ARCHIVED - Telecom - Commission Letter - 8621-C12-200404327 - Process arising from CISC Report OSRE001a - CLEC access to ILEC Operational Support Systems

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Letter

Our file: 8621-C12-200404327

by e-mail

Ottawa, 13 May 2004
To: OSS WG Participants list, PIAC


Re: Process arising from CISC Report OSRE001a - CLEC access to ILEC Operational Support Systems

Dear Sir/Madam

Commission staff is writing with respect to the report entitled CLEC Access to ILEC's Operational Support Systems filed with the Commission on 1 May 2003 by the CRTC Interconnection Steering Committee (CISC) Operational Support Systems (OSS) working group (OSS-WG).

1) Background

The Commission, in Service intervals for the provision of unbundled loops, Telecom Decision CRTC 2002-68, 1 November 2002 (Decision 2002-68), found that access by competitive local exchange carriers (CLECs) to the incumbent local exchange carriers' (ILECs) OSS functions might be an important factor in achieving the Commission's objective to provide CLECs with an equal opportunity to provide local service to customers in a timely manner. The Commission, therefore, directed CISC to study the issue and provide a report to the Commission describing the various OSS functions that could be of use to CLECs and the measures that could be implemented to permit CLECs to access those functions.

The OSS-WG filed with the Commission, on 1 May 2003, a non-consensus report (the Report) which recommended access to ILEC's OSS to obtain customer information, facilities information, installation status information and repair status information through a "gateway" access interface arrangement to be developed and implemented serially in four phases.

At a meeting on 27 and 28 February 2003, the OSS-WG had developed a document which set out the data elements included in, and the objectives of access to, these categories of information. Customer information included access to billing name and service address by the billing telephone number, working telephone number or account number, and services for a given customer service address including an indication of other customers or services located at the same service address (Customer Information). Facilities information included access to non-POTS services within a given cable binder group, COLT assignment data, plant records to determine if "dedicated plant" is available, and loop specification data prior to loop ordering (Facilities Information). Installation status information included access to loop provisioning status through defined milestones, and switch data by working telephone number (Installation Status Information). Repair status information included an electronic interface between LEC trouble ticketing systems including specific data elements and the capability to create and update trouble tickets (Repair Status Information).

The Report indicated that implementing this access could cost tens of millions of dollars and could take a number of years to complete. Commission staff considers that the cost estimates provided to implement the OSS access described in the report were high and the implementation timeframes were long. Commission staff further notes that no substantiation for the estimated costs was provided with the report.

In Commission staff's view, the highest priority is to resolve certain issues with respect to obtaining customer information in order to reduce the rate of rejection of local service requests (LSRs) being sent between local exchange carriers (LECs).

2) Proposals

a) Bell Canada and TCI

Staff notes that the Report indicated that access to the OSS of Bell Canada and Telus Communications Inc. (TCI) is the highest priority. In order to expedite the reduction of the LSR rejection rate, Bell Canada and TCI are to file detailed proposals on an approach to implementing CLEC access to their OSS to obtain the data required to complete an LSR. Specifically, Bell Canada and TCI are to propose an approach to CLEC access to their OSS to obtain electronically in real-time: the end user name, telephone number(s), end user service address, and customer service and equipment information including the Account Number, Number of Lines, Line Sharing, Circuits, ISDN BRI or PRI Service, Customer Centrex User Group, Features, Contract, Class of Service, Hunt Type, Hunt Sequence and Toll-free Termination as described in section 10 of the Canadian Local Ordering Guidelines and including other customers or services at the same service address.

The proposals are to detail an approach that can be implemented, as step 1, within 90 days of a Commission decision in this process.

In addition, Bell Canada and TCI are to propose approaches, building on the proposal for step 1, to implement CLEC access to their OSS to obtain electronically in real-time Facilities Information, Installation Status Information and Repair Status Information as steps 2, 3, and 4.

The proposals for step 1 are to enable CLECs to query the information using the working telephone number as the search criteria. The proposals for steps 2, 3 and 4 may use other search criteria if appropriate. All four proposals are to enable CLECs to query the information for residential, small business and enterprise customers.

The proposals for each step are to include:

a) A detailed description of the proposed OSS access system, including the technical details, for example the type of interface, functionality, limitations, restrictions, protocol specifications, access platform, system administration and logon, security, technical support, user documentation and training, details of testing and verification, performance specifications, deployment plan, and any other procedures relevant to implementing the proposal;

b) Justification for the OSS access system proposed, including benefits, security, ease of use and expandability;

c) Detailed cost estimates with justification for development, implementation and operation of the proposed system, including a breakdown of the costs associated with providing access to the information for a) residential and small business customers, and b) large business/enterprise customers. Commission staff notes that in contributions to the OSS-WG Bell Canada estimated its cost to provide access to its OSS for customer information at $7.6M +/- 25% and TCI estimated its cost to provide access to its OSS for customer information, facilities information, installation status information and repair status information at $8.5 Million +/- 100%;

d) A detailed development, verification and deployment plan, including a detailed schedule for each step that outlines the timeframe for each major activity, states which tasks must be performed sequentially, and provides full justification; and

e) A discussion of any other relevant information or issues.

Bell Canada and TCI are to file their proposals by 12 July 2004.

b) CLECs

Commission staff considers that in order to implement access to OSS, proposals are required from the CLECs, with respect to steps 1 to 4, on what they will need to do to implement access on the terms set out above. Call-Net Enterprises Inc. (Call-Net), Allstream Inc. (Allstream) and FCI Broadband are to file proposals by 11 August 2004 on how they will implement access on the terms set out above. The proposals are to include:

a) A detailed description of the proposed system it will need to put in place to implement access, including the technical details, for example the type of interface, functionality, limitations, restrictions, protocol specifications, access platform, system administration and logon, security, technical support, user documentation and training, details of testing and verification, performance specifications, deployment plan, and any other procedures relevant to implementing the proposal;

b) Justification for the system proposed, including benefits, security, ease of use and expandability;

c) Detailed cost estimates with justification for development, implementation and operation of the proposed system, including a breakdown of the costs associated with obtaining access to the information for a) residential and small business customers, and b) large business/enterprise customers;

d) A detailed development, verification and deployment plan, including a detailed schedule for each step that outlines the timeframe for each major activity, states which tasks must be performed sequentially, and provides full justification; and

e) A discussion of any other relevant information or issues.

3) Cost Recovery

As part of the process of examining access to OSS, the OSS-WG sought a Commission determination on how and from whom the costs of providing access to OSS should be recovered. In order to provide the Commission with a complete record on the issue of cost recovery, interested parties are to file, by 10 September 2004, their comments on the following cost recovery options:

a) Each ILEC is responsible for the development, implementation and operating costs, including those of the CLECs, associated with CLEC access to its OSS.

b) Each CLEC is responsible for the development, implementation and operating costs, including those of the ILEC, associated with its access to an ILEC's OSS.

c) Each ILEC and each CLEC is responsible for its own development, implementation and operating costs associated with CLEC access to ILEC OSS.

d) The development, implementation and operating costs, including those of ILECs and CLECs, associated with CLEC access to ILEC OSS are recovered from the ILEC Deferral account.

Interested parties are to include in their comments a detailed rationale for supporting their preferred option and for opposing the other options.

4) Procedure

Bell Canada, TCI, Call-Net, Allstream and FCI Broadband are made parties to this proceeding.

Other parties wishing to participate in this proceeding must notify the Commission of their intention to do so, by 10 June 2004. They should contact Procedure, by mail at CRTC, Ottawa, Ontario, K1A 0N2; by fax at (819) 994-0218; or by email at procedure@crtc.gc.ca. They are to indicate in the notice their email address where available. If parties do not have access to the Internet, they are to indicate in their notice whether they wish to receive disk versions of hard copy filings.

Commission staff notes that the process established in this letter may be modified if interrogatories are necessary to clarify the proposals. Therefore, parties are to also indicate in their notice whether they wish to receive copies of any interrogatories when posed during this proceeding.

Commission staff will issue, as soon as possible after the registration date, a complete list of parties and their mailing address (including their email address, if available), identifying those parties who wish to receive disk versions of hard copy filings and interrogatories.

As set out above, interested parties are to file submissions as follows:

a) Bell Canada and TCI are to file the proposals requested under 2 a) above by 12 July 2004;
b) Call-Net, Allstream and FCI Broadband are to file the proposals requested under 2 b) above by 11 August 2004;
c) Comments of any interested party on the proposals filed by Bell Canada, TCI, Call-Net, Allstream and FCI Broadband and on the issue of cost recovery set out in 3) above are to be filed by 10 September 2004; and
d) Reply comments from interested parties are to be filed by 20 September 2004.

Parties are reminded to serve a copy of all their filings on all other parties at the same time they file them with the Commission. Where a document is to be filed or served by a specific date, the document is to be actually received, and not merely sent, by that date.

Sincerely,


Scott Hutton
Director General - Competition, Costing and Tariffs (Acting)

Date modified: 2004-05-13

Date modified: