ARCHIVED - Order CRTC 2000-394

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Order CRTC 2000-394

Ottawa, 12 May 2000
Final rates for call routing – Local routing number absent service
Reference: National Services Tariff Notice 711 and TELUS Communications Inc. Tariff Notice 113
The Commission approves rates for call routing – Local routing number absent service.

1.

In Telecom Order CRTC 99-340, dated 12 April 1999, the former Stentor companies were directed to file proposed tariff pages for a final cost based rate for performing the local number portability (LNP) query processing and call routing functions per interconnecting Feature Group A circuit (i.e., line-side access).

2.

TELUS Communications Inc. (TCI) and Bell Canada, on behalf of itself, BC TEL, Island Telecom Inc., Maritime Tel & Tel Limited, MTS Communications Inc., NBTel Inc. and NewTel Communications Inc. (collectively, the companies), filed applications proposing revisions to call routing - Local routing number (LRN) absent service on 13 July 1999.

3.

The companies proposed to apply the call routing – LRN absent rates to all line-side circuits and trunk-side circuits using multi-frequency (MF) signalling employed by interconnecting carriers to route calls to the companies that are destined for telephone numbers within portable NXX codes. They indicated that with either of these types of interconnecting circuit it is not possible to detect whether an LNP query has been performed. As a result, incremental activities, which are the responsibility of the interconnecting carrier, must be performed by the companies in order to determine whether the destination telephone number has been ported to another local exchange carrier. The companies stated that in such cases they are also required to determine the LRN associated with the destination telephone number.

4.

The companies proposed that call routing – LRN absent service be provided to interconnecting carriers with trunk-side circuits using common channel signalling number 7 (CCS7) on an optional basis since these carriers may transmit the LRN in the CCS7 message.

5.

The proposed final rates range from $2.30 to $6.20 per month per DS-0 for trunk-side interconnecting circuits using either CCS7 or MF signalling and from $1.95 to $6.10 per month per DS-0 for line-side interconnecting circuits.

6.

Comments were received from Rogers Cantel Inc. on 12 August 1999, from Clearnet Communications Inc. on 7 and 13 August 1999 and from AT&T Canada Corp. and AT&T Canada Telecom Services Company (collectively, AT&T Canada) on 13 August 1999. The companies submitted their replies on 23 August 1999.

7.

AT&T Canada submitted that it can configure its line-side circuits and trunk-side circuits using MF signalling in such a manner that traffic, for which an LNP query is necessary, will be delivered separately from traffic which terminates directly on the incumbent local exchange carrier (ILEC). AT&T Canada submitted that the companies will know which trunks have been designated as not requiring any further LNP processing and therefore the call routing – LRN absent charge should apply on an optional basis.

8.

The companies noted that whether or not their switches perform the routing activities is not determined based on the specific interconnecting circuit on which a call is received, but rather on the basis of the NXX of the destination telephone number being portable. They submitted that the application of call routing – LRN absent rates to all line-side circuits and trunk-side circuits using MF signalling employed by interconnecting carriers to route calls destined for telephone numbers within portable NXX codes would permit them to recover the incremental costs incurred.

9.

The companies submitted that they would need to provision additional trunks to interconnect with carriers that chose AT&T Canada's approach and would therefore incur additional costs. They noted that AT&T Canada had not specified how the interconnecting carriers would compensate them for the incremental costs they would incur to accommodate the use of specific interconnecting trunks for the delivery of traffic not requiring further LNP processing.

10.

The Commission agrees with the companies that additional trunks would be needed to accommodate the approach suggested by AT&T Canada. The Commission is of the view that AT&T Canada's approach would impose additional costs on the companies.

11.

Therefore, the Commission is of the view that the call routing – LRN absent charge should apply to all line-side circuits and trunk-side circuits using MF signalling employed by interconnecting carriers, whenever the LRN information is not transferred.

12.

Clearnet submitted that the Commission's letter decision of 29 July 1998, which approved a rate of $7.50 per interconnecting DS-0 per month for performing the LNP query function, and Order 99-340 pertain to the specific circumstances associated with the interexchange carriers (IXC) trunk-side and line-side interconnection regime and not to the existing interim wireless service provider (WSP) interconnection regime established in Telecom Order CRTC 98-687, dated 9 July 1998.

13.

Clearnet submitted that the call routing – LRN absent tariff could be considered a case of double charging because the required call processing capability is inherently bundled within the existing network access tariff elements associated with the interim wireless interconnection regime regardless of whether or not the exchange of the terminating subscriber is LNP ready.

14.

Clearnet submitted that the Commission should direct the ILECs to only apply the charges in the context of the final wireless trunk-side interconnection regime. It submitted further that the charges should apply only when the network access components associated with the wireless interconnection regime are sufficiently unbundled.

15.

Cantel made arguments similar to those presented by Clearnet noting that, until now, the charge for call routing – LRN absent has only been applied to WSP trunk-side interconnecting circuits. It submitted that the companies are not justified in applying the charge to WSP line-side circuits.

16.

The companies replied that the Commission's letter decision dated 25 October 1996 regarding outstanding issues arising from Implementation of regulatory framework - Local number portability and related issues, Telecom Public Notice CRTC 95-48 dated 10 November 1995clearly identified that WSPs have the responsibility, as do IXCs and competitive local exchange carriers, to ensure the correct routing of calls in an LNP environment.

17.

The companies noted that nothing in the Commission's determinations would indicate that these obligations would vary depending on the type of interconnecting circuits used to route calls. They expressed concern that the parties were attempting to avoid certain costs that they should be incurring to meet their responsibilities by having the companies bear these costs instead.

18.

The companies noted that the Commission previously approved on an interim basis a rate of $7.50 for the performance of the LNP query processing function on behalf of carriers that were not doing it for themselves.

19.

The companies submitted that the interim tariffed rates and charges currently applicable for WSP line-side access or trunk-side access arrangements, which were developed prior to the implementation of LNP in Canada, do not capture the costs intended to be recovered through the application of the call routing – LRN absent charges.

20.

In a letter decision dated 19 July 1996, and again in Order 99-340, the Commission stated that the N-1 carrier, that operates the last network before the network where the call would terminate, is to perform the query processing prior to delivering a call to a local service provider in a portable serving area, regardless of the type of interconnection used. Service providers were permitted to enter into business arrangements to contract out the LNP query processing function to another service provider for technical, economic or business reasons.

21.

In its letter decision dated 25 October 1996, the Commission found that where wireline carriers are providing LNP and wireless carriers are not, wireless carriers must provide the correct routing of calls from their networks to the serving switch either directly or by securing the routing service from another service provider that has the capability.

22.

Since WSPs are responsible for the correct routing of calls from their networks and the existing tariffs for access services provided to WSPs do not contain provisions for the recovery of costs associated with the identification of a carrier in an environment where LNP is available, the Commission considers that the call routing - LRN absent charge is a reasonable means by which the terminating company can recover the costs for performing LNP query processing and call routing functions for WSPs.

23.

In view of the above, the Commission approves the applications filed under National Services Tariff Notice 711 and TCI Tariff Notice 113.
Secretary General
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