ARCHIVED - Telecom - Commission Letter - 8638-C12-47/00 - Follow-up to Telecom Order CRTC 2000-397 - Altering terms of service for competitors that are customers
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LetterOttawa, 4 June 2003 BY TELECOPIER To: Distribution List File: 8638-C12-47/00 Follow-up to Telecom Order CRTC 2000-397 - Altering terms of service for competitors that are customersSummary This letter requests that Aliant Telecom Inc., Bell Canada, MTS Communications Inc., Saskatchewan Telecommunications Inc., Télébec société en commandite, TELUS Communications Inc. and TELUS Communications (Québec) Inc.:
. report which competitors were affected by a service interruption, and report when service was restored to such competitors; Other incumbent local exchange carriers are not required to file reports pursuant to Telecom Order CRTC 2000-397 at this time. Staff letter dated 27 November 2002 In the letter dated 27 November 2002, sent to Aliant Telecom Inc. (Aliant), Bell Canada, MTS Communications Inc. (MTS), Saskatchewan Telecommunications Inc. (SaskTel), TELUS Communications Inc. (TELUS), TELUS Communications (Québec) Inc. (TELUS Québec) and Société en commandite Télébec (Télébec) (collectively referred to as the ILECS), other small incumbent local exchange carriers (the small ILECS), interchange carriers and wireless carriers, Commission staff requested that: a) Bell Canada, Aliant, MTS and TELUS:
1. describe and justify their current definitions and classification of service interruptions; and b) Bell Canada, Aliant and MTS identify the number of service interruptions due to "cut cables/specials"; and if it was included in the other types of service interruptions, correct the reported category and numbers accordingly; c) SaskTel, O.N.Telcom, Cochrane and City Tel to show cause why Order 2000-397 should not apply to them; d) the ILECS and small ILECS to provide the information requested in a) to c) by 9 December 2002; e) the small ILECS to discuss the reasons why they have not filed the service interruption reports to date and to file, if they are not serving and competitor, a statement to that effect with the Commission; f) other parties were requested to submit their comments on the filings by the ILECS or small ILECS on or before 20 December 2002; and g) all ILECS, and any small ILEC that provides service to at least one competitor, file for the first quarter of 2003 all the information requested by paragraph 34 of Order 2000-397 for all ten types of service interruptions identified by TELUS, as outlined on page 2, above. Some ILECS received an extension to 23 December 2002 to file some of their responses. Amtelcom Inc. (Amtelcom), Association de compagnies telephoniques du Québec (ACTQ), Brooke Telecom Co-operative Ltd (Brooke), City Tel, Gosfield North Communications Co-operative Limited, Hay Communications Co-operative Limited (Hay), Huron Telecommunications Co-operative Ltd (Huron Tel), KMTS, Mornington Communications Co-operative Limited (Mornington), Nexicom Telephones Inc., Northern Telephone Limited Partnership (Northern), North Frontenac Telephone Corporation Ltd. (North Frontenac), North Renfrew Telephone Company Limited, O.N.Telcom, People's Telephone Company of Forest Inc. (People's), Quadro Communications Co-operative Inc. (Quadro), Tuckersmith Communications Co-operative Ltd., Westport Telephone Company Limited, Thunder Bay Telephone (TBT), Wightman Telecom Ltd. (Wightman), Aliant, Bell Canada, MTS, SaskTel, and TELUS responded to the staff letter. No party filed comments on the responses provided to the Commission. A. Obligation of the small ILECS to file Small ILECS in Québec ACTQ ACTQ, on behalf of its members, notified Commission staff via e-mail that its members were only facing competition in wireless and long distance services at present, and that the competitors were interconnected at Bell Canada's switch. Small ILECS in Ontario Gosfield submitted that it intends to file the service interruption reports only when it provides service to at least one competitor. Amtelcom, Brooke, Hay, Huron Tel, Mornington, North Frontenac, Quadro, Roxborough, Westport and Wightman stated that they were providing at present service only to wireless and long-distance competitors. They further submitted that it would be onerous and burdensome to file the service interruption reports quarterly. They requested that if required to file the reports, they be permitted to file them once a year only. Northern/Télébec
Northern/Télébec submitted that, according to their understanding, Thunder Bay TBT indicated that it intends to commence filing the service interruption reports commencing with the first quarter of 2003. Conclusion Staff notes that Order 2000-397 applies to any local exchange carrier (LEC) that provides service to competitors, regardless of whether the LEC faces competition in the local market. However, staff is of the view that the small ILECS may incur significant costs in compiling accurate service interruption reports. At the same time, because of their small size, the small ILECS are unlikely to cause significant competitive harm. Accordingly, staff considers that, at this time, the small ILECS are not required to file the service interruption reports. B. Responses to the show cause request SaskTel SaskTel submitted that it should be subject to the same reporting requirement as the other ILECS. SaskTel stated that since the reporting requirements may be changed as a result of this proceeding, it will commence to report to the Commission after its conclusion. City Tel City Tel submitted that it would not find it onerous to submit the service interruption reports pursuant to Order 2000-397. Conclusions SaskTel is requested to commence submitting the service interruption reports starting with the third quarter of 2003, in the details as discussed in Section C, below. City Tel, Cochrane and O.N.Telcom are small ILECS, and are therefore not required to file the service interruption reports at this time. C. Responses by the ILECS Bell Canada Bell Canada submitted that the Commission has yet to make a final determination on the nature of service interruptions and the associated details that are to be included in future reports. Bell Canada stated that within the industry "outages (interruptions) are typically understood to be a significant degradation of a customer facility to establish and maintain a channel of communication as a result of a failure or degradation in the performance of a carrier's network." Bell Canada indicated that the company has interpreted nine different types of interruptions, as reported in its quarterly service interruption reports; it was of the view that this reporting format provided an equitable arrangement between the regulatory requirement to safeguard service to competitors and allowing the company to efficiently comply with the reporting requirements. Bell Canada further stated that for service interruptions at the 800 SCP database, BNS SCP database, LNP SCP database, End office and Toll access tandem switches, it reported "total failure" where no functionality is possible, and that for CCS7 Network interconnection, 9-1-1 Emergency services and Co-location, it reports "total isolation", where no re-routing was implemented or possible. As an illustration, Bell Canada noted that "isolation" may occur if a toll access tandem is not equipped with routing diversity or contingency. Bell Canada stated that for interconnecting trunk facilities, it reports failures of 50% or more of the capacity. Bell Canada stated that it previously reported cable-cuts under the category 'interconnecting trunk facilities'. Bell Canada also indicated that competitors' and the company's traffic was frequently routed through the same transmission or trunking facilities. Aliant Aliant indicated that it reported only interruptions in service to competitors interconnected at the company's access tandem switches, and that it did not report service interruptions at remote switching centres that impacted all customers served by that switch. Aliant stated that it did not report interruptions for 800 SCP database, Billed Number Screening (BNS) SCP database, and Local Number Portability (LNP) SCP database since these databases are maintained nationally by Bell Canada, and, consequently, any interruptions would be reported by Bell Canada. MTS MTS noted that it did not report interruptions for CCS7 interconnection, 800 SCP database, BNS SCP database and LNP SCP database as these services are provided from a national platform in Bell Canada's territory and, as a result, interruptions were included in the reports by Bell Canada. MTS indicated that it reported any network event where service was either totally unavailable or significantly degraded, or where associated troubles were reported by the customer. However, MTS stated that it did not report planned interruptions of which competitors were advised in advance. TELUS TELUS stated that it used the same classification of service interruptions as Bell Canada, but also reported on service interruptions on account of cut cables due to construction, motor vehicle accidents or vandalism. Conclusions Reportable interruptions Staff notes that pursuant to Order 2000-397, Aliant, Bell Canada, MTS, Télébec, TELUS and TELUS Québec are required to report interruptions that affect service to competitors, and whether these interruptions also affect service to the reporting ILEC's other customers. SaskTel agreed that it should be subject to Order 2000-397, and therefore the conclusions in this section apply to it as well. To comply with Order 2000-397, Aliant, Bell Canada, MTS, SaskTel, Télébec, TELUS and TELUS Québec are requested to: . identify the competitors affected by a service interruption, and when service was restored to the affected competitor or competitors; and . report whether an interruption in service to competitor(s) also affected service to the ILECS' other customers, and when service was restored to such customers. Staff notes that competitors normally use the CCS7, Feature Group D (CCS7-FGD) protocol to connect to the ILECS at an access tandem switch or trunk side at an end office. Therefore, the ILECS are requested to report interruptions in service to competitors for all connections using the CCS7-FGD protocol. The ILECS are not required to report interruptions in service on line-side connections by competitors to an end office Classification of interruptions The ILECS are requested to use the current classification of service interruptions, reporting separately outages for:
. CCS7 network interconnection The ILECS are not required to report outages due to cable-cuts, since ILEC and competitor traffic often is routed through the same facilities, and cable cuts could be caused by independent contractors, motor vehicle accidents or vandalism. Staff notes that all ILECS are involved in operating the CCS7 network, and accordingly, all ILECS are requested to report failures to the CCS7 network in their respective service territories. An ILEC does not need to report interruptions in access to, or other failures of, databases maintained and managed by another ILEC, provided that such interruptions or failures are reported by the ILEC maintaining and managing the database(s). Definitions of interruptions and frequency of the reports The ILECS are requested to use Bell Canada's definitions of service interruptions. The ILECS are requested to file the service interruption reports on a quarterly basis.
Paul M. Godin |
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