Telecom Commission Letter Addressed to Donald Cavanagh (Navigata Communications Limited)

Ottawa, 11 July 2018

Our reference: 8740-N108-201801522

BY EMAIL

Mr. Donald Cavanagh
VP Service Operations
Navigata Communications Limited
3300 Bloor St. W. West Tower, Suite 801
Toronto Ontario M8X 2X2
regulatory@distributel.ca

RE:  Tariff Notice 1, 1A – CLEC General Tariff

Dear Mr. Cavanagh:

On 16 March 2018, the Commission received an application by Navigata Communications Limited (Navigata), under Tariff Notice (TN) 1, proposing to introduce its CLEC General Tariff CRTC 25670 with applicable rates that cross-reference to the specific tariff items containing the applicable rates set out in the incumbent local exchange carrier (ILEC) tariff.

Commission staff is continuing its analysis of this application.

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

Navigata is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 19 July 2018. Any revisions to tariff pages should be filed as TN 1B.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c.: Joanne Baldassi, CRTC, 819-997-3498, joanne.baldassi@crtc.gc.ca

Requests for information

Under TN 1A, submitted on 26 June 2018, Navigata filed revisions to its proposed Access Services tariff pages to operate as a competitive local exchange carrier (CLEC).

  1. In Part D, Item 401 (1), page 51, regarding Terms and Conditions Applicable to Interconnection with WSPs, Navigata did not include the company name. Please resubmit the tariff page with this information added.
  2. In Part E, Item 501 (4), page 65, regarding Call Routing - Location Routing Number (LRN) Absent, Navigata has included the following text:

    NAVIGATA COMMUNICATIONS LIMITED may also provide the service in this tariff at rates and on terms different from the tariffed rates and terms if the service is provided pursuant to an agreement entered into between NAVIGATA COMMUNICATIONS LIMITED and a competitor because the Commission has forborne, in Telecom Decision CRTC 2008-17, with respect to the regulation of this service.

    Commission staff notes that Decision 2008-17 phased out only certain non-essential services, and call routing is classified as a public good rather than a non-essential service subject to phase-out.  Provide additional justification regarding why this text should be included in the company’s Access Services Tariff. 

  3. In Part E, Item 502.1, page 68, Local Service Request (LSR) Rejection Charge, Navigata has included incorrect dates for the Local Service Request (LSR) Rejection Charge thresholds. As noted in paragraphs 30 and 31 of Telecom Regulatory Policy 2012-523, the lower threshold will be set at 12.8 percent on the date that the tariff is first approved by the Commission. That rate will decrease to 10.4 percent one year after the tariff is approved, and 8 percent two years after the tariff is approved. The higher threshold will be set at 25.6 percent on the date that the tariff is first approved by the Commission, decreasing to 20.8 percent one year after the tariff is approved and 16 percent two years after the tariff is approved.

    The tariff page currently states, for example, in 2(c)(1)   “A monthly LSR rejection rate threshold of 12.8% until 11 July 2018 …”. Navigata should use later dates in its revised filing (e.g. 31 July 2019 and 31 July 2020 as its proposed threshold dates). Please resubmit the tariff page with this information added.

  4. 4. In Part E, Item 503 (9), page 75, regarding 9-1-1 Emergency Response Service (ERS) Limitation of Liability, Navigata did not indicate where the company’s liability terms are set out.  Navigata can include a reference to Part A, Item 102 (10) which lists the company’s liability terms. Please resubmit the tariff page with this information added.

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