ARCHIVED - Telecom Commission Letter - 8740-B2-200809296
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Ottawa, 21 October 2008
Mr. David Palmer
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:
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.
Original signed by
cc: Joe Cabrera, CRTC, email@example.com, (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:
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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