ARCHIVED - Telecom - Commission Letter - 8643-C25-01/99 - Follow-up to the Networkof Networks Workshop

Letter

8643-C25-01/99

Ottawa, 7 December 2000

To: all parties on the distribution list (Network of Network Workshop list)

Re: Follow-up to the Network of Networks Workshop

Dear Sir or Madam:

The attached report summarizes the status of the Commission's and Commission staff's actions on the various issues raised at the Network of Networks Workshop (the Workshop) held on 8-9 June 2000.

The Workshop provided an opportunity for Commission staff to solicit the views of telecommunications service providers regarding improvements to the interconnection and interoperation regime for items such as trunking, signaling, points of interconnection, co-location and the architecture of the Canadian network and any steps that should be taken in recognition of the current circumstances and the future evolution of the network.

Yours sincerely,

Shirley Soehn
Executive Director
Telecommunications

Attachment

c.c. Victor Lawetz, CRTC, (819) 997-4578

FOLLOW-UP TO THE NETWORK OF NETWORKS WORKSHOP

I BACKGROUND

The Network of Networks Workshop (the Workshop) was held on 8 and 9 June 2000. The purpose of the Workshop was to assist Commission staff to develop recommendations to the Commission regarding the most appropriate means to address various issues with respect to the interconnection and interoperation of telecommunications networks in Canada.

Issues related to the interconnection of local exchange (LECs), incumbent local exchange (ILECs) and inter-exchange carriers (IXCs) were identified in two Part VII applications filed by Call-Net Enterprises Inc. (Call-Net) on 2 June 1999. These applications were:

1. A request that the Commission implement what Call-Net described as a new more efficient and pro-competitive frame work for interconnection through the rationalization of current interconnection arrangements (i.e. by creating a network of networks).
2. A review and vary of Telecom Order CRTC 99-340 to permit IXCs to continue to terminate interexchange traffic using the ILECs' line side connection services, at the tariffed rates paid by retail customers for the same service.

The issues related to the connection charges were dealt with in a separate process. As a result of that process, in its letter of 9 March 2000, the Commission approved the lowering of the direct connection charge from $.007 to $.003 per minute. The part of the application dealing with the "Network of Networks" was placed in abeyance.

Prior to initiating any further process on the issues raised by Call-Net's applications, on 8 May 2000, Commission staff invited industry participants to a two-day workshop to express their views on how the architecture, interconnection and interoperation of networks in Canada can be improved to respond to the new competitive environment.

Parties were invited to submit papers prior to the meeting. The following parties did so: AT&T Canada Corp. on behalf of itself and AT&T Canada Telecom Services Company (AT&T Canada); the Coalition for Better Co-location (the Coalition); Call-Net on behalf of itself and C1.com Inc.; Combined Telecom Inc.; GT Group Telecom Services Corporation; Optel Communications Corporation, now AXXENT Corp. and Riptide Networks Inc. (Riptide); Clearnet Communications Inc. (Clearnet); Covad Canada Communications Inc. (Covad); Eastlink Telephone (Eastlink); Microcell Telecommunications Inc. (Microcell); Ontario 911 Advisory Board; Riptide; Rogers Wireless Inc.(Rogers); and, TELUS Communications (BC) Inc. and TELUS Communications Inc. (TELUS).

In the course of the Workshop, the participants were grouped into the following general areas:

• Co-location
• Interconnection
• Emerging technologies

Each group then prepared a list of issues.

Following the workshop, written submissions on the various issues were received from the following: AT&T Canada; AXXENT Corp. (AXXENT); Bell Canada on behalf of itself and Aliant Telecom Inc., MTS Communications Inc. and Saskatchewan Telecommunications (Bell et al.); Canadian Cable Television Association (CCTA); Call-Net; Clearnet; Covad; Eastlink; Futureway Communications Inc. (Futureway); Mobilexchange (letter to Mr. Manley); Microcell; O.N. Tel; Rogers; RSL COM Canada Inc. (RSL COM); TELUS; Thunder Bay Telephone; and Videotron Communications Inc. on behalf of Videotron (1998) ltee and Videotron Telecom (1998) ltee (VTI).

II SUMMARY OF PROPOSALS

The proposals on how to handle the issues raised at the Workshop varied considerably in scope. TELUS proposed a comprehensive proceeding, including an oral phase, to deal with all the interconnection/co-location issues. This view was supported by RSL COM. On the other hand, Clearnet and Microcell proposed that the Commission use its established written processes or the appropriate CRTC Interconnection Steering Committee (CISC) groups to deal with each issue as it is raised. In between were proposals to handle some issues via formal proceedings and others via the CISC process or other processes. Most parties did not favour a comprehensive process with an oral proceeding phase as proposed by TELUS.

Eastlink proposed that the Commission consider the use of a modified Inquiry Officer model. All the parties, except Bell et al., placed a high priority on many of the issues related to interconnection and co-location. Bell et al. noted that a number of the issues identified by the Workshop constitute requests to the Commission to selectively alter existing principles established in past Commission decisions or to establish new principles. Bell et al. stated that it was not convinced that the re-examination of selected Commission determinations in relation to a particular interconnection regime is neither necessary nor appropriate at this time. Bell et al. were of the view that only the emerging technologies issues should be the subject of a public notice and that the other issues (co-location and interconnection) should be dealt with only after the emerging technologies issues had been addressed.

Most parties agreed that the emerging technologies issues could be dealt with on a lower priority basis.

The Commission is of the view that a comprehensive proceeding, as proposed by TELUS, would not be the most effective way to deal with the issues raised. The Commission established the CISC process to provide industry participants with a forum to resolve issues related to the implementation of competition. Rather than initiate a new proceeding, the Commission is of the view that the CISC process should continue to be used to address competitive issues. Many of the issues raised are of an operational nature that are best addressed through established or new CISC working groups. At the Workshop, the ILECs in fact expressed willingness to discuss some of these operational issues in these types of working groups.

Other issues, such as those that deal with wireless competitors, are more focused and any process established to address these issues would likely be of limited interest to many parties.

Since the Workshop, parties have filed requests to address some of the issues raised. On 17 July 2000 the Coalition, consisting of AT&T Canada, C1.com Inc., Call-Net, Covad, Gateway Telephone Limited, GT Group Telecom Services Corp., Northpoint Canada Inc., AXXENT, PSINet Limited, Riptide, UUNET Canada Inc., and Wispra Networks Inc., requested that, among other things, the CISC co-location working group (CLG) address several of the operational issues identified at the Workshop. In addition, on 17 July 2000, the Coalition also filed two Part VII applications requesting relief for many of the other co-location issues raised at the Workshop.

The sunset rules in the Local Competition decision (Decision 97-8) and in the Transiting Order (Order 98-486) were identified as issues at the Workshop. The Commission issued Public Notice 2000-96, dated 11 July 2000, seeking comments on, among other things, its preliminary view that the sunset rule should be extended.

III STATUS OF THE ISSUES

A. Co-location

As noted above, the Coalition has requested that the CLG be convened to address several of the operational issues. In addition, the Coalition has also filed two Part VII applications (one asking for expedited relief and the other for general relief) requesting resolution on many of the remaining issues. The Coalition offered to withdraw the applications if the ILECs accept the relief requested and proceeded to the CLG to discuss implementation of the relief requested.

Comments have been received on both of the Coalition's Part VII applications. Both TELUS and Bell proposed that the issues raised by the Part VII applications should be dealt with by the CLG. Subsequently, members of the Coalition met with Bell and TELUS to determine whether it would be possible to refer any of the issues raised in the Coalition's two Part VII applications to the CLG. Based on the results of the discussion, the Coalition asked to withdraw certain requests and suspend others.

The Coalition will continue with its request for expedited relief for the following issues:

As well, the Coalition will continue with its request for relief on following issues addressed in the Part VII application requesting general relief:

The CLG will consider the issues that the Coalition initially requested be referred to the CLG and the issues for which the request for relief was withdrawn or suspended. These are:

There were a number of other co-location issues raised at the Workshop that were not covered by the Coalition's applications. Microcell submitted that the Commission should consider mandating shared access to rooftops and other sites for the purpose of co-locating wireless equipment. Rogers on the other hand argued that no action should be taken on this issue, noting that this issue is being addressed in the CISC Building Access and Inside Wire Sub-Working Group. Microcell included the issue of access to exclusive rooftops with the other co-location policy issues identified by the co-location Workshop Group that should be addressed immediately.

Since the CISC Building Access and Inside Wire Sub-Working Group is addressing this issue, no process will be initiated by the Commission at this time.

B. General Interconnection issues

The Commission has established the Network of Networks Ad Hoc Working group to examine general interconnection issues. It will consider the following interconnection issues identified at the Workshop.

C. More specialized interconnection related issues

Both the Interconnection and the Emerging Technologies Workshop groups raised issues regarding access to databases currently administered by the ILECs. Competitors have suggested that it may be appropriate to apply the Local Number Portability model of third party administration of databases (including 411, 800, Directory Assistance and Billed Number Screening) to these databases. The Commission does not intend to establish a process to address these questions at this time. However these issues are included in the Commission's longer term action plan.

Rogers recommended that a CISC working group be established to examine how Calling Party Pays can be implemented. Rogers argued that the ILECs' proposed implementation of the Call Originator Billing system (as offered in the ILEC market trials) has led to a service that is not viable. Rogers proposed that the whole issue be re-examined in the context of an interconnection proceeding which would consider different implementation approaches.

The Commission considered issues related to Calling Party Pays in the context of the market trials offered by the various companies in General Principles in Setting Rates, Terms and Conditions of Call Originator Billing Service, Telecom Public Notice CRTC 1997-23, 13 June 1997. In Conditions of Call Originator Billing Service for Wireless Service Providers, Decision CRTC 2000-74, 16 March 2000 (Decision 2000-74), the Commission found that Call Originator Billing service is not in the nature of an essential service and that the wireline companies would be permitted to introduce it based on a business case assessment. Based on the submissions, the Commission is not persuaded that it would be appropriate to initiate a process to re-consider its finding in Decision 2000-74.

The question of how multiple service providers can serve large Centrex customers is currently under consideration by a subgroup of the CISC Network Sub-Working Group. Currently large Centrex systems cannot be split up to be provisioned by different LECs. Trials to test Centrex interworking have been conducted but have not been totally successful. While this was raised as an issue to be considered for further process, in the Commission's view, this should remain a CISC issue for the time being.

Parties raised the issue of access to remotes that are placed in buildings. These remote units are on property that belongs to the building owner, not to the ILEC. The Commission is of the view that the appropriate forum for the consideration of this issue is the CISC Building Access and Inside Wire Sub-Working Group. In addition, Public Notice 2000-124 has recently been issued to examine access to multi-dwelling units, in-building wire and riser space.

D Emerging Technologies

There appears to be general agreement that emerging technologies issues are not as pressing and can be handled on a lower priority basis. The main concern at this time is the interoperation of Internet Protocol (IP) based networks and predominately circuit switched legacy networks. Since there is a decreasing distinction between voice and data networks, several parties suggested that minimum obligations and quality of service be considered for networks that are used to carry data as well as voice traffic. There is a need to examine the impact of these next generation networks on the definition of basic service, universal access and affordability of such services as well as the interconnection and interoperation of these networks. Few parties argued that the emerging technologies issue required immediate attention; the Commission is of the view that it should be addressed as soon as possible.

While a number of implementation issues related to interconnection of IP networks to existing networks were identified by the Interconnection Workshop group, in the Commission's view, these should be addressed once the more fundamental interconnection methodology and general framework are established. In addition, the standards for IP based networks are under active consideration by standard bodies such as the International Telecommunications Union (ITU) and Internet Engineering Task Force (IETF).

The Commission intends to issue a Public Notice on emerging technology issues once the current interconnection issues have been addressed.