ARCHIVED - Telecom Commission Letter - 8740-B2-200809296

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Ottawa, 21 October 2008

File No. 8740-B2-200809296

By E-mail

Mr. David Palmer
Director - Regulatory Matters
Bell Canada
110 O'Connor Street, 7th floor
Ottawa ON   K1P 1H1  

RE: Bell Canada Tariff Notice 7144 and Bell Aliant Tariff Notice 202 - Local Service Request (LSR) Rejection Charge

1.    On 4 July 2008, the Commission received applications by Bell Canada and Bell Aliant Regional Communications, Limited Partnership. (Bell Canada et al.) under cover of Tariff Notices 7144 and 202, respectively, in which they proposed the introduction of Access Services Tariff Item 108, Local Service Request (LSR) Rejection Charge.

2.    The Commission received comments from Rogers Communications Inc., MTS Allstream Inc., and Quebecor Media Inc. on behalf of its affiliate Videotron Ltd. (the intervenors). The Commission also received reply comments from Bell Canada et al., dated 15 August 2008.

3.   The procedures set out in the Commission's letter, dated 30 September 2008 are amended as follows:

a.   The parties to this proceeding are to provide responses to the attached interrogatories and other interrogatories addressed to them in the context of this proceeding by, serving copies on all other parties by 4 November 2008.

b.   The intervenors may file written arguments with the Commission with respect to the responses to the interrogatories and any issues raised in this proceeding, serving copies on all other parties by 28 November 2008.

c.   Bell Canada et al. may file reply arguments with the Commission, serving copies on all other parties by 8 December 2008.

d.   Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

Yours sincerely,

Original signed by

Suzanne Bédard
Senior Manager, Tariffs

cc:   Joe Cabrera, CRTC,, (819) 934-6352


1.   Provide Bell Canada et al. 's rationale as to why rejecting LSRs should not be considered part of the normal cost of providing this function, as for to other LECs.

2.   Paragraph 81, 82 and 83 of Telecom Decision 2003-72 state the following:

81. The Commission notes that in Decision 2001-217, Indicator 1.17 was introduced to monitor the possibility of biased treatment of a CLEC by an ILEC in respect of the rejection of LSRs because of perceived errors. The Commission is of the view that LSRs should not be rejected based on a subjective perception. Instead, an LSR should only be rejected on the basis of an error that can be objectively demonstrated and that requires some corrective action which warrants the subsequent re-issue of an order. The Commission is therefore of the view that the Definition of Indicator 1.17 should be changed to read "due to errors identified by the ILEC" instead of "due to errors perceived by the ILEC".

82. The Commission notes that no supporting rationale was provided by AT&T Canada to justify its proposed 5% standard. The Commission also notes that no alternative standard was proposed by any other participant in the BPWG.

83. The Commission is of the view that establishing a standard for Indicator 1.17 would help in the assessment of the quality of orders issued by CLECs. The Commission is also of the view that, in those cases where the standard is not met, an analysis of the ILEC's reasons for rejecting the CLEC's orders would assist both the ILEC and the CLEC in identifying the root problems with the orders and motivate the parties to find solutions.

In their 4 July 2008 applications, Bell Canada et al. submitted that the proposed LSR Rejection Charge is meant to "address the continuing high levels of order rejections and the limited use of CLEC Access to OSS Service, and to provide an incentive for Service Providers to reduce the level of LSR rejections."

(a)  In light of the Commission's position in Telecom Decision 2003-72, provide Bell Canada et al.'s justification for using the 5% standard as a threshold beyond which LSR rejection charges would apply;

(b)  explain whether, in Bell Canada et al.'s view, competitors currently have incentives to misuse the LSR process; identify these incentives and explain how the proposed LSR rejection charge would curtail this behaviour;

(c)   identify and describe the types of errors made by competitors that lead to LSR rejections; indicating which errors are not the result of a wrongful entry by the competitor;

(d)   identify whether Bell Canada et al. has worked with any CLEC(s) to identify the causes of, and find solutions to reduce LSR rejections, and if so, discuss the impact of these efforts; if not, explain why not;

(e)   identify the operational controls that Bell Canada et al. has put in place to avoid repeated errors by competitors with respect to LSRs.

3.   Provide the total number of LSRs that Bell Canada et al. have made to other service providers (LECs, WSPs, ISPs) over the period from January to June 2008 and the percentage that was rejected due to errors. The response should include a discussion of the most frequent types of errors causing LSR rejections and any company initiatives to find solutions to reduce the number of their LSRs that were rejected by other service providers.

4.   With respect to the present applications, provide Bell Canada et al. 's views on whether LSR rejection rates for a competitor are lower if the competitor subscribes to CLEC Access to Operational Support Systems (CAOSS) service . The response should discuss whether the LSRs that are rejected are typically from competitors that subscribe to CAOSS service.

5.   At paragraph 4 of their 4 July 2008 application, Bell Canada et al. argued that "a reduction in LSR rejections would reduce provisioning intervals for CLECs' local service customers and provide those CLECs with the opportunity to realize improvements in productivity, new revenues due to improved customer service and significant cost savings."

Given the above highlighted market incentives for CLECs to reduce the amount of LSR rejections, provide a detailed justification for the proposed LSR Rejection Charge rates, with particular emphasis on the proposed mark-up. The answer provided should address the Policy Directions' directive set out at paragraph 1(a)(ii).

6.   Identify whether there are differences in the error rate between LSRs that are submitted to Bell Canada et al. via automated versus manual systems, and if so, provide Bell Canada et al. 's views as to the reasons for the differences.

7.    Refer to the Service Provisioning expense (PWAC) per order estimate provided in Table 6 of the economic evaluation. Provide a detailed description of the activities required to process rejected LSRs. Further, provide the assumed processing time estimate by major activity including the assumed percentage occurrence and the applicable labour unit cost for each major activity. Include a discussion on how these activities may be impacted depending on the type of LSR and the type of error causing its rejection. Date Modified: 2008-10-21
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