ARCHIVED - Telecom Commission Letter Addressed to Ian Gomm (Broad-Connect Telecom Inc.)

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Ottawa, 23 October 2014

File number: 8740-B77-201401059

BY E-MAIL

Mr. Ian Gomm
Vice-President, Carrier Relations
Broad-Connect Telecom Inc.
151 North Rivermede Rd.
Concord, Ont.  L4K 0C4
ian.g@broadconnect.ca

Re: Tariff Notice No. 1 – Access Services Tariff

Dear Sir:

On 3 February 2014, the Commission received an application by Broad-Connect Telecom Inc. (Broad-Connect), under Tariff Notice 1 (TN 1), in which the company proposed to introduce its competitive local exchange carrier (CLEC) Access Services Tariff (AST). The company noted that it intended to register and operate as a Type IV CLEC.

Broad-Connect submitted that its proposed tariff was based on the CLEC Model Tariff version 34-1. It noted that it intended to register and operate as a Type IV CLEC and, therefore, had modified Part E of the CLEC Model Tariff to reflect, among other things, that it would obtain LRN Absent, Port-out cancellation charge and 9-1-1 services through Bell Canada. The Company also proposed to exclude Part C and D of the CLEC Model Tariff because it did not intend to provide interconnection services with interexchange or wireless service providers (IXSPs or WSPs).   

Commission staff notes that, as a proposed CLEC, Broad-Connect must adhere to all CLEC obligations and requirements, which are set out in Telecom Decision 97-8 and Telecom Decision 2006-58, and are summarized on the Commission’s website (http://www.crtc.gc.ca/eng/comm/telecom/eslcclec.htm).

Commission staff notes that for service providers qualifying as Type IV CLECs, a number of the obligations may be fulfilled on behalf of the CLEC through an arrangement with a third party and that such CLECs are also relieved of fulfilling certain obligations.

However, staff notes that although Telecom Decision 2006-58 relieves Type IV CLECs from providing equal access to IXSPs, they are not relieved from the requirement to interconnect with IXSPs and WSPs for the purpose of terminating calls to their customers.

Therefore, Broad-Connect must specify how it will interconnect with other telecommunications service providers in Part C and D of its CLEC tariff. If the interconnection services provided to IXSPs and WSPs under Part C and D, respectively, are to be carried out by Bell Canada pursuant to Bell Canada’s tariffs, this must be specified in these sections. See, for example, Nor-Del Cablevision Limited’s TN 1 (https://crtc.gc.ca/8740/eng/2013/n85.htm).

Further, staff reminds Broad-Connect that although it has a Schedule C with Bell Canada, Type IV CLECs are still required to enter into a master agreement for local interconnection (MALI) with all other local exchange carriers (LECs) operating in the same exchange(s) and file Schedule C(s) to that MALI with the Commission. The Special MALI applicable to Type IV CLECs is available on the Commission’s website under “CRTC Interconnection Steering Committee.” 

Broad-Connect is requested to provide amended tariff pages to reflect the changes required to Part C and D of its tariff.

Yours sincerely,

Original signed by

Michel Murray
Director, Regulatory Implementation
Telecommunications Sector

c.c.: Wendy McClintock, CRTC, 819-639-6211, wendy.mcclintock@crtc.gc.ca

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