ARCHIVED - Telecom - Commission Letter - CISC - PN 98-26 - Commission DecisionRegarding CRTC Interconnection Steering Committee Dispute on Issues related toDaily Local Service Request Cutoff Time on "Day 0" of the ServiceIntervals (BODI003)

Letter

Ottawa, 10 April 2000

To: PN 2000-17 Distribution List

Subject: Commission Decision Regarding CRTC Interconnection Steering Committee Dispute on Issues related to Daily Local Service Request Cutoff Time on "Day 0" of the Service Intervals (BODI003)

1. In August 1998, a consensus was achieved in the Billing and Ordering Working Group of CISC that in order to be able to issue, receive and process service requests in a timely manner, a daily 2:00 p.m. cutoff time was appropriate for the submission of local service request (LSR) by the ordering local exchange carrier (LEC) to the provisioning LEC ("the Consensus"). That consensus was approved by the Commission.
   
2. Four months later, parties to the Billing and Ordering Working Group (now, Business Process Working Group) filed a dispute with respect to the Consensus. Essentially, MetroNet Communications Group Inc. (MetroNet) on behalf of itself, Call-Net Enterprises Inc. and Vidéotron Télécom ltée (the Competitors) request that the LSR cutoff time be changed, from 2:00 p.m. to 4:00 p.m., so that they are afforded more hours in a business day to transmit their LSRs. This will enable them to manage their workflow and provide reasonable service intervals to their customers.
3. Comments and replies were received from the Competitors and from Stentor Canadian Network Management (Stentor) on behalf of BC TEL, Bell Canada, Island Telecom Inc., Maritime Tel & Tel Limited, MTS Communications Inc., NBTel Inc., NewTel Communications Inc. and TELUS Communications Inc. (the Incumbents).
   
4. The Competitors stated that the Consensus was based on the following information provided by the Incumbents:
   

• The 2:00 p.m. LSR cutoff time would be consistent with the existing Primary Interexchange Carrier/Customer Account Record Exchange (PIC/CARE) cutoff time (PIC/CARE is the process by which a customer selects a long distance carrier); and,
  

• the 2:00 p.m. cutoff time provides an opportunity to resolve technical issues associated with an order prior to the end of the day, such that problem orders sent before 2:00 p.m. may still be considered "received" on that day, provided that they are corrected and resubmitted before 4:00 p.m.
  

5. In the absence of any experience in the local exchange market at the time of the negotiations, the Competitors submit that they accepted the Incumbents’ rationale for the 2:00 p.m. cutoff time.
   
6. According to the Competitors, after the Consensus was reached they discovered that the PIC/CARE cutoff time was not 2:00 p.m., as the Incumbents had indicated during negotiations, but rather 4:00 p.m. The Competitors note that the 2:00 p.m. PIC/CARE cutoff time applies only to those Interexchange carriers (IXCs) that use old technology (magnetic tape) to transmit their PIC/CARE transaction orders. The Competitors add that PIC/CARE transactions have very little in common with LSR transactions, in terms of frequency of transmission, number of transactions per transmission and data interchange medium and that clearly, the Incumbents' rationale that the LSR cutoff time should be aligned with a 2:00 p.m. PIC/CARE cutoff time, does not stand.
   
7. In reply, the Incumbents deny that they based their rationale for the Consensus on the PIC/CARE cutoff time. According to the Incumbents, it was based on their standard cutoff time for facilities-based products and that, at the time of the negotiations, most CLECs and potential CLECs were already familiar with their practices regarding order cutoff time, through other types of orders placed with the CSGs (interexchange, wireless and resale). They submit that changing the LSR cutoff time would (1) impact order processing for other CSG operations; (2) require additional staff or overtime costs; and (3) would impede their efforts to align cutoff times for other carrier orders. Consequently, it would deprive them from gaining operational efficiency and meeting service intervals commitments.
   
8. The Competitors note that many carrier order cutoff times, including most PIC/CARE and Centrex resale cutoff times, are set at 4:00 p.m. They submit that if the Incumbents wish to align cutoff times, it would be preferable to align them at 4:00 p.m., which is closer to the end of the business day.
   
9. The Incumbents provided the following arguments against the requested change to the LSR cutoff time: (1) it would be contrary to the need to align all CSG cutoff times; (2) would require the deployment of additional staff or additional overtime costs because they have adapted their legacy systems, with manual interventions, to accommodate the new services to be provided to CLECs; and (3) the actual demand from CLECs does not allow the Incumbents to test their systems.
   
10. The Commission notes that the Competitors agreed to a 2:00 p.m. LSR cutoff time on "day 0" based on their understanding that the PIC/CARE Cutoff time was at 2:00 p.m. In fact, it is at 4:00 p.m. except in the rare cases where magnetic tape is used as the data exchange medium. The Commission is of the view that the Incumbents should have clarified that the 2:00 p.m. PIC/CARE cutoff time applied only in rare cases.
    
11. Furthermore, the Competitors are not guaranteed a chance to resend problem orders between 2:00 p.m. and 4:00 p.m., as the parties did not agree on a 2:00 p.m. daily notice of rejection. According to the guidelines used by LECs, the provisioning LEC is afforded up to two days to send such notice.
    
12. With respect to the Incumbents' need to align all CSG cutoff times, the Commission notes the Incumbents' comment that many (unspecified) carrier orders have a 2:00 p.m. cutoff time. The record indicates that at least two types of carrier orders, namely PIC/CARE and Centrex resale, have a cutoff time of 4:00 p.m. The Commission believes that the Competitors should be afforded a cutoff time that (1) is not earlier than the cutoff time for other types of carrier orders; and (2) allows the Competitors to effectively compete against the Incumbents. Although there could be merit to the Incumbents' desire to gain efficiencies by aligning cutoff times, it should not be done to the detriment of the Competitors. The Competitors had four months experience with the 2:00 p.m. LSR cutoff time and have found it to be inappropriate. The Commission notes that the Incumbents did not provide any support for their claim that they need to align cutoff times at 2:00 p.m. (and not at 3:00 p.m. or at 4:00 p.m.).
    
13. With respect to the Incumbents' comment that if the LSR cutoff time is moved to 4:00 p.m., they would have to deploy additional staff or incur additional overtime costs, the Commission notes that they did not provide any indication as to the level of additional costs they would have to incur in order to implement a later cutoff time.
    
14. With respect to the Incumbents' argument that the light demand from CLECs is insufficient for the Incumbents to test their internal systems, the Commission notes that at the time of the negotiations, only one CLEC was active in Canada while at the moment, a dozen of them are participating in the market. The Commission also notes that even some of the Incumbents themselves are in the process of becoming CLECs. The Commission considers it reasonable to expect that the demand is higher now than it was last year. The Commission is of the view that a trial of the 4:00 p.m. cutoff time is not necessary.
    
15. The Incumbents state that the current cycle of LSR submission, validation, rejection, resubmission and reprocessing is costly in terms of human and capital resources and causes substantial delays. They submit that it would be more beneficial and appropriate to improve the quality of LSRs and LSCs exchanged between LECs than moving the cutoff time by two hours. The Competitors concur that all parties should do their best to improve the quality of the LSRs and LSCs exchanged, but that the issue of quality improvement should not be dependent on any particular cutoff time.
    
16. The Commission notes that the agreed upon local ordering guidelines provide that when an LSR is found to contain data entry errors (more than three in a paper environment or just one in a mechanized environment), the provisioning LEC sends, within the agreed-upon 2-day service interval, a notification of rejection of the LSR to the ordering LEC, using the LSC. The Commission notes that the provisioning process (second segment) only starts when an LSR is accepted. Therefore, in the Commission's view, although the poor quality of LSRs postpone the provisioning activities to be performed by the Incumbents (and, therefore, the date at which the CLEC customer will receive service from that CLEC) the discussion around the poor quality of LSR is irrelevant to the issue of LSR cutoff time.
17. Considering all of the above, the Commission is of the view that the Competitors must not be put at any undue disadvantage by having an earlier cutoff time than other carriers. The Commission therefore approves the request made by the Competitors and directs that the LSR cutoff time be changed to 4:00 p.m.
18. The Incumbents note that the 2:00 p.m. LSR cutoff time was instituted as a multi-lateral arrangement and state that the consensus reflects the needs of all participants to be able to issue, receive, and process orders in a timely manner. The Competitors respond that they are prepared to honour a 4:00 p.m. cutoff time for both the transmission and the receipt of orders.
    
19. The Commission notes that, in order not to impact the agreed upon service interval for the return of the Local Service Confirmation (LSC), the LSC cutoff time needs to be moved to 4:00 p.m. as well. The Commission directs that the LSC cutoff time be changed to 4:00 p.m.
    

Yours sincerely,

Ursula Menke,
Secretary General

c.c. Renée Gauthier, CRTC, (819) 953-8608