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ARCHIVED - Telecom Decision CRTC 2004-68

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Telecom Decision CRTC 2004-68

  Ottawa, 21 October 2004
 

Follow-up to Telecom Decision 2003-76: Rogers Wireless Inc. vs. TELUS Communications Inc. - Toll termination arrangements

  Reference: 8638-C12-200317918
  In this decision, a follow-up to Rogers Wireless Inc. vs. TELUS Communications Inc. - Toll termination arrangements, Telecom Decision CRTC 2003-76, 7 November 2003, the Commission directs TELUS Communications Inc. (TCI) to offer a new optional two-way trunk service to wireless service providers (WSPs). This new option would allow WSPs to combine toll termination traffic with local traffic on local trunks between the WSP's point of interconnection and TCI's local switch.
1. In Rogers Wireless Inc. vs. TELUS Communications Inc. - Toll Termination Arrangements,Telecom Decision CRTC 2003-76, 7 November 2003 (Decision 2003-76), the Commission directed TELUS Communications Inc. (TCI) to show cause why a tariff should not be filed for an optional two-way trunk service that would allow wireless service providers (WSPs) to combine toll terminating traffic with local traffic on local trunks between the WSP's point of interconnection (POI) and TCI's local switches (the two-way local/toll option). The Commission also directed TCI to file a proposed tariff for this service.
2. In accordance with the Commission's directives, TCI filed comments on 27 November 2003. Rogers Wireless Inc. (RWI) filed reply comments on 8 December 2003.
 

Background

3. In order to complete telephone calls originating from and terminating to wireless telephone subscribers, WSPs must connect to other carriers for both local and long distance calls. When cellular service was first introduced in Canada in the mid-1980s, WSPs interconnected with local exchange carriers using only line-side connections. More recently, WSPs have also obtained trunk connections. By contrast to line-side access, trunk-side access is used only to interconnect carriers and offers common channel signalling #7 (CCS7) capabilities. Trunks may be either one-way or two-way. One-way trunks permit one of the interconnecting carriers either to originate or to terminate calls on the other carrier's network, whereas two-way trunks allow interconnecting carriers to originate and terminate calls on each other's networks.
4. On 18 March 2003, RWI filed an application, submitting that TCI was insisting on using separate one-way trunks to terminate its toll traffic on RWI's network. RWI requested, among other things, that the Commission direct TCI to offer the two-way local/toll option.
5. In Decision 2003-76, the Commission made no final determination with respect to this request, but initiated a show-cause proceeding.
 

Position of Parties

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TCI's comments

6. TCI submitted that the emphasis of Final terms and conditions for provision of trunk-side access and common channel signalling #7 to wireless service providers, Telecom Public Notice CRTC 98-15, 9 July 1998, which led to Order CRTC 2000-395, 12 May 2000 (Order 2000-395), was to set the final terms and conditions for trunk-side wireless interconnection with CCS7 signalling. As such, TCI was of the view that it should not be directed to develop additional services based solely on a request by a WSP, arguing that service development must proceed consistently with the Commission's established framework, and not on an ad hoc and unpredictable basis.
7. TCI argued that Decision 2003-76 provided no rationale that would justify the introduction of an additional optional trunk service for WSPs in TCI territory.
8. TCI submitted that in Decision 2003-76, the Commission noted that the arrangements requested by RWI were being offered to WSPs by incumbent local exchange carriers (ILECs) in other parts of the country. TCI submitted that this observation could not justify the introduction of the two-way local/toll option.
9. TCI stated that the Commission had ruled on this issue in Order 2000-395. TCI argued that directing it to offer the same trunking arrangement as other ILECs would amount to a review and vary of Order 2000-395, and should not proceed without affording all interested parties an opportunity to submit their comments.
10. Further, TCI submitted that there was nothing in Order 2000-395 that would justify the imposition of uniformity for the sake of uniformity.
11. TCI noted that in Decision 2003-76, the Commission observed that a two-way trunk-side connection to the local switch which carries both local and toll traffic over the same facilities may be more cost effective than a one-way trunk-side connection. TCI submitted that the cost-effectiveness of trunking design depended on many parameters in addition to the trunk group orientation (i.e., one-way vs. two-way). TCI argued that in the case of a large trunk group, the efficiency gain of two-way trunk over one-way trunk was insignificant and that the particular trunk group efficiency gain should be measured against overall network efficiency. TCI submitted that in the case of RWI's proposal, the trunks to various end-offices may need to be augmented and argued that while gaining insignificant efficiency on the local trunks, both RWI and TCI would likely suffer in overall trunking efficiency in the transport network.
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RWI's reply comments

12. RWI strongly disagreed with TCI and submitted that in Decision 2003-76, the Commission clearly outlined the rationale for the introduction of the two-way local/toll option. RWI submitted that the Commission's rationale was that the provision of the two-way local/toll option would result in enhanced call management services for customers and would result in more efficient interconnection arrangements for WSPs. RWI argued that both of these outcomes would be in the public interest and were consistent with past determinations regarding interconnection arrangements for WSPs.
13. RWI submitted that in Order 2000-395, the Commission determined that WSPs must be provided with optional arrangements for termination of toll traffic. RWI further submitted that in Decision 2003-76, the Commission merely clarified that these optional arrangements should include termination of toll traffic via the two-way trunk-side trunks that were being used for routing WSPs' local traffic, since this would be a more efficient form of interconnection and would provide value to customers.
14. RWI disagreed with TCI's statement that WSPs were not entitled to the two-way local/toll option, since they interconnect as "customers" and not as "co-carriers", stating that the Commission had already determined that WSPs were entitled to efficient interconnection arrangements. RWI noted that in Decision 2003-76, the Commission agreed with RWI that the two-way local/toll option was a more efficient form of interconnection than the arrangements currently made available by TCI. RWI therefore stated that, contrary to the assertions put forward by TCI, WSPs were entitled to the two-way local/toll option and that they should not be required to become competitive local exchange carriers (CLECs) to qualify for it in TCI's operating territory. RWI argued that this was further evidenced by the fact that the service was made available to WSPs by ILECs in other parts of the country. RWI stated that the other ILECs did not view the two-way local/toll option as being reserved exclusively for CLECs.
15. RWI noted TCI's statement that both RWI and TCI would likely suffer in overall trunking efficiency in the transport network and further noted that TCI characterized any prospective efficiency gains as insignificant. RWI submitted that TCI's assertions were wholly unsubstantiated and should be disregarded by the Commission, noting that RWI had previously demonstrated that the current arrangement imposed by TCI was more costly than the two-way local/toll option.
 

Commission's analysis and determination

16. With respect to TCI's argument regarding the finality of the terms and conditions established in Order 2000-395, the Commission notes that in directing TCI to offer the new two-way local/toll option, the Commission would not be adjusting, on a retroactive basis, any mandatory terms and conditions of trunk-side interconnection. Rather, the Commission would be requiring TCI to offer an additional service on a prospective basis. The Commission also notes that whether TCI should offer that service has been the subject of a public proceeding in which TCI had an opportunity to address the issue.
17. The Commission notes that TCI submitted that there was nothing in Order 2000-395 that justified the imposition of uniformity for the sake of uniformity. Accordingly, TCI maintained that if the Commission directed TCI to offer the same trunking arrangements as other ILECs, it would amount to a review and vary of Order 2000-395.
18. TCI also considered that the Commission's observation in Decision 2003-76, that the two-way local/toll option was being offered to WSPs by other ILECs, did not justify the introduction of the new option.
19. The Commission notes that it did not use this observation as rationale to justify the introduction of the new option, but merely as an indication that other carriers find this option technically feasible.
20. As well, a requirement that TCI offer the two-way local/toll option would not be imposed for the sake of uniformity and would not establish a uniform national tariff for interconnection with WSPs. In fact, the rates charged by TCI for the two-way local/toll option would depend on the cost and attributes of TCI's networks as reflected in TCI's tariff.
21. In light of the above, the Commission considers that requiring TCI to provide the two-way local/toll option does not amount to a review and vary of Order 2000-395, as argued by TCI.
22. The Commission notes TCI's assertions that the efficiency gain of two-way trunk over one-way trunk would be insignificant and that both RWI and TCI would likely suffer in overall trunking efficiency in the transport network. The Commission further notes that RWI strongly disagreed with this view.
23. The Commission notes that in Decision 2003-76, it stated that the two-way local/toll option may be more cost-effective. The Commission's main rationale for the provision of the two-way local/toll option to WSPs was that WSPs should have the option of choosing the most cost-effective interconnection solutions and that "increasing the range of interconnection options available to WSPs seeking CCS7 functionality, and promoting opportunities for network efficiency, would be in the public interest and in keeping with Decision 84-10".
24. The Commission also noted in Decision 2003-76 that with two-way trunks, traffic congestion can be eliminated by re-directing traffic to an alternate trunk group until additional trunks can be added to the two-way trunk group. The Commission's view is that this enhances network efficiency.
25. It is the Commission's opinion that the two-way local/toll option allows for enhanced call management services for customers and may allow for more efficient interconnection arrangements, which is in the public interest.
26.

Accordingly, the Commission directs TCI to offer a new optional two-way trunk service that would allow WSPs to combine toll terminating traffic with local traffic on local trunks between the WSP's POI and TCI's local switches.

27. The Commission's determinations with respect to TCI's proposed tariff for the two-way local/toll option are set out in Toll termination arrangements, Telecom Order CRTC 2004-351, 21 October 2004.
  Secretary General
  This document is available in alternative format upon request and may also be examined at the following Internet site: http://www.crtc.gc.ca

Date Modified: 2004-10-21

Date modified: