ARCHIVED - Telecom Order CRTC 2004-351

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Telecom Order CRTC 2004-351

  Ottawa, 21 October 2004

TELUS Communications Inc.

  Reference: Former TCI Tariff Notices 522 and 522A and
TCBC Tariff Notices 4204 and 4204A

Toll termination arrangements


The Commission received applications by TELUS Communications Inc. (TCI), dated 10 December 2003 and amended 14 May 2004, filed pursuant to Commission directives in Rogers Wireless Inc. vs. TELUS Communications Inc. - Toll Termination Arrangements, Telecom Decision CRTC 2003-76, 7 November 2003 (Decision 2003-76). TCI proposed revisions to former TCI General Tariff item 555, Wireless Service Providers (WSP) - Network Access Service, and TELUS Communications (B.C.) Inc. (TCBC) General Tariff item 197-A, Wireless Access Service. TCI stated that the proposed tariff revisions would allow 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).


For changes to a WSP's toll traffic termination routing option, TCI proposed to introduce a Toll Termination Routing Conversion service charge of $583.00, which it later amended to $543.00, per NXX or partial NXX.


TCI stated that it would require an implementation time of one week for every two switches requested, in addition to the regular service interval required for the trunk augmentation activities.


TCI filed an economic study in support of the proposed new option and indicated that the proposed rate passed the imputation test.


TCI requested that the tariffs become effective four weeks after the date that the decision on the show cause proceeding set out in Decision 2003-76 was issued. TCI stated that this four-week period was critical to permit the completion of implementation activities.



The Commission received comments from Rogers Wireless Inc. (RWI), dated 22 December 2003 and 28 May 2004, and reply comments from TCI, dated 15 January 2004.


On 19 April 2004, the Commission issued interrogatories to TCI. The company responded on 29 April 2004, and amended its response on 14 May 2004.

Position of Parties


RWI's comments


RWI submitted that it welcomed the filing of a tariff for the two-way local/toll option and requested that TCI's applications be approved by the Commission, subject to certain changes. RWI objected to the proposed service charge and the proposed implementation time, and requested that TCI revise the proposed wording of item 555.4.14 in the former TCI's tariff and item 197-A.E.4(b) in TCBC's tariff.


RWI submitted that the proposed toll termination routing conversion service charge of $583.00 per NXX, or partial NXX, was excessive and unjustified. In RWI's view, redirecting toll traffic from existing one-way toll termination trunks to existing two-way trunks between RWI's POI and TCI's local switch would only require a single data translation change in the toll tandem switch and possibly a single data translation change in the local switch, for each NXX. RWI noted that the Commission had previously approved a service charge of $117.95 for TCI's 100-block and 1000-block trunk-side routing service, and submitted that these services, like the two-way local/toll option, required nothing more than data translation changes. RWI requested that the Commission direct TCI to use the same service charge of $117.95 for the two-way local/toll option, arguing that it would more accurately reflect the cost of performing the necessary data translations.


RWI noted that the proposed tariffs stated that where a WSP requested a change to its existing routing option, TCI would require an implementation time of one week for every two switches. RWI submitted that TCI did not provide justification for the implementation time, which was in addition to the twenty-day service interval required for trunk augmentation activities. RWI also stated that it was not clear why the additional service interval was expressed as a function of the number of switches.


RWI noted that item 555.4.14 of the former TCI tariff and item 197-A.E.4(b) of the TCBC tariff stated:

Toll Traffic Termination to a WSP's switch via Trunk Side Interconnection that carries both local and toll terminating traffic at TCI's designated local switch.


RWI submitted that TCI should revise the wording of these items to make it clear that WSPs, may, at their option, use the two-way trunks that were already installed between the WSP's POI and TCI's local switch. RWI stated that TCI must not require that WSPs establish new trunk groups for the purpose of combining local and toll terminating traffic.

TCI's reply comments and response to Commission interrogatories


TCI submitted that the proposed service charge was fully supported by its cost study and that it reflected the appropriate one-time cost for the conversion to the new two-way local/toll option.


TCI stated that the work required to make the two-way local/toll option available involved more than a single data translation, and included the following activities:
  • order processing and service provisioning/administration;
  • overall traffic routing study and planning in preparation for changes to traffic routing;
  • verification and review of routing tables;
  • pre-testing of translation changes;
  • input of data translation changes in both TCI's toll and local switches;
  • post implementation testing; and
  • overall review of impacts on TCI's network resulting from these routing changes.


TCI submitted that it was much more labour intensive to migrate an NXX, or a partial NXX, from an existing interconnection to another existing interconnection than to create a new interconnection. TCI further submitted that there was an added cost to ensuring that the conversion was co-ordinated in a manner that minimized the disruption of services to customers.


TCI submitted that the service charge of $117.95, approved for 100-block and 1000-block Trunk Side Routing was not appropriate for the purposes of the new toll routing conversion, due to the differences in the amount of resources required.


In response to Commission interrogatories, TCI provided confidential details of the labour time and labour unit costs for each activity involved in the conversion process. In an amendment to its response, TCI noted that it had inadvertently treated the labour costs used to generate the economic cost figures as one-time expenses instead of as ongoing expenses. TCI noted that, as a result of its error, it had overstated the Phase II costs and the proposed rates. TCI indicated that the service charge should be $543.00 per NXX or partial NXX, and filed an amended application, which reflected this adjustment.


With respect to implementation time, TCI stated that the standard twenty-day service interval for augmentation to trunk groups did not include any translation activity as required for traffic routing changes. TCI submitted that any activity outside trunk augmentations therefore required a separate period of time for implementation.


TCI also submitted that as RWI had not specifically identified either the quantities of the NXXs or the number of localities that it might want to migrate, it was appropriate to propose the implementation time as a function of the number of switches requested.


In response to RWI's concerns regarding the wording of former TCI item 555.4.14 and TCBC item 197-A.E.4(b), TCI confirmed its intention to use the WSPs' existing two-way trunks. To clarify, TCI amended the proposed wording of these sections to read:

Toll Traffic Termination to a WSP switch via two-way Trunk Side Interconnection that carries both local and toll terminating traffic at TCI's designated local switch. The WSP's existing two-way Trunk Side Interconnection trunk group will be used for this purpose. (additions are in bold.)


RWI's reply comments


RWI submitted that while it was encouraged by the lower proposed service charge, the charge was still much higher than the service charge for 100-block and 1000-block trunk side routing.


RWI submitted that it did not object to the wording proposed by TCI regarding the use of existing two-way trunks, as long as the WSP would be provided with adequate and reasonable time to augment its two-way trunk group capacity and to migrate its toll terminating traffic from the existing one-way trunks to the two-way trunks.

Commission's analysis and determination


In Follow-up to Telecom Decision 2003-76: Rogers Wireless Inc. vs. TELUS Communications Inc. - Toll termination arrangements, Telecom Decision CRTC 2004-68, 21 October 2004, the Commission directed TCI to offer the two-way local/toll option.


The Commission notes that the proposed service charge is a one-time charge for WSPs opting to migrate toll traffic from existing one-way trunk-side interconnections to two-way local/toll trunk-side interconnections. In the Commission's view, TCI will require more time and therefore incur more labour costs to deactivate an existing interconnection and migrate that interconnection to another existing interconnection than to create a new 100-block or 1000-block trunk-side routing interconnection.


Furthermore, the Commission considers that there will be additional costs to ensure that the translation activities required for conversion cause minimal interruption of service to the WSP's end-customers. The Commission does not expect that trunk augmentations have the same potential to result in the interruption of service to customers.


The Commission notes that the $117.95 service charge, approved for 100-block and 1000-block trunk side routing, is for trunk augmentations and that trunk augmentations require less work than migration from an existing one-way trunk side interconnection to the two-way local/toll option. The Commission therefore considers that a service charge of $117.95 would not reflect TCI's cost for conversion to the two-way local/toll option.


The Commission examined the list of activities and associated labour costs provided by TCI and considers that they are reasonable. Accordingly, the Commission is of the view that the proposed service charge of $543.00 is appropriate.


The Commission notes that the proposed implementation time of one week for every two switches refers to the period of time required by TCI to complete traffic routing changes to redirect toll traffic from existing one-way toll terminating trunks to existing pre-configured two-way trunks between RWI's POI and TCI's local switch. The Commission considers that the proposed implementation time of one week for every two switches is a reasonable amount of time to complete the required traffic routing changes.


The Commission notes that the twenty-day service interval, to which RWI referred, is the implementation time for trunk augmentations for 100-block/1000-block routing. The Commission considers that the twenty-day service interval is not applicable to the redirection of toll traffic to two-way trunks, unless trunk augmentations are also necessary to carry out the traffic redirection.


The Commission notes RWI's concerns regarding the clarity of the proposed wording in item 555.4.14 of the former TCI tariff and item 197-A.E.4(b) of the TCBC tariff. The Commission further notes that TCI proposed changes to that wording, and considers the revised wording to be appropriate, as it clarifies that the WSP's existing two-way trunks will be used to combine local and toll terminating traffic.


In light of the above, the Commission approves TCI's applications. The revisions take effect as of 22 November 2004.
  Secretary General
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Date Modified: 2004-10-21

Date modified: