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Ottawa, 19 November 1993
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Telecom Public Notice CRTC 93-68
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TERMINAL-TO-NETWORK INTERFACE DISCLOSURE REQUIREMENTS
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The Terminal Attachment and Policy Advisory Committee (TAPAC) was formed by the Department of Communications (DOC) in order to afford interested parties (for example, telecommunications carriers and terminal equipment manufacturers) the opportunity to participate voluntarily in the development of network protection standards for terminal equipment. Responsibility for TAPAC was recently transferred to Industry and Science Canada (ISC), and it is to ISC that TAPAC refers its consensual decisions as to procedures and standards. Following publication in the Canada Gazette and a period for public comment, ISC issues the procedures and standards.
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In Attachment of Subscriber-Provided Terminal Equipment, Telecom Decision CRTC 82-14, 23 November 1982 (Decision 82-14), the Commission stated that the certification procedure published as CP-01, Issue 3 (CP-01), provided a satisfactory approach to equipment certification. Since Decision 82-14, compliance with the CP-01 procedures for (1) equipment certification according to TAPAC certification standards (i.e., CS-03), and (2) network change notification when proposed network changes would render existing equipment incompatible, has generally been required by virtue of the tariffs of telephone companies regulated by the Commission.
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Subsequent to Decision 82-14, but prior to Competition in the Provision of Public Long Distance Voice Telephone Services and Related Resale and Sharing Issues, Telecom Decision CRTC 92-12, 12 June 1992, CP-01 (Part I, Paragraph 4.11) was amended to expand the circumstances in which network disclosure is required. The amendment, which has not been incorporated into the tariffs of the telephone companies, requires that disclosure be made when the introduction of a new service requires a new or augmented terminal-to-network interface that will not affect the operation of existing customer-provided equipment. CP-01 states that disclosure is intended to provide timely information to manufacturers to facilitate the competitive supply of terminal equipment and to provide an environment that encourages the development of telecommunications services.
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CP-01 requires that a preliminary disclosure be provided prior to a field trial incorporating the new or augmented interface. Preliminary disclosure provides a basic description of the proposed interface, as well as the name of the party from whom specifications can be obtained. Terminal suppliers can normally acquire the specifications during the trial. Final disclosure is to be made at least six months before the service begins. Disclosure is made by sending the disclosure information to ISC, which then distributes a Notice of Disclosure to registered interested parties.
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Telephone companies regulated by the Commission have generally acceded to the disclosure provisions of CP-01 with respect to the terminal-to-network interface. In fact, the Commission has on occasion made the approval of a tariff contingent upon a carrier making public sufficient information to enable the competitive provisioning of terminating equipment. However, the Commission has never made disclosure according to paragraph 4.11 of Part I of CP-01 a pre-condition to tariff approval.
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In a recent proceeding regarding Tariff Notice 782 filed by Unitel Communications Inc. (Unitel), the Commission received comments from Stentor Resource Centre Inc. (Stentor) on behalf of AGT Limited (AGT), BC TEL, Bell Canada (Bell), The Island Telephone Company Limited (Island Tel), Maritime Telegraph and Telephone Company Limited (MT&T), The New Brunswick Telephone Company Limited (NB Tel) and Newfoundland Telephone Company Limited (Newfoundland Tel). Stentor expressed concern that Unitel had not disclosed information regarding a terminal-to-network frame relay interface in accordance with established procedures. Stentor asserted that CP-01 does not distinguish by network or carrier type, or provide for exemptions to the disclosure requirement; rather, the procedures are meant to apply uniformly and consistently to all network providers, regardless of their size or market share.
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In Telecom Order CRTC 93-730, 27 August 1993, the Commission granted interim approval to Unitel's Tariff Notice 782. The Commission also stated that it intended to review the procedures regarding interface disclosure pursuant to TAPAC Certification Procedure CP-01 as they relate to Unitel and other facilities-based carriers. Accordingly, the Commission hereby initiates a public proceeding to consider if adherence to the disclosure requirements of CP-01 should be a pre-condition to tariff approval. Interested parties are invited to comment on the disclosure provisions of CP-01 as they relate to the carriers and on the classes of service to which disclosure provisions should apply, as well as on any other relevant issues.
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Procedure
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1. AGT, BC TEL, Bell, Island Tel, MT&T, NB Tel, Newfoundland Tel, Northwestel Inc. and Unitel are made parties to this proceeding.
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2. Other persons wishing to participate in this proceeding must notify the Commission of their intention to do so by writing to Mr. Allan J. Darling, Secretary General, CRTC, Ottawa, Ontario, K1A 0N2, by 10 December 1993 (fax: 819-953-0795). The Commission will issue a complete list of parties and their mailing addresses.
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3. Parties may file comments with the Commission, serving copies on all other parties, by 24 December 1993
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4. Parties may file reply comments with the Commission, serving copies on all other parties, by 7 January 1994.
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5. Where a document is to be filed or served by a specific date, the document must be actually received, not merely mailed, by that date.
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6. Copies of Certification Procedure CP-01 are available from the following ISC offices:
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Headquarters
Industry and Science Canada
(Attention DOSP-P)
300 Slater Street
Ottawa, Ontario
K1A 0C8
(613) 990-4761
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Atlantic Region
Industry and Science Canada
7th Floor, Terminal Plaza Building
P.O. Box 5090
1222 Main Street
Moncton, New Brunswick
E1C 8R2
(506) 851-6225
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Quebec Region
Industry and Science Canada
295 St-Paul Street, East
Montréal, Quebec
H2Y 1H1
(514) 283-5682
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Ontario Region
Industry and Science Canada
9th Floor
55 St Clair Avenue East
Toronto, Ontario
M4T 1M2
(416) 973-8215
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Central Region
Industry and Science Canada
200-386 Broadway Avenue
Winnipeg, Manitoba
R3C 3Y9
(204) 983-7471
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Pacific Region
Industry and Science Canada
800 Burrard Street
Vancouver, British Columbia
V6Z 2J7
(604) 666-5477
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Allan J. Darling
Secretary General
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