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Ottawa, October 29, 2013

Our reference: 8662-R28-201312610

BY EMAIL

Mr. David Watt
Vice President – Regulatory Telecommunications
Rogers Communications Partnership
333 Bloor Street East
Toronto, Ontario M4W 1G9
RCI.Regulatory@rci.rogers.com

Mr. Scott Mitchell
Telecom Manager
Cochrane Telecom Services
153 Sixth Avenue
Cochrane, Ontario P0L 1C0
smitch@cochranetel.ca

RE: Rogers Application to Review and Vary Telecom Order CRTC 2013-287, Cochrane Telecom Services – Revisions to Wireless Access Tariff and Carrier Access Tariff regarding network interconnection

Dear Sirs:

On 11 September 2013, the Commission received an application by Rogers Communications Partnership (RCP) requesting that the Commission review and vary Telecom Order CRTC 2013-287 (Telecom Order 2013-287). RCP submitted that Telecom Order 2013-287 contains errors in fact and in law, and that it failed to consider a basic principle – namely, that the Commission has consistently allowed SS7 transit via third-party arrangements.

Rogers requested that the Commission

a) vary Telecom Order 2013-287 by mandating that Cochrane Telecom Services (Cochrane) accept SS7 third-party transit arrangements, and

b) direct Cochrane to include a specific clause in its Wireless Access Service tariff that stipulates that the monthly SS7 port charges can only be applied when direct SS7 links are used between the wireless service provider and the small incumbent local exchange carrier.

The Commission received comments from Cochrane and Allstream Inc., both dated 15 October 2013, and reply comments from RCP, dated 25 October 2013.

Paragraph 28(1) (a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.

RCP and Cochrane are requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 8 November 2013.

RCP and Cochrane may provide reply comments to the responses by 13 November 2013.

Yours sincerely,

Original signed by

Michel Murray
Director, Regulatory Implementation
Telecommunications

c.c.: Jonathan Holmes, ITPA, jonathan.holmes@itpa.ca
Allen Trafford, MTS Allstream, allen.trafford@mtsallstream.com
Teresa Griffin-Muir, MTS Allstream, workstation@mtsallstream.com
Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca

ATTACHMENT

Request for information

In Network interconnection for voice services, Telecom Regulatory Policy CRTC 2012-24, 19 January 2012, the Commission determined that parties could enter into off-tariff network interconnection arrangements without seeking regulatory approval. In Telecom Order CRTC 2013-287, the Commission noted that although Cochrane’s proposal to include rates for wireless carrier signalling network interconnection arrangements in its tariff was appropriate, it did not prevent parties from making alternative arrangements pursuant to Telecom Regulatory Policy 2012-24.

Questions for RCP

1. RCP stated in its 25 October 2013 reply comments that it had tried to negotiate a third-party SS7 transit arrangement with Cochrane with no success. Identify
i. the terms and conditions RCP was attempting to negotiate with Cochrane, and
ii. why negotiations were not successful.

2. Identify why RCP would prefer to interconnect with Cochrane through a third-party transit arrangement rather than interconnect directly with Cochrane’s network. If there is any cost difference, identify the magnitude of the cost difference and the savings that would result from using a third-party transit arrangement.

3. Describe in detail what RCP would be required to do in order to implement a third-party SS7 transit arrangement with Cochrane.

Questions for Cochrane

1. Identify when Cochrane was approached by RCP to negotiate a third-party SS7 transit arrangement, and the terms and conditions RCP was attempting to negotiate with Cochrane.

2. Explain why RCP’s attempt to negotiate with a third-party SS7 transit arrangement with Cochrane was not successful, including whether or not there are technical and/or operational issues preventing Cochrane from permitting this type of interconnection with RCP.

3. Describe in detail what would be required for Cochrane to implement a third-party SS7 transit arrangement with RCP.

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