Letter
Ottawa, 6 April 1998
BY FAX ONLY
To: PN 96-28 List
Re: Commission Decisions Regarding Certain CRTC Interconnection Steering Committee Consensus Items and Disputes
Dear Sir or Madam:
The Commission has addressed a number of items brought before it by the CRTC Interconnection Steering Committee (CISC) and has made findings as outlined below.
Network-to-Network Technical Interface For Local interconnection - Call Completion to a Portable Number
The Technical Interface Sub-Working-Group of the CISC prepared a document titled Network-to-Network Technical Interface For Local interconnection - Call Completion to a Portable Number, Version 1.0, dated 1997 10 30. After confirmation of a consensus in the CISC Co-ordinating Committee, the document was submitted to the Commission for consideration.
The Commission has reviewed the document and considers it appropriate. The Commission approves the interface described.
Network-to-Network Technical Interface For Local interconnection - NP Query-Response Network Capability
The Technical Interface Sub-Working-Group of the CISC prepared a document titled Network-to-Network Technical Interface For Local interconnection, - NP Query-Response Network Capability Version 1.0, dated 1997 10 30. After confirmation of a consensus in the CISC Co-ordinating Committee, the document was submitted to the Commission for consideration.
The Commission has reviewed the document and considers it appropriate. The Commission approves the interface described.
Network Planning Sub-Working-Group - Facility Build Principle, Implementation Alternative & Process
The Network Planning Sub-Working-Group of the CISC prepared a document titled Network Planning Sub-Working-Group Consensus Report on Facility Build Principle, Implementation Alternatives & Process, NPRE007, reference NPSWG TIF #2, Issue 2.0, Oct 14 1997. After confirmation of a consensus in the CISC Co-ordinating Committee, the document was submitted to the Commission for consideration.
The Commission has reviewed the document and considers it appropriate. The Commission approves the contents of the document.
Emergency Services Sub-Working-Group - Development of Standard Form Agreement(s) Between CLECs and Municipalities/Associations
The Emergency Services Sub-Working-Group provided English and French versions of a standard form agreement for the Assignment and Collection of Receivables for use in the province of Québec between CLECs and Municipalities/Municipal Associations, attached to reports ESRE006B and ESRE006C dated 15 January 1998. After confirmation of a consensus in the CISC Co-ordinating Committee, the form agreements were submitted to the Commission for consideration.
The Commission has reviewed the form agreements and considers them appropriate. The Commission approves the form agreements.
Data Interchange Sub-Working-Group - Canadian Data Interchange Guidelines
The Data Interchange Sub-Working-Group submitted a report to which was attached the proposed Canadian Data Interchange Guidelines, DIRRE002A, version 1.0, 14 January 1998. After confirmation of a consensus in the CISC Co-ordinating Committee, the report was submitted to the Commission for consideration.
The Commission has reviewed the proposed Canadian Data Interchange Guidelines and considers them appropriate. The Commission approves the Canadian Data Interchange Guidelines.
Network Planning Sub-Working-Group - Facilities Build Principles - Default Technology
This dispute is related to the default technology of the facilities required to establish transmission links between local exchange carriers. The Stentor companies were of the view that there should be no default technology, so that the interconnecting parties would be required to decide the appropriate interconnection facilities while considering related issues such as the suitability of existing facilities, forecast for demand, and the technology required to satisfy economically the requirements.
The Competitors (AT&T Canada Long Distance Services Company, Canadian Cable Television Association, Clearnet Communications Inc., fONOROLA Inc., MetroNet Communications Corp., Microcell Communications Inc., Sprint Canada Inc., TelcoPlus Services Inc., Vidéotron ltée.) proposed that, in cases where the parties cannot agree on the appropriate technology, fibre be adopted as the default technology. The Competitors argued that since there must be concurrence between the parties as to the technology to be deployed, and since, in the long term, fibre will be the most efficient and capable of handling long term growth, the Commission should prescribe fibre as the default technology. The Competitors were of the view that, without guidelines, the Competing Local Exchange Carriers (CLECs) would be at the mercy of the Incumbent Local Exchange Carriers (ILECs).
The Commission observes that the parties agreed that, in some instances, fibre is not the most appropriate technology to use because of the facilities in place. The Commission considers that it is not reasonable to construct new facilities in every case where there is a dispute over whether existing facilities are adequate or could be made adequate at a cost lower than that of constructing new facilities. The Commission is of the view that mandating fibre as the default technology may have the effect of causing the inefficient construction of new facilities and that, accordingly it would be preferable to rule on a case by case basis on such situations.
The Commission does not consider it advisable to mandate a default technology for facilities used for interconnection between LECs.
Network Planning Sub-Working-Group - CLEC Direct Access to Stentor Company 800/888 Database
This dispute is related to CLEC access to the Stentor Company 800/888 databases. The databases are used to route toll-free 800/888 calls to the interexchange carrier (IXC) providing the service. Decision 97-8 directed the Stentor companies to route CLEC originated 800/888 calls to the appropriate IXC. The Decision also directed that alternate approaches be studied. One alternative examined is to provide CLECs with direct access to the database to enable them to route calls to IXCs directly.
Stentor noted that CLECs or other parties could construct their own databases. Stentor also noted that access to its database would require major modification to separate the carrier identification capability from the Stentor toll-free service capability as well as to provide secure access to the database for multiple competing carriers.
The Competitors (AT&T Canada Long Distance Services Company, Canadian Cable Television Association, Clearnet Communications Inc., fONOROLA Inc., MetroNet Communications Corp., Microcell Communications Inc., Sprint Canada Inc., TelcoPlus Services Inc., Vidéotron ltée.) were of the view that CLECs should have direct access for the purpose of routing 800/888 calls to the correct carrier. The Competitors noted that, without direct access, all 800/888 calls would have to be routed through the ILEC even if the call was destined to a vertically integrated CLEC's IXC network. CLECs also noted the option of building a national database. They did not consider the option of a CLEC database viable because the CLEC 800/888 traffic was insufficient to warrant building a second database and the cost would be out of proportion with the requirements.
Though the Commission would generally favour direct access to the Stentor 800/888 database, given the cost to Stentor of modifying its database and the uncertain scope of the gain from providing direct access, the Commission does not consider it either necessary or appropriate to mandate direct access at this time.
The Commission also notes that databases are periodically redesigned in order to improve efficiency. The Commission is of the view that the Stentor companies should seriously consider the provision of direct access during the course of an appropriate redesign.
The Commission also notes the Competitors suggestion regarding a national all-carriers database. The option of a national database administered by an independent third party has many potential benefits for all Canadian carriers and the Commission encourages further exploration of this option.
Central Funds Sub-Working-Group - Expansion of ILEC Extended Area Service Boundaries and Extended Flat Rate Calling Areas
This dispute was initiated by Call-Net Enterprises Inc. (Call-Net) and is related to the alteration of free local calling areas and the impact such alteration would have on the payment of contribution specifically and on competitors generally.
On 26 November 1997, the Commission requested comments on whether paragraphs 7, 23 and 24 of Decision 97-8 imply that contribution will be calculated based on the incumbent local exchange carriers' (ILEC) boundaries as they exist on 1 January 1998, regardless of the boundaries of the local calling areas that may be defined by any ILEC after 1 January 1998 or by any CLEC.
AT&T Canada Long Distance Services Company, ACC TelEnterprises Ltd., Call-Net Enterprises Inc., and Westel Telecommunications Ltd. (collectively, the Competitors) were of the view that the only logical interpretation of paragraphs 7, 23 and 24 of Decision 97-8 is that the present ILEC boundaries used to establish whether a call attracts contribution are to be maintained, at least during the Price Cap regime. The competitors were of the view that the Decision indicated that free local calling area boundaries and toll boundaries had been "de-linked." The Competitors were also of the view that it would be inequitable and inconsistent with the co-carrier status of CLECs to allow only ILECs to change free calling areas. The Competitors were concerned that permitting ILECs to alter EAS areas would make it more difficult for CLECs to assess market conditions and would have the effect of reducing the flow of contribution funds.
Microcell Telecommunications Inc. (Microcell) was of the view that the Decision made it quite clear that existing ILEC exchange boundaries would be fixed for contribution purposes. Microcell concluded that each LEC could have two areas, one that defines its free local calling area and another that defines the area within which calls would not attract contribution charges. Microcell considered that the fundamental issue is that boundaries must not be subject to unilateral changes by the ILECs. Microcell's position was that, for both practical and public interest reasons, the Commission should fix the ILEC contribution boundaries establish them as the benchmark and make them effective 1 January 1998. Microcell also stated that for reasons of cost reduction and number conservation, rate centre consolidation and exchange consolidation must be considered by the Commission on a going forward basis.
CCTA was of the view that the Commission should rigorously enforce its traditional policies with regard to modification of EAS boundaries. It also expressed the view that, if the EAS criteria are modernized, consideration should be given to the effect that doing so on the competitive market.
Stentor was of the view that if the Commission had meant for EAS boundaries to be frozen it would have clearly stated so and a date would have been provided. Stentor stated that it would have been nonsensical for the Commission to suggest that a change in ILEC exchange boundary could not result in a change in the toll contribution boundary. Stentor noted that the Commission has approved many applications modifying EAS boundaries since Decision 97-8 and the Commission has not severed the links between EAS boundaries and toll contribution boundaries. Stentor also noted that there was no discussion of the link between EAS and contribution boundaries in the proceeding leading to Decision 97-8 and it submitted that it is unlikely that the Commission would have made such a significant ruling, which represented a marked departure from existing policy, if it was not expressly raised and debated by parties.
In Decision 97-8, the Commission did not freeze EAS/EFRC boundaries and, by extension, toll contribution boundaries. The Commission notes that it has approved a number of changes to EAS boundaries since rendering Decision 97-8. The Commission provided the calculation of contribution in competitive environment on the basis of ILECs' exchanges. The Commission notes that present EAS criteria do not take into account the competitive impact that the extension of EAS/EFRC may have on CLECs and on toll contribution revenues. However, the Competitors have the opportunity to submit their concerns in respect of a proposed change to a EAS/EFRC boundary at such time as an application to do so is before the Commission.
Yours sincerely,
Laura M. Talbot-Allan
Secretary General and
Chief Operating Officer
Date Modified: 1998-04-06
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