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Telecom Decision CRTC 2006-5

Ottawa, 30 January 2006

VoIP 9-1-1 call routing

Reference: Aliant Telecom Inc. Tariff Notice 169
Bell Canada Tariff Notice 6879
MTS Allstream Inc. Tariff Notices 568 and 569
Saskatchewan Telecommunications Tariff Notice 87
TELUS Communications Inc. Tariff Notice 182
Former TELUS Communications Inc. Tariff Notice 551
TELUS Communications (B.C.) Inc. Tariff Notice 4236

In this Decision, the Commission approves on a final basis TELUS Communications Inc. Tariff Notice 182, Former TELUS Communications Inc. Tariff Notice 551 and TELUS Communications (B.C.) Inc. Tariff Notice 4236, and denies MTS Allstream Inc. (MTS Allstream) Tariff Notice 569. The Commission directs Aliant Telecom Inc. (Aliant Telecom), Bell Canada, MTS Allstream and Saskatchewan Telecommunications (SaskTel) to file tariff revisions to their respective tariffs to allow voice over Internet protocol (VoIP) service providers access to zero-dialed emergency call routing service (0-ECRS).

Following the Commission's approval of these tariff revisions to their respective 0-ECRS tariffs, Aliant Telecom, Bell Canada, MTS Allstream and SaskTel are directed to migrate their respective VoIP 9-1-1 call routing customers to 0-ECRS.

The Commission further directs Aliant Telecom, Bell Canada, MTS Allstream and SaskTel to include provisions within their respective Resale and Sharing tariffs in order to explicitly include in those tariffs the condition that local VoIP service providers are to abide by the directions set out by the Commission in paragraphs 52, 68, 93, 94 and 98 of Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005.

Background

1. In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Decision 2005-21), the Commission set out its determinations regarding the provision of 9-1-1 and Enhanced 9-1-1 (E9-1-1) service using local voice over Internet protocol (VoIP) services.

2. In Decision 2005-21, the Commission directed Canadian carriers offering fixed local VoIP services, where the end-user was assigned an NPA-NXX native to any of the local exchanges within the region covered by the customer's serving public safety answering points (PSAPs), to provide 9-1-1/E9-1-1 service, where it was available from the incumbent local exchange carrier (ILEC), within 90 days from the date of that Decision. The Commission stated that this service was to include provisioning end-user information in the Automatic Location Identification (ALI) database associated with the end-user's serving PSAP, and routing 9-1-1 calls, along with Automatic Number Identification (ANI) and ALI data, to the correct PSAP in a manner that was compatible with the PSAP's systems. The Commission also stated that call control features were to be supported to the extent technically feasible.

3. The Commission also directed Canadian carriers supporting nomadic local VoIP services or fixed/non-native local VoIP services to implement an interim solution, within 90 days from the date of Decision 2005-21, which would provide a level of 9-1-1 service, in areas where 9-1-1/E9-1-1 service was available from the ILEC, that would be functionally comparable to Basic 9-1-1 service. The Commission further directed Canadian carriers to ensure that a 9-1-1 call originating from a local VoIP service would not be routed to a PSAP that did not serve the geographic location from which the call was placed.

4. In addition, in Decision 2005-21, the Commission directed all Canadian carriers offering local VoIP services to provide initial customer notification, regarding any limitations that might exist with respect to 9-1-1/E9-1-1 service, before service commencement. The Commission stated that this information was to be made available through all of the following: marketing material used for television, radio and printed media, the terms and conditions of service, on-line material, customer service representatives, service contracts and starter kits.

5. The Commission further directed all Canadian carriers offering local VoIP service to provide on-going customer notification during service provision through all of the following: marketing material used for television, radio and printed media, the terms and conditions of service, on-line material, customer service representatives, warning stickers affixed to telephone sets and billing inserts.

6. For cases where there were limitations on VoIP 9-1-1/E9-1-1 service, in Decision 2005-21 the Commission directed Canadian carriers offering local VoIP services to obtain, prior to commencement of service, the customer's express consent, by which the customer acknowledged his/her understanding of the 9-1-1/E9-1-1 service limitations, using one of the methods approved in Part VII application to revise Article 11 of the Terms of Service, Telecom Decision CRTC 2005-15, 17 March 2005. The Commission stated that to ensure that information regarding limitations on 9-1-1/E9-1-1 service was accessible to persons with visual disabilities, all customer notification, and any printed information used to secure the express customer consent, must be provided in alternative formats (e.g. Braille and large print), upon request. The Commission also stated that to ensure that such documentation was accessible to persons with cognitive disabilities, local VoIP service providers are required, at a minimum, to explain it, upon request.

7. In Decision 2005-21, the Commission directed all Canadian carriers, as a condition of providing telecommunications services to local VoIP service providers, to include in their service contracts or other arrangements with these service providers, the requirement that the latter abide by the directions set out in paragraphs 52, 68, 93, 94 and 98 of that Decision.

8. The Commission issued Telecom Order CRTC 2005-245, 28 June 2005 (Order 2005-245), approving on an interim basis Aliant Telecom Inc. (Aliant Telecom) Tariff Notice 169 (TN 169), Bell Canada Tariff Notice 6879 (TN 6879), MTS Allstream Inc. (MTS Allstream) Tariff Notice 568 (TN 568), Saskatchewan Telecommunications (SaskTel) Tariff Notice 87 (TN 87) and TELUS Communications Inc. (TCI) Tariff Notice 182 (TN 182). The tariff notices by Aliant Telecom, Bell Canada, MTS Allstream, and SaskTel proposed the introduction of a VoIP 9-1-1 call routing service. TCI's tariff notice proposed a revision to General Tariff item 309, Emergency Services - Operator Access Coordination Service (ES-OACS), in order to allow VoIP service providers access to ES-OACS for the purpose of VoIP 9-1-1 call routing.

9. The Commission issued Telecom Order CRTC 2005-246, 29 June 2005, approving on an interim basis Former TCI Tariff Notice 551 (TN 551) and TELUS Communications (B.C.) Inc. (TCBC) Tariff Notice 4236 (TN 4236), which proposed revisions to TCI General Tariff item 130, Resale and Sharing of Services, and to TCBC General Tariff item 24, Resale and Sharing (the latter two tariffs collectively referred to as the Resale and Sharing tariffs), in order to explicitly include in those tariffs the condition that local VoIP service providers were to abide by the directions set out by the Commission in paragraphs 52, 68, 93, 94 and 98 of Decision 2005-21.

10. On 6 July 2005, the Commission received an application by MTS Allstream requesting approval of Tariff Notice 569 (TN 569) proposing revised tariff wording related to its VoIP 9-1-1 call routing service proposed in TN 568.

Process

11. On 8 July 2005, the Commission notified MTS Allstream that it would be premature to address TN 569 at that time, as TN 569 raised issues being addressed in TN 568. The Commission stated that its determination on TN 569 would be rendered at the same time as its final determination on TN 568.

12. On 22 July 2005, Aliant Telecom, Bell Canada, MTS Allstream and SaskTel filed responses to the Commission's interrogatories addressed on 6 July 2005.

13. The Commission received comments from the Alberta E9-1-1 Advisory Association (AEAA) on 5 July 2005, Xit télécom inc. on behalf of itself, Xittel télécommunications inc. and 9141-9077 Québec Inc. (Xit), on 29 July 2005, and TCI on 12 August 2005.

14. The Commission received reply comments from Aliant Telecom on 25 July 2005, and Bell Canada and SaskTel on 22 August 2005.

Positions of parties

Comments

15. The AEAA stated that it was in favour of both Aliant Telecom's and Bell Canada's proposed services. The AEAA submitted that public safety would be best served if ILEC VoIP 9-1-1 routing services were priced consistently and affordably across Canada.

16. The AEAA noted that Aliant Telecom and Bell Canada already provided zero-dialed emergency call routing service (0-ECRS) that were similar, in many respects, to the proposed VoIP 9-1-1 call routing services. The AEAA argued that, based on the existence of the 0-ECRS services, the incremental cost to add VoIP 9-1-1 call routing services did not justify the rates for which Aliant Telecom and Bell Canada had requested approval. The AEAA submitted that Aliant Telecom and Bell Canada could combine their respective 0-ECRS and VoIP 9-1-1 call routing services and offer a combined service for rates similar to those applicable for 0-ECRS.

17. The AEAA noted that Aliant Telecom's proposed rate for its VoIP 9-1-1 call routing service was $675 per month, with a one-time service charge of $3,730.70, and that Bell Canada's proposed rate was $2,309.49 per month, with a one-time service charge of $3,730.70.

18. The AEAA indicated that the total price for Aliant Telecom's 0-ECRS for New Brunswick, Newfoundland, Nova Scotia and Prince Edward Island was $508.49 per month with a one-time service charge of $2,804.99. The AEAA noted that the price for Bell Canada's 0-ECRS was $1,024.01 per month with a one-time service charge of $1,654.16.

19. The AEAA noted that an alternate operator services provider (AOSP) that required the ability to terminate 0-dialed emergency calls and 9-1-1 VoIP calls would need to subscribe to both services in both Aliant Telecom's and Bell Canada's territories, at a combined cost of $1,183.49 per month in Aliant Telecom's territory and $3,333.50 per month in Bell Canada's territory.

20. The AEAA referred to TCI's TN 182 to support its assertion that an ILEC could combine 0-ECRS and VoIP 9-1-1 call routing service without a significant price increase. The AEAA noted that instead of creating an entirely new service, TCI had proposed to expand its existing ES-OACS to include 9-1-1 VoIP calls, in addition to 0-dialed emergency calls, without any rate increases to ES-OACS.

21. Xit stated that it was not reasonable that Bell Canada's VoIP call routing service was limited to routing Basic 9-1-1 calls. Xit submitted that Bell Canada should be directed to enhance its VoIP 9-1-1 call routing service so that location codes could be transmitted.

22. Xit stated that it was interested in using the same system as that used for 0-ECRS in order to automate the routing of VoIP 9-1-1 calls without involving an operator when the caller's location was known. Xit also stated that, given Bell Canada's proposed rates, it should have the option of using the same system so as to eliminate any confusion associated with the intervention of several human operators who were not working for emergency call coordination centres and whose conversations were not recorded.

23. TCI stated that rather than limiting its proposed VoIP 9-1-1 call routing services to VoIP-originated calls only, Bell Canada should amend its application to allow non-IP voice-originated 0-dialed calls as well.

24. TCI stated that prior to Decision 2005-21, Aliant Telecom, Bell Canada, MTS Allstream, SaskTel and TCI each offered a service that provided 0-dialed emergency call access to end-users served by competitive local exchange carriers (CLECs), wireless service providers (WSPs), interexchange carriers (IXCs), competitive pay telephone service providers (CPTSPs) and AOSPs.

25. TCI stated that, recognizing the similarity in function between its ES-OACS and the service that it was directed to provide in Decision 2005-21, it had proposed to amend its ES-OACS tariff to include 9-1-1 dialed calls originating from VoIP service providers, but without changes to the rates or terms and conditions of the ES-OACS. TCI noted that Bell Canada proposed a new, non-automated version of 0-ECRS that would see 9-1-1-dialed calls from VoIP service providers directed to a Bell Canada operator before being redirected to the appropriate PSAP for response, rather than amend its 0-ECRS tariff in order to route emergency calls originating from VoIP service providers. TCI stated that, in essence, Bell Canada's VoIP call routing service would function like TCI's ES-OACS.

26. TCI stated that Bell Canada had indicated in reply to an interrogatory that its decision to provide a non-automated system to provide 9-1-1 access to VoIP service providers was based on two fundamental concerns with respect to handling 9-1-1 calls:

  1. calls may be routed to the wrong PSAP; and
  2. the existing 9-1-1 system, including the ALI database, may not accept out-of-territory NPA-NXXs. TCI noted that Bell Canada stated that its automated 0-ECRS systems could not be used to perform VoIP 9-1-1 call routing.

27. TCI indicated that it shared the AEAA's concern that Bell Canada's proposal would require AOSPs with the ability to terminate 0-dialed calls and VoIP 9-1-1 calls to subscribe to both 0-ECRS and VoIP 9-1-1 call routing service.

28. TCI argued that the requirement for certain service providers to subscribe to both 0-ECRS and the VoIP 9-1-1 call routing service could lead to unnecessary delays in the handling and processing of emergency calls. TCI stated, as an example, that Bell Canada's VoIP 9-1-1 call routing service would require the operators of those service providers who provide both 0-dialed and VoIP 9-1-1 call voice service to perform a triage function with respect to the type of emergency call, 0-dialed or VoIP 9-1-1, and, once determined, the call would then be routed to Bell Canada using either 0-ECRS or the VoIP 9-1-1 call routing service.

29. TCI stated that despite the functional similarity between 0-ECRS and the VoIP 9-1-1 call routing service, the rates for the latter were significantly higher. TCI noted that in response to an interrogatory, Bell Canada explained the difference by noting that it had conducted development work with regard to the VoIP call routing service. TCI submitted that these development costs were likely incurred by Bell Canada in order to meet its requirements for its own nomadic or fixed/non-native basis VoIP services.

30. TCI stated that its comments were in response to Bell Canada TN 6879 and Bell Canada's responses to interrogatories but also applied, in general, to Aliant Telecom TN 169 and SaskTel TN 87, although it did not address those tariff applications individually.

Reply Comments

31. Aliant Telecom stated that its 0-ECRS was based on traditional public switched telephone network services and could not accommodate the essential differences in VoIP services which required routing arrangements that recognized nomadic or fixed/non-native service arrangements. Aliant Telecom submitted that there was no opportunity to upgrade 0-ECRS to create a viable VoIP 9-1-1 call routing service.

32. Aliant Telecom stated that for 0-ECRS in Nova Scotia, New Brunswick and Prince Edward Island, the operator transferred the call to the 9-1-1 tandem office including ANI information from the end user, and from this point the call was treated as an E9-1-1 call with the 9-1-1 tandem routing the call based on the primary PSAP associated with the telephone number.

33. Aliant Telecom stated that for its proposed VoIP 9-1-1 call routing service, the Aliant Telecom call routing operator could not route the call based on ANI because the end user might have a non-native NPA NXX or might be roaming. Aliant Telecom submitted that its call routing operator verbally received the address from the VoIP service provider, manually looked up the PSAP associated with that address and forwarded the call to the 9-1-1 tandem where it was sent via the E9-1-1 trunks to the primary PSAP associated with the address.

34. Bell Canada noted that among all the ILECs only TCI and MTS Allstream had chosen to route both 0-dialed emergency calls and VoIP 9-1-1 calls over a single service. Bell Canada submitted that if it and the other ILECs had not adopted automated means to route 0-dialed emergency calls, it might have been possible for them to simply expand their 0-ECRS to include nomadic VoIP service 9-1-1 calls as well. Bell Canada was of the view, however, that even if this had been the case, differences between 0-dialed emergency calls and calls placed from nomadic VoIP services warranted additional development work.

35. Bell Canada submitted that, to the extent that the automation implemented for 0-dialed emergency calls potentially provided superior call routing, as the location of the caller was already known when the 0-dialed emergency call was initially placed by the end-user and the call could be routed automatically without human intervention, it would not be appropriate to extend eligibility to the VoIP 9-1-1 call routing service to 0-dialed emergency calls since this would result in degraded 0-dialed emergency service for all ILECs other than TCI.

36. Bell Canada submitted that it had developed its VoIP 9-1-1 call routing service to closely reflect the submissions made by the PSAPs' representatives in the Emergency Services Working Group (ESWG). Bell Canada indicated that its proposal was one of a number put forward in the ESWG by a variety of potential service providers and received strong PSAP support in the ESWG discussions.

37. Bell Canada argued that it had made substantial concessions in order to provide maximum flexibility to potential customers of this service. Bell Canada noted that in response to requests made by VoIP service providers in the ESWG when Bell Canada's proposal was reviewed and discussed, it had agreed to make changes so that the service could be available to call processing service providers. Bell Canada submitted that, as a result, the charges associated with the service would likely be shared by many VoIP service providers as call processing centres aggregated demand.

38. Bell Canada stated that, with reference to the concerns expressed by the AEAA and TCI regarding the rates proposed in its application, it had provided a detailed cost study in support of the proposed charges and the costs and revenues associated with the service reflected an all carriers approach.

39. Bell Canada rejected the premise put forward by TCI that an extra step in emergency call processing would be imposed as a result of the existence of two services. Bell Canada submitted that since 0-dialed emergency calls differ in important respects from VoIP 9-1-1 calls, prudent call answering service providers would handle 0-dialed emergency calls and VoIP 9-1-1 calls in separate streams.

40. Bell Canada noted that Xit supported final approval of Bell Canada's application on the condition that the service was enhanced to enable provision of an enhanced 9-1-1 service. Bell Canada submitted that Xit's remaining comments appeared to focus on proposals to further improve VoIP 9-1-1 calling services and argued that the ESWG was the appropriate forum to consider future VoIP 9-1-1 calling services.

41. SaskTel noted that its VoIP 9-1-1 call routing service was developed in conjunction with the other ILECs as an interim, short-term solution in response to the Commission's directives arising from Decision 2005-21. SaskTel stated that utilizing each ILEC's operator services within their territories to route in-province VoIP 9-1-1 calls was the best interim solution until such time as a long term Enhanced 9-1-1 solution for nomadic and non-native VoIP was developed. SaskTel stated that its proposed service was consistent with the services proposed by Bell Canada and Aliant Telecom, and endorsed by the representatives of PSAPs participating in the ESWG.

42. SaskTel stated that the option was left open for any VoIP service provider to employ a third party to assist in the handling of nomadic and non-native VoIP 9-1-1 calls rather than subscribe to SaskTel's VoIP 9-1-1 call routing service.

Commission's analysis

Disclosure of 10-digit PSAP numbers

43. The Commission notes that in response to interrogatories, Bell Canada indicated that in ESWG contribution ESCO0200, 29 April 2005 (ESCO0200), the 9-1-1 agencies set out their views with regard to the interim VoIP 9-1-1 calling solution mandated for nomadic VoIP services in Decision 2005-21. Bell Canada stated that its contribution was supplemented by comments provided by the 9-1-1 agencies' representatives who participated in the ESWG meetings and conference calls and that, on several occasions, the 9-1-1 agencies stated that they had serious concerns regarding the disclosure of the 10-digit numbers that local exchange carriers (LECs) currently used to route calls to the 9-1-1 agencies to VoIP service providers and/or to call processing intermediaries.

44. The Commission notes that in ESCO0200, the PSAP representatives indicated their desire to  eliminate the need for circulating non-published 10-digit PSAP numbers to any number of unknown and unregulated third parties.

45. In Regulatory framework for voice communication services using Internet Protocol, Telecom Decision CRTC 2005-28, 12 May 2005 (Decision 2005-28), the Commission determined that local VoIP services should be regulated as local exchange services, and that the regulatory framework governing local competition as set out in Local Competition, Telecom Decision CRTC 97-8, 1 May 1997 (Decision 97-8), and subsequent determinations applies to local VoIP service providers, except as otherwise provided in Decision 2005-28. In Decision 2005-28, the Commission concluded that the rights and obligations of Canadian carriers providing local exchange services are set out in Decision 97-8 and that it would not be appropriate to modify those rights and obligations in respect of the provision of local VoIP services. With regard to VoIP services, the Commission determined that non-dominant Canadian carriers must fulfill the requirements of a CLEC and conform to the entry procedures set out in Decision 97-8 in order to provide local exchange services in Canada. The Commission directed that all local VoIP service providers that were not operating as Canadian carriers were to register with the Commission as resellers, as a condition of obtaining services from a Canadian carrier or other telecommunications service provider.

46. As provided in Decision 2005-28, local VoIP service providers in Canada will be operating either as LECs or resellers. The Commission, therefore, does not consider LECs or resellers to be unknown third parties. The Commission notes that the 10-digit numbers currently used by LECs to route calls to 9-1-1 agencies are already made available to various types of service providers through the ILECs' 0-ECRS. The Commission also notes that VoIP service providers that also offer non-VoIP services would already have access to these numbers. The Commission is of the view that preventing VoIP-only service providers that are not carriers from obtaining the 10-digit numbers that LECs currently use to route calls to 9-1-1 agencies could harm the customers of those VoIP-only service providers in case of emergencies, and would be unjustly discriminatory against those service providers and their customers.

47. Accordingly, the Commission concludes that local VoIP service providers should have access to the 10-digit numbers currently used by LECs to route calls to 9-1-1 agencies.

Emergency call routing service

48. In Decision 2005-21, the Commission found that an interim solution for the routing of 9-1-1 calls associated with nomadic or fixed/non-native local VoIP services that connects an emergency call to an intermediary, which in turn transfers the call to the proper PSAP or emergency services agency, would provide benefits similar to Basic 9-1-1 service. The Commission also considered that an interim solution that uses an intermediary would mitigate the financial and other burdens that improper routing of calls places on PSAPs and, in effect, the local VoIP service providers would absorb the costs of the temporary work-around by funding the intermediary call centres.

49. The Commission notes that all the ILECs have proposed interim solutions that are functionally comparable to Basic 9-1-1 service. Aliant Telecom, Bell Canada, MTS Allstream and SaskTel have each proposed the introduction of a service specifically for routing of VoIP 9-1-1 calls, whereas TCI has proposed to modify its existing ES-OACS in order to make this service available to VoIP service providers.

50. The Commission finds that TCI's proposal to offer ES-OACS to local VoIP service providers for the routing of emergency calls from their end-customers is reasonable.

51. The Commission is however concerned about the additional costs that the proposals of Aliant Telecom, Bell Canada, MTS Allstream and SaskTel would impose on local service providers that offer both VoIP and non-VoIP services. The Commission notes that while these service providers would only be required to subscribe to ES-OACS in TCI's territory, they would be required to subscribe to both 0-ECRS and VoIP 9-1-1 call routing service in the territories of Aliant Telecom, Bell Canada, MTS Allstream and SaskTel.

52. The Commission notes that  the 0-ECRS services of Aliant Telecom, Bell Canada, MTS Allstream and SaskTel, and the current ES-OACS service of TCI, allow CLECs, WSPs, IXCs, CTPSPs and AOSPs to route emergency calls from their end-customers to the designated PSAP or other emergency response agencies within the ILECs' respective territories. The Commission agrees that the functionality provided by ES-OACS and 0-ECRS is very similar to the service that the ILECs were directed to provide in Decision 2005-21.

53. The Commission notes that Decision 2005-21 required the local VoIP service providers to fund the intermediary call centres. The Commission notes that with access to the 10-digit numbers currently used by LECs to route calls to 9-1-1 agencies, a local VoIP service provider operator could interface directly with the PSAP in order to provide its end-customers Basic 9-1-1 service on nomadic or fixed/non-native calls. In such an instance, the operator that Aliant Telecom, Bell Canada, MTS Allstream and SaskTel would provide with VoIP 9-1-1 call routing service would not be required.

54. Accordingly, the Commission considers that Aliant Telecom, Bell Canada, MTS Allstream and SaskTel should file tariff revisions to allow VoIP service providers access to 0-ECRS at the same rates as any other service provider. To ensure continuity of service, Aliant Telecom, Bell Canada, MTS Allstream and SaskTel are to maintain the services given interim approval in Order 2005-245, until the tariff revisions to their 0-ECRS tariffs are approved by the Commission and their customers to VoIP 9-1-1 call routing service have been migrated to 0-ECRS.

Inclusion of provisions within Resale and Sharing tariffs

55. As noted above, in Decision 2005-21, the Commission directed all Canadian carriers, as a condition of providing telecommunications services to local VoIP service providers, to include in their service contracts or other arrangements with these service providers, the requirement that the latter abide by the directions set out in paragraphs 52, 68, 93, 94 and 98 of that Decision.

56. The Commission notes that in TCI TN 551 and TCBC TN 4236, TCI proposed revisions to its Resale and Sharing tariffs in order to explicitly include in these tariffs the condition that local VoIP service providers are to abide by the directions set out by the Commission in paragraphs 52, 68, 93, 94 and 98 of Decision 2005-21. The Commission notes, however, that Aliant Telecom, Bell Canada, MTS Allstream, and SaskTel did not propose the same condition in their respective tariffs.

57. The Commission considers that it would be appropriate for Aliant Telecom, Bell Canada, MTS Allstream and SaskTel to include provisions within their respective Resale and Sharing tariffs in order to explicitly include in those tariffs the condition that local VoIP service providers are to abide by the directions set out by the Commission in paragraphs 52, 68, 93, 94 and 98 of Decision 2005-21.

MTS Allstream TN 569

58. The Commission considers that, in light of its directive set out in this Decision to MTS Allstream and the other 0-ECRS based ILECs to migrate their VoIP 9-1-1 call routing customers to 0-ECRS, approval of MTS Allstream TN 569 would serve no purpose.

Commission's determinations

59. Accordingly, the Commission:

60. Aliant Telecom, Bell Canada, MTS Allstream and SaskTel are to file proposed tariff pages within 30 days of the date of this Decision.

Secretary General

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