreement with the Commission within 60 days of the receipt of Unitel's request for interconnection.
7. (a) Upon receipt of a request from Unitel for specific information exchanges and reports, such as a supply of weekly reports of names and addresses of all new subscribers and those changing their addresses, AGT is directed to negotiate the details of such reports or information exchanges consistent with the findings in Decision 92-12.
(b) AGT is directed to file proposed tariffs for the specific information exchange or report within 60 days of the receipt of the request.
Unitel
Unitel is directed to issue tariff pages forthwith incorporating Appendix III, modified as necessary to reflect the specific services it offers.
Allan J. Darling
Secretary General
APPENDIX I
TARIFF FOR INTERCONNECTION WITH UNITEL
1.Definitions
For the purposes of this tariff item:
"Circuit" means a voice-grade analog channel or a 64 kbps (DS-0) channel.
"Circuit Group" means a group of equivalent circuits.
"Data Service" means a telecommunications service other than a voice service.
"Dedicated Service" means a telecommunications service which is dedicated to the private communications needs of a user where one end of the facility used to provide the service is terminated at equipment dedicated to the user.
"Interconnecting Circuit" means a circuit that connects a facility of Unitel to a facility of AGT or Ed Tel to provide access to the public switched telephone network (PSTN) of AGT or Ed Tel. An interconnecting circuit may connect (1) a Unitel facility to a central office to which subscriber lines are directly connected (end office); or (2) an interexchange circuit to a Centrex switch; or (3) a local circuit from a Unitel switch to a Centrex switch; or (4) a Unitel facility to a central office to which end offices are directly connected in order to originate or terminate toll traffic (toll office).
"Interexchange Service" or "Interexchange Facility" means a service or facility configured to operate between any two exchanges for which Message Toll Service charges would apply, including overseas and international services and facilities.
"Joint-Use Basis" means on a basis in which a circuit is not dedicated to a single user.
"Overseas Access Circuit" means a circuit which connects to a service or a facility of Teleglobe for the purpose of providing overseas service.
"Resale" means the subsequent sale or lease on a commercial basis, with or without adding value, of a telecommunications service leased from the Company.
"Reseller" means a person engaged in resale.
"Sharing" means the use by two or more persons, in an arrangement not involving resale, of a telecommunications service leased from the Company.
"Sharing group" means a group of persons engaged in sharing.
"User" means a person or a member of a sharing group using a telecommunications service or facility for the person's or member's private communications needs.
"Voice Service" means a two-way telecommunications service involving direct real-time voice communication between two or more natural persons, but does not include a service the purpose of which is limited to the co-ordination or setting up of a data service.
2. General
(a) The facilities and services of Unitel may be interconnected to the Company's facilities and services, subject to their availability, in accordance with the terms and conditions set out in this tariff.
(b) Unless otherwise specified in an approved tariff or agreement, Unitel may not use the Company's services to originate competitive public switched interexchange voice services in the operating territories of telephone companies other than AGT, Bell Canada, BC TEL, The Island Telephone Company Limited, Maritime Telegraph and Telephone Company Limited, The New Brunswick Telephone Company Limited or Newfoundland Telephone Company Limited.
(c) Unitel may not provide local public pay telephone service.
(d) Where Unitel offers shared tenant services, it must provide the Company with direct access, under reasonable terms and conditions, to tenants who choose to receive service from the Company rather than, or in addition to, service from Unitel.
(e) Unitel traffic may not be aggregated or terminated using the switched services of a reseller or a sharing group.
3. Requirement to Furnish Test Facilities
(a) The Company shall furnish to Unitel, interconnecting circuits, CCS7 connections and WATS and 800 connections, with appropriate ANI or Caller ID signalling, for the purpose of testing its network.
(b) Connections furnished to Unitel pursuant to this section shall be restricted to testing functions. Unitel shall not use these connections to carry any of its administrative or commercial traffic.
(c) Contribution charges shall not apply to facilities designated as test facilities.
4. Notice of Network Changes
The Company shall provide Unitel with at least two years' notice in writing of any changes in its network that could affect any of the interconnection or access arrangements contemplated in this tariff. Where it is not possible to give Unitel two years' notice, the Company shall advise Unitel as soon as a decision to proceed with the change has been made.
5. Notice of Network Outages
The Company shall provide Unitel with the earliest possible notice of all network outages affecting the operation of Unitel's network.
6. Interconnection Charges
(1) Interconnecting Circuits
The Company will furnish interconnecting circuits at rates specified in the Company's tariffs.
(2) Network Charges
Where Unitel requests an interconnecting circuit providing 1+950, 1+ or 10XXX access (trunk-side access), a switching and aggregation charge of $0.011 also applies to each minute of traffic carried on the interconnecting circuit.
This charge relates to all associated switching, transport and signalling functions performed by the Company at the originating or terminating end of a call, including:
(a) hardware answer supervision;
(b) delivery of calling line identification;
(c) casual calling;
(d) pay telephone access;
(e) busy line verification;
(f) barge-in services;
(g) directory assistance;
(h) billing and collection services; and
(i) database queries/access.
(3) Recovery of Start-Up Costs
Where Unitel is provided with 1+950, 1+ or 10XXX access, a further charge $.00081 per minute related to the recovery of start-up costs applies to each minute of originating or terminating traffic.
7. Contribution Charges
(a) Interconnecting Circuits
(i) Where the interconnecting circuit is associated with trunk side access, the monthly contribution charges specified below shall apply for each interconnecting circuit within a circuit group.
CONTRIBUTION TABLE
# of circuits in the
circuit group
1 - 3
4 - 6
7 - 9
10 - 14
15 - 19
20 - 29
30 - 39
40 - 49
50 - 74
75 - 99
100 plus
Per Circuit
Contribution Charge
$ 50
160
230
290
335
380
415
445
465
490
520
(ii) Where the interconnecting circuit is associated with line side access, 85% of the applicable contribution charges in Item 7(a)(i) above shall apply.
(b) Overseas Access Circuits
Note: For each overseas access circuit located in the Company's operating territory, used by Unitel, Teleglobe shall collect the monthly contribution charges specified in Item 7(a)(i) from Unitel pursuant to Teleglobe's tariffs and shall remit the payment to the Company.
(c) Canada-U.S.A. Circuits
For each Unitel Canada-U.S.A. circuit which uses a border crossing point located in the Company's operating territory, the monthly contribution charge of $475 shall apply.
(d) Terminations in Ed Tel territory
On a monthly basis, Unitel shall report the number of interconnecting circuits that it terminates in Ed Tel territory and remit to the Company contribution charges as specified in 7(a) above.
8. Exemptions
(a) Where an interconnecting circuit is used solely to access the Company's MTS/WATS services, the contribution charges specified in Item 7 shall not apply.
(b) Where an interconnecting circuit associated with line side access, a Canada-U.S.A. circuit, an overseas access circuit is used to provide a data service or a dedicated service, the contribution charges specified in Item 7 shall not apply, provided that Unitel applies to the Commission on a case by case basis and provides evidence satisfactory to the Commission that by reasons of the technical, economic or operational characteristics of the service, it is unlikely that the connections will be used significantly for voice service.
(c) Where an interconnecting circuit associated with line side access, a Canada-U.S.A. circuit, or an overseas access circuit is used by a reseller or a member of a sharing group to provide a joint-use interexchange voice service, the contribution charges specified in the Company's General Tariff - Resale and Sharing shall apply in place of the contribution charges specified in Item 7. Unitel shall collect the contribution payment from the reseller or sharing group pursuant to Unitel's tariff and shall remit the payment to the Company.

APPENDIX II

GENERAL TARIFF - RESALE AND SHARING

1. Definitions
For the purposes of this tariff item:
"Affiliate" means any person that controls or is controlled by the Company or that is controlled by the same person that controls the Company.
"Circuit" means a voice-grade analog channel or a 64 kbps (DS-0) channel.
"Circuit Group" means a group of equivalent circuits.
"Control" includes control in fact, whether or not through one or more persons.
"Data Service" means a telecommunications service other than a voice service.
"Dedicated Service" means a telecommunications service which is dedicated to the private communications needs of a user where one end of the facility used to provide the service is terminated at equipment dedicated to the user.
"Interconnecting Circuit" means a circuit that connects a facility of a reseller or sharing group to a facility of AGT or Ed Tel to provide access to the public switched telephone network (PSTN) of AGT or Ed Tel. An interconnecting circuit may connect (1) a facility of a reseller or a sharing group to a central office to which subscriber lines are directly connected (end office); or (2) an interexchange circuit to a Centrex switch; or (3) a local circuit from a switch of a reseller or a sharing group to a Centrex switch.
"Interexchange Service" or "Interexchange Facility" means a service or facility configured to operate between any two exchanges for which Message Toll Service charges would apply, including overseas and international services and facilities.
"Joint-Use Basis" means on a basis in which a circuit is not dedicated to a single user.
"Overseas Access Circuit" means a circuit which connects to a service or a facility of Teleglobe for the purpose of providing overseas service.
"Resale" means the subsequent sale or lease on a commercial basis, with or without adding value, of a telecommunications service leased from the Company.
"Reseller" means a person engaged in resale.
"Sharing" means the use by two or more persons, in an arrangement not involving resale, of a telecommunications service leased from the Company.
"Sharing group" means a group of persons engaged in sharing.
"User" means a person or a member of a sharing group using a telecommunications service or facility for the person's or member's private communications needs.
"Voice Service" means a two-way telecommunications service involving direct real-time voice communication between two or more natural persons, but does not include a service the purpose of which is limited to the co-ordination or setting up of a data service.
2. General
(a) The Company's telecommunications services may be shared or resold in accordance with the conditions in this tariff.
(b) Resellers and sharing groups are required to register with the Company and the Commission prior to receiving service.
(c) Unless otherwise specified in an approved tariff or agreement, resellers and sharing groups may not use the Company's services to originate competitive public switched interexchange voice services in the operating territories of telephone companies other than AGT, Bell Canada, BC TEL, The Island Telephone Company Limited, Maritime Telegraph and Telephone Company Limited, The New Brunswick Telephone Company Limited or Newfoundland Telephone Company Limited.
(d) The provision of public pay telephone service by resellers and sharing groups is not permitted.
(e) Where a reseller offers shared tenant services, it must provide the Company with direct access, under reasonable terms and conditions, to tenants who choose to receive service from the Company rather than, or in addition to, service from the reseller.
(f) Interexchange services shall not be provided to an affiliate of the Company, or to a sharing group which involves one or more persons who is an affiliate of the Company, where such services would be resold on a joint-use basis or shared to provide interexchange interconnected voice services, except where such services would be used only to provide portable communications services.
3. Interconnection Charges
The Company will furnish interconnecting circuits at rates specified in the Company's tariffs.
4. Contribution Charges
(a) Interconnecting Circuits
The monthly contribution charges specified below shall apply for each interconnecting circuit within a circuit group.
CONTRIBUTION TABLE
Contribution Charge Per Circuit
# of circuits in the
circuit group
1 - 3
4 - 6
7 - 9
10 - 14
15 - 19
20 - 29
30 - 39
40 - 49
50 - 74
75 - 99
100 et plus


$30
100
150
190
220
245
270
290
305
315
340
(b) Overseas Access Circuits
Note: For each overseas access circuit located in the Company's operating territory, used by a reseller or a member of a sharing group, Teleglobe shall collect the monthly contribution charges specified in Item 4(a) from the reseller or the sharing group pursuant to Teleglobe's tariffs and shall remit the payment to the Company.
(c) Canada-U.S.A.
Circuits For each Canada-U.S.A. circuit leased by a reseller or a sharing group from the Company, a monthly contribution charge of $310 shall apply.
(d) Terminations in Ed Tel territory
Based on Ed Tel's provision of trunk side access, for each interexchange circuit that terminates in Ed Tel territory leased by a reseller or a member of a sharing group, the monthly contribution charge shall be $456.
5. Exemptions
(a) Where an interconnecting circuit is used solely to access the Company's MTS/WATS services, the contribution charges specified in Item 4 shall not apply.
(b) Where an interconnecting circuit, a Canada-U.S.A. circuit, an overseas access circuit is used to provide a dedicated voice or data service, a local service, or a joint-use interexchange data service, the contribution charges specified in Item 4 shall not apply, provided that the reseller or the sharing group applies to the Commission on a case by case basis and provides evidence satisfactory to the Commission that by reasons of the technical, economic or operational characteristics of the service, it is unlikely that the connections will be used significantly for joint-use interexchange voice.

APPENDIX III

GENERAL TARIFF - RESALE AND SHARING

For the purposes of this tariff item:
"Affiliate" means any person that controls or is controlled by Unitel or that is controlled by the same person that controls Unitel.
"Circuit" means a voice-grade analog channel or a 64 kbps (DS-0) channel.
"Circuit Group" means a group of equivalent circuits.
"Control" includes control in fact, whether or not through one or more persons.
"Data Service" means a telecommunications service other than a voice service.
"Dedicated Service" means a telecommunications service which is dedicated to the private communications needs of a user where one end of the facility used to provide the service is terminated at equipment dedicated to the user.
"Interconnecting Circuit" means a circuit that connects a facility of a reseller or sharing group to a telephone company switch to provide access to the telephone company's public switched telephone network (PSTN). An interconnecting circuit may connect: (1) a facility of a reseller or a sharing group to a telephone company central office to which subscriber lines are directly connected (end office); or (2) an interexchange circuit to a telephone company Centrex switch; or (3) a local circuit from a switch of a reseller or sharing group to a telephone company Centrex switch.
"Interexchange Service" or "Interexchange Facility" means a service or facility configured to operate between any two exchanges for which Message Toll Service charges would apply, including overseas and international services and facilities.
"Joint-Use Basis" means on a basis in which a circuit is not dedicated to a single user.
"Overseas Access Circuit" means a circuit which connects to a service or facility of Teleglobe for the purpose of providing overseas service.
"Resale" means the subsequent sale or lease on a commercial basis, with or without adding value, of a telecommunications service leased from the Company.
"Reseller" means a person engaged in resale.
"Sharing" means the use by two or more persons, in an arrangement not involving resale, of a telecommunications service leased from Unitel.
"Sharing group" means a group of persons engaged in sharing.
"Telephone Company" means AGT, Bell Canada, BC TEL, The Island Telephone Company, Maritime Telegraph and Telephone Company Limited, The New Brunswick Telephone Company Limited, or Newfoundland Telephone Company Limited or any other company with which Unitel has an approved interconnection agreement.
"User" means a person or a member of a sharing group using a telecommunications service or facility for the person's or member's private communications needs.
"Voice Service" means a two-way telecommunications service involving direct real-time voice communication between two or more natural persons, but does not include a service the purpose of which is limited to the co-ordination or setting up of a data service.
2. General
a) Unitel's telecommunications services may be shared or resold in accordance with the conditions in this tariff.
(b) Resellers and sharing groups are required to register with Unitel and the Commission prior to receiving service.
(c) Unless otherwise specified in an approved tariff or agreement, resellers and sharing groups may not use Unitel's services to originate competitive public switched interexchange voice services in the operating territories of companies other than AGT, Bell Canada, BC TEL, The Island Telephone Company Limited, Maritime Telegraph and Telephone Company Limited, The New Brunswick Telephone Company Limited or Newfoundland Telephone Company Limited.
(d) Interexchange services shall not be provided to an affiliate of Unitel, or to a sharing group which involves one or more persons who is an affiliate of Unitel, where such services would be resold on a joint-use basis or shared to provide interexchange interconnected voice services, except where such services would be used only to provide portable communications services.
3. Contribution Charges
Contribution charges shall apply for each interconnecting circuit within a circuit group, overseas access circuit within a circuit group, or Canada-U.S.A. circuit provided by Unitel to a reseller or a sharing group, at terms and conditions specified in the general tariffs for resale and sharing of the telephone companies within whose territory the above-mentioned circuits are located.
Attachment
AGT LIMITED
Calculation of Contribution 1993
A. Contribution Requirement ($Millions):
1. Phase III Equivalent Non-Toll Exp. 1,008.5
2. Phase III Equivalent Non-Toll Rev* 576.4
    Deduct: Contribution Rev 2.75 573.7
    Phase III Equivalent Non-Toll Deficit 434.8
3. WATS Reclassification 0.0
4. Common/PUC 47.8
5. Settlement -45.9
6. Level of Contribution Required (1-2-3-4-5) 432.9
B. Toll Minutes Calculation:
7. AGT Switched Orig & Term Mins 4,491.1
8. (a) Entrant Switched Orig & Term Mins 53.4
(b) DALS Loading (Fixed Factor) 1.1735
(c) Entrant Switched & Non-Switched Mins 62.6
(d) Entrant Stim. Mins Ratio (Fixed Factor) 0.0678
(e) Entrant Sw & Non-Sw Stim Mins 4.2
9. Market Sw & Non-Sw Mins w/o Entrant Stim. 4,549.5
10.Contribution per Minute per End $0.0952
C. Multiplicative Adjustments:
11. Gross Receipts Tax (applicable to Bell only) 1.0
12. DAL Surcharge 1.02
13. Discount 0.75
14. Stim. Min. Factor 0.9322
15. Contribution per Min per End - IXC $0.0679
16. Reseller Discount 0.65
(a) Contribution per Min per End - Reseller $0.0441
* Reflects adjustment for Toll Uncollectibles
Date modified: