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Telecom Order CRTC 2023-26

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Ottawa, 10 February 2023

Public records: Tariff Notice 567; Tariff Notice 644; Tariff Notice 568

TELUS Communications Inc. – Tariff Notices 567 and 644 – Destandardization of DS-0 and DS-1 services and Tariff Notice 568 - Destandardization of DS-0 and DS-1 competitor digital network services

Summary

The Commission approves with modifications TELUS Communications Inc.’s Tariff Notices 567, 644 and 568.

Applications

  1. The Commission received applications from TELUS Communications Inc. (TCI), Tariff Notices (TNs) 567, 644 and 568, dated 27 January 2022, in which the company proposed changes to its General Tariff CRTC 21461, its General Tariff CRTC 25080, and its Carrier Access Tariff.
  2. Specifically, in TNs 567 and 644, TCI proposed changes to
    • General Tariff CRTC 21461, Item 500, Digital Network Access;
    • General Tariff CRTC 21461, Item 503, Inter-Exchange (IX) Digital Channels;
    • General Tariff CRTC 25080, Section 5.01.02, Accès au réseau numérique; and
    • General Tariff CRTC 25080, Section 5.01.14, Circuits numériques intercentraux.

    In TN 568, the company proposed changes to

    • Carrier Access Tariff CRTC 21462, Item 224, Competitor Digital Network (CDN) Services; and
    • Carrier Access Tariff CRTC 21462, Item 225, Competitor Digital Network Access (CDN Access).
  3. In TNs 567 and 644, TCI proposed to destandardize DS-0 and DS-1 digital network access (DNA) and inter-exchange (IX) channelsFootnote 1 such that
    • DS-0 DNA and DS-0 IX channels would no longer be available for new installations for any customers, but would be maintained for existing customers as is, without additions, moves or changes; and
    • DS-1 DNA and DS-1 IX channels would no longer be available for new customers; existing customers would not be impacted.
  4. In TN 568, TCI proposed to destandardize DS-0 competitor digital network (CDN) accesses, and DS-1 CDN links and accesses, such that
    • DS-0 CDN accesses would no longer be available for new installations for any customers, but would be maintained for existing customers as is, without additions, moves or changes; and
    • DS-1 CDN links and accesses would no longer be available to new customers; existing customers would not be impacted.

    For wholesale customers, TCI proposed not to destandardize those services when they are used

    • for interconnections pursuant to master agreements for local interconnection that carriers have signed with TCI; or
    • for connections between customers’ points of presence and TCI’s network for the purposes of obtaining any of TCI’s interconnection services, including toll, local, wireless and transiting services, as set out in the appendix to Telecom Decision 2008-17.
  5. TCI submitted that, with the exemptions for interconnection arrangements, the proposed destandardization would not result in a lessening of competition.
  6. TCI submitted that the proposed destandardization would help alleviate operational challenges impacting both retail and wholesale customers. The company stated that destandardization is necessary because the use of manufacturer-discontinued equipment is causing increasing difficulty in sourcing replacement parts for repairing and maintaining the affected services.
  7. TCI stated that the situation has been particularly challenging for DS-0 services and that it is therefore crucial to stop supporting new customers and additions, moves and changes for existing customers. For DS-1 services, TCI indicated that ceasing to support new customers would be the first phase of destandardization and would help ensure that network equipment supply is reserved for existing customers, while sending a signal for them to consider alternatives.
  8. TCI submitted that the demand for DS-0 and DS-1 DNA and IX channels has been declining in recent years, and that there have been no new customers for DS-0 or DS-1 CDN links and access services in the past two years.
  9. TCI identified various possible substitutes for the affected services that are based on newer, more easily supported technology that enables much faster data transmission. The company submitted that the proposed destandardization would encourage customers to migrate to substitutes before the reliability of the affected services is seriously jeopardized.
  10. TCI stated that, pursuant to Telecom Information Bulletin 2010-455-1, it would provide notice to all existing customers of the affected services, informing them of the proposed destandardization and providing information on how to submit comments to the Commission by 14 March 2022.
  11. TCI requested an effective date of 28 March 2022.
  12. The Commission received an intervention regarding both applications from Distributel Communications Limited (Distributel), dated 15 March 2022, and an intervention from Shaw Communications Inc. (Shaw) regarding TN 568, also dated 15 March 2022.

Interventions

Distributel

  1. Distributel put forward two main arguments:
    • TCI should not be permitted to use the destandardization process instead of the forbearance process in order to relieve itself of its obligation to provide the affected services on a regulated basis. However, if its applications are approved, TCI should be required to either identify or offer to provide substitute services in all areas, at similar rates.
    • The question of the extent to which telecommunications service providers (TSPs) should be allowed to continue using the affected services for interconnection and network-related purposes when they are destandardized or otherwise forborne from regulation raises issues about interconnection that are not specific to TCI. Such issues should be considered as part of a broader review of the interconnection framework.
Destandardization versus forbearance
  1. Distributel submitted that, despite their legacy nature, the affected services continue to meet the needs of TSPs and customers that require economic, reliable low-speed connectivity that is subject to quality of service requirements. Distributel noted that in Telecom Decision 2019-344 the Commission denied TCI’s application for forbearance of the same CDN services that it now seeks to destandardize.
  2. Distributel argued that if TCI, or any other incumbent local exchange carrier (ILEC), is unable to obtain forbearance of a service, it should not be permitted to achieve an equivalent outcome through a process that is far less robust and imposes a lower evidentiary threshold, i.e., destandardization. According to Distributel, the destandardization process, unlike the forbearance process, does not provide the Commission with the necessary information to determine whether there is enough competition to protect the interest of users in the applicable market, or whether destandardization would instead harm the competitive market for a service.
  3. Distributel noted that the substitutes that TCI identified in its application are the same ones mentioned in its forbearance application, which the Commission denied. Distributel submitted that TCI has not provided any rationale as to why the Commission’s determinations in that decision are no longer correct or why the fibre-based, Internet Protocol (IP)-based, or coaxial cable-based services that TCI identified as alternatives to the affected services should now be considered appropriate. Distributel added that TCI has not demonstrated that fibre optic and coaxial cable facilities are present in all areas where the affected services are currently available.
  4. According to Distributel, if TCI is unable to identify a substitute service that is available at similar rates, it could propose to offer such a service where feasible. As an example, Distributel submitted that TCI could offer DS-3 DNA servicesFootnote 2 where they are available, at similar rates to the affected services. However, Distributel argued that, if such a service is unavailable in an area where the affected services are currently offered, the Commission should not permit them to be destandardized in that area.
Broader review of the interconnection framework
  1. According to Distributel, if the Commission were to approve the destandardization of the affected services, that decision should not apply to TSPs that utilize those services for purposes other than directly providing a retail service to a customer.
  2. From its perspective as a TSP, Distributel stated that the affected services are primarily used to connect points within its network and to establish local, toll, wireless, and transiting interconnections with TCI.
  3. Distributel acknowledged that, to address the impact that destandardization would have on such usage of the affected services, TCI has proposed tariff language to exempt them where they are used for those purposes. However, Distributel added that, while it appreciated TCI’s recognition that the affected services remain necessary for interconnection-related purposes at this time, a determination about the extent to which TSPs should be allowed to continue using the affected services when they are otherwise forborne or destandardized would raise broader interconnection-related issues and considerations that are applicable not just to TCI, but to all TSPs and ILECs. Distributel submitted that those considerations include whether and how IP-based interconnection represents an alternative to CDN/DNA/IX-based interconnection for all or some interconnection arrangements available from an ILEC (i.e., toll, local, wireless, and transiting); whether and how parties should be encouraged to migrate to IP-based interconnection and away from legacy services; whether the wording of any CDN/DNA/IX destandardization or forbearance exemption is broad enough to account for how TSPs use CDN/DNA/IX services for interconnection and network-related purposes; and other, similar considerations.
  4. Distributel noted that Bell Canada recently raised similar concerns regarding its ability to continue supporting CDN services. According to Distributel, this provides evidence that issues related to the continued use and support of DS-0- and DS-1-based services are industry-wide. Distributel added that, given the extent to which local and toll interconnection arrangements continue to rely on legacy DS-1 architecture at this time, ILEC’s concerns related to the continued ability to support those services are concerns for TSPs as well. According to Distributel, the IX expansion plans of competitive local exchange carriers should not be impeded, now or in the future, based on the availability of DS-0 and DS-1 equipment. To this end, according to Distributel, a broader proceeding should identify and remove barriers that currently prevent TSPs from migrating away from DS-0- and DS-1-based services.
  5. Finally, Distributel added that its intent is not to suggest that TCI should be required to provide the affected services indefinitely. However, Distributel noted that the Commission has stated its intention to initiate a proceeding to review the interconnection framework. The company was of the view that such a proceeding would be an appropriate place to review this matter and allow for a determination that would apply to all ILECs.

Shaw

  1. Shaw’s intervention regarded TN 568 and focused on specific terminology proposed for items 224 and 225 of the Carrier Access Tariff.
  2. Shaw submitted that it is not clear what exactly is meant by “Customer” because it is not a defined or commonly used term in TN 568. The relevant tariff items instead use the terms “Competitors” and “End-Customers”.
  3. Shaw stated that it had contacted TCI to confirm (i) that the proposed changes would not limit Shaw’s ability to use DS-1 CDN links and accesses to serve new end-customers (as defined in TN 568;) and (ii) that the term “new customers” in TN 568 means new wholesale customers of TCI (or “Competitors”, as they are referred to in TN 568) not new end-users of TCI’s existing wholesale customers (or "End-Customers", as they are referred to in TN 568). Shaw indicated that TCI confirmed that this understanding was correct.
  4. Shaw recommended replacing the word “Customer” with “Competitor” in the tariff changes proposed in TN 568 in order to better reflect TCI’s intention to permit wholesale customers to add new end-users on DS-1 services.

TCI’s reply

  1. Regarding Distributel’s comments on forbearance and destandardization, TCI submitted that these are distinct processes with different outcomes. TCI stated that a regulated carrier applies for forbearance as a means to better compete with alternative providers of the services in question or similar services, raising or lowering rates according to market conditions. While, in TCI’s view, the ability to withdraw the service is a feature of forbearance, it is generally not the reason for a forbearance application.  In contrast, destandardization has a far more limited scope, suitable primarily for services that are nearing the end of their lives and that the carrier intends to eventually discontinue.
  2. TCI submitted that the intent of the proposed destandardization is to adjust the support of the affected services in response to the declining supply of manufacturer-discontinued equipment so that it can serve existing customers more adequately without compromising competition.
  3. TCI submitted that, should the proposed destandardization be approved, the company would continue to provide the affected services pursuant to the terms, conditions and rates specified in the approved tariffs. TCI also noted that, unlike services that have been granted forbearance, the destandardized services would remain fully regulated and would be subject to the Commission’s tariff application processes for any future changes.
  4. In response to Distributel’s argument that TCI has an obligation to provide the affected services because they are still regulated, TCI noted that, while CDN is a mandated competitor service, DNA and IX Channels are not mandated, because they are general tariff services that serve both retail and wholesale customers. TCI added that even if a service is tariffed, it does not imply an unending obligation to serve.
  5. Regarding the need for substitutes with the same availability as the affected services at similar rates, TCI noted that the Commission eliminated the requirement to establish the availability of reasonable substitutes in Telecom Decision 2008-22. TCI also noted that in the notification it sent to all customers impacted by the applications, it listed possible substitutes to the affected services, and encouraged customers to contact sales representatives to discuss the available options. TCI submitted that it intends to work with impacted customers to determine the appropriate transition plan and substitutes based on their specific business needs.
  6. TCI also submitted that Distributel’s statement that fibre-based, IP-based and cable-based services should not be accepted as appropriate substitutes is irrelevant, because the Commission statement cited in that regard was made in response to an application for forbearance, not for destandardization.
  7. TCI further submitted that, even if there were no substitutes for the affected services, the shortage of equipment would make the proposed destandardization both necessary and prudent.
  8. TCI noted that wholesale customers have been migrating from DS-0 and DS-1 services to the substitutes it mentioned in its applications and that, with the exception of Distributel’s intervention, it had received no comments on its proposal. TCI added that the demand for these legacy services has been declining rapidly.
  9. Regarding the need for a review of the interconnection framework, TCI was of the view that Distributel had not identified any issue that the Commission did not consider in developing the guideline for destandardization set out in Telecom Information Bulletin 2010-455-1. TCI submitted that a broader, industry-wide review to define exemption rules on the destandardization of DS-0 and DS-1 services is not needed in order to approve the proposed changes; delaying approval to permit such a review, on the other hand, may mean that the protection of existing customers will not be possible.
  10. TCI therefore requested that the Commission approve its applications separate from any industry-wide proceedings to avoid delay that could compromise the existing services, noting that this would not preclude further changes that might result from a future review.
  11. However, TCI agreed with Distributel’s comments regarding wholesale customers’ usage of the affected services for the purpose of connecting to co-locations. TCI acknowledged the importance of co-location for purposes of interconnection, and proposed additional wording to the destandardization exemption clause in the proposed tariffs that would extend the exemption to include that purpose.
  12. Regarding Shaw’s intervention, TCI indicated that it agreed with Shaw’s recommendation regarding the specific usage and definition of the term “Competitor” in Items 224.3, 225.1, and 225.3 of TCI’s Carrier Access Tariff.

Commission’s analysis

  1. The Commission considers that the applications meet the requirements for the destandardization of tariffed services set out in Telecom Information Bulletin 2010-455-1, and include a description of the services proposed to be destandardized, the proposed effective date, the rationale for the destandardization, and the number of customers affected. In addition, the company has provided notification to customers affected by its applications. Of all TCI’s customers for the affected services, only Distributel and Shaw commented.
  2. With respect to Distributel’s arguments concerning forbearance vs. destandardization, the Commission notes that when services are destandardized, they remain fully regulated and subject to the Commission’s established tariff application processes, which is not the case with services that have been granted forbearance. Additionally, the affected services would still be available to existing customers, with certain limitations. Accordingly, the Commission does not consider that TCI is using destandardization to circumvent forbearance.
  3. With regard to Distributel’s request for a broader review to address concerns about the destandardization and/or forbearance of the affected services, the Commission notes that, even if the affected services were destandardized, they would continue to be regulated; and that any withdrawal of those services would require the Commission’s approval. The Commission further notes that Distributel submitted that its intention was not to suggest that TCI should be required to provide those services indefinitely, and that TCI provided a valid reason to destandardize the services. The Commission is of the view that a broader review of its interconnection framework is not necessary at this time.
  4. With respect to Distributel’s short term concerns regarding the use of the affected services by wholesale customers for the purpose of connecting to co-locations, the Commission considers that the wording that TCI has proposed for the destandardization exemption clause addresses those concerns.
  5. In regards to Distributel’s request that TCI identify or offer substitutes for the affected services, the Commission notes that, although it was not required to do so, TCI provided alternative service options for those who would like to transition their services. TCI also committed to work with customers who are negatively impacted by the destandardization of these services.
  6. With respect to Shaw’s proposed changes to the wording of tariff items 224 and 225 of TCI’s Carrier Access Tariff, the Commission considers that the use of the word “competitor” would be more appropriate than “customer”. However, Shaw’s proposed wording for item 225.3, note 6 used the phrase “between the Customer and the Competitor”, whereas it should be “between the Competitor and the Company”. With this change, the Commission considers Shaw’s proposed wording appropriate.
  7. The Commission acknowledges the validity of TCI’s rationale for destandardizing the affected services, which includes the limitations that aging, manufacturer-discontinued technology poses for the continued offering of those services, the impact that the lack of support and spare equipment would have on the ability for the company to support them, and declining demand.
  8. Furthermore, the Commission notes that responses to requests for information that it issued to a number of companies, including the interveners, on 30 June 2022 demonstrated a decrease in demand for the affected services for the period from 2019 to 2021, and a forecasted decrease in demand for 2022 and 2023.
  9. The Commission therefore considers TCI’s proposal to destandardize the above-noted services as set out in its application to be reasonable.

Conclusion

  1. In light of all of the above, the Commission approves with modifications TCI’s applications TN 567, TN 644 and TN 568. The modified wording is provided in the appendix to this decision.
  2. Specifically, the modifications are:
    • for TNs 567, 644 and 568, the addition of wording proposed by TCI to the destandardization exemption clause; and
    • for TN 568, the replacement of the word “competitor” with the word “customer”.

Policy directions

  1. In accordance with subparagraph 1(b)(i) of the 2006 Policy Direction,Footnote 3 the Commission considers that the approval of these applications will advance the policy objectives set out in paragraphs 7(b) and (f) of the Telecommunications Act.Footnote 4
  2. The 2019 Policy DirectionFootnote 5 states that the Commission should consider how its decisions can promote competition, affordability, consumer interests and innovation. The Commission considers that approval of these applications is compliant with the 2019 Policy Direction. Specifically, approval of these applications will promote consumer interests and innovation, because it will lead to the destandardization of certain legacy services that use manufacturer-discontinued network equipment and are becoming hard to repair and maintain.

Secretary General

Related documents

Appendix to Telecom Order CRTC 2023-26

TELUS Communications Inc. Tariff Notice (TN) 567, TN 644 and TN 568: items and notes approved with modifications in Telecom Order 2023-26

TN 567

Item 500.4.1

DS-0 DNA

Effective February 10, 2023, DS-0 DNA is no longer available for new installations, moves, additions or changes, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 500.4.2

DS-1 DNA

Effective February 10, 2023, DS-1 DNA is no longer available for new customers, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 500.4.2

DS-1 DNA - Continued

Effective February 10, 2023, DS-1 DNA is no longer available for new customers, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 503.1

Service Description

(…)

Effective February 10, 2023, DS-0 IX Channels are no longer available for new installations, moves, additions or changes while DS-1 IX Channels are no longer available for new customers, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 503.3

Note 3: Each DS-0 IX Channel is charged individually per Cross-section until the Maximum is reached per each count of 24 DS-0 IX Channels. Effective February 10, 2023 DS-0 IX Channels are no longer available for new installations, moves, additions or changes, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 503.3

Note 4: Each DS-1 IX Channel is charged individually per Cross-section until the Maximum is reached per each count of 28 DS-1 IX Channels. A DS-1 IX Channel may also be comprised of 24 DS-0s on the same Cross-section. Effective February 10, 2023, DS-1 IX Channels are no longer available for new customers, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Customer and the Company, or for connection between the Customer’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17,

Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

TN 644

Article 5.01.02

Accès au réseau numérique - suite

d. Accès numérique à bas débit

À partir du 10 février 2023, l'accès numérique à bas débit ne sera plus offert pour de nouvelles installations ou pour des changements d'adresses, des déplacements, des modifications de configuration et des ajouts touchant des installations existantes, sauf lorsqu'il est utilisé pour interconnexion en vertu d'une Entente Cadre d'Interconnexion Locale entre le Client et l’Entreprise, ou pour le raccordement entre le point de présence du Client et le réseau de l'Entreprise aux fins d'obtenir l'un des services d'interconnexion de l'Entreprise (services interurbains, locaux, sans fil et de transit) énoncés dans la Décision de Télécom CRTC 2008-17, Annexe, Catégorie (e); ou aux fins de raccordement à un espace de co-implantation d’un central établi conformément aux tarifs de l’Entreprise.

Article 5.01.02

Accès au réseau numérique – suite

e. Accès DS-1 et DS-3

(1) L'accès DS-1 est fourni avec le service suivant :

À partir du 10 février 2023, l'accès DS-1 ne sera plus offert pour de nouveaux abonnés, sauf lorsqu'il est utilisé pour interconnexion en vertu d'une Entente Cadre d'Interconnexion Locale entre le Client et l’Entreprise, ou pour le raccordement entre le point de présence du Client et le réseau de l'Entreprise aux fins d'obtenir l'un des services d'interconnexion de l'Entreprise (services interurbains, locaux, sans fil et de transit) énoncés dans la Décision de Télécom CRTC 2008-17, Annexe, Catégorie (e); ou aux fins de raccordement à un espace de co-implantation d’un central établi conformément aux tarifs de l’Entreprise.

Article 5.01.14

Circuits numériques intercentraux

c. Circuits intercirconscriptions - circonscriptions adjacentes

À partir du 10 février 2023, les circuits DS-0 ne seront plus offert pour de nouvelles installations ou pour des changements d'adresses, des déplacements, des modifications de configuration et des ajouts touchant des installations existantes, et les circuits DS-1 ne seront plus offert pour de nouveaux abonnés, sauf lorsqu'il est utilisé pour interconnexion en vertu d'une Entente Cadre d'Interconnexion Locale entre le Client et l’Entreprise, ou pour le raccordement entre le point de présence du Client et le réseau de l'Entreprise aux fins d'obtenir l'un des services d'interconnexion de l'Entreprise (services interurbains, locaux, sans fil et de transit) énoncés dans la Décision de Télécom CRTC 2008-17, Annexe, Catégorie (e); ou aux fins de raccordement à un espace de co-implantation d’un central établi conformément aux tarifs de l’Entreprise.

Article 5.01.14

Circuits numériques intercentraux – suite

d. Circuits intercirconscriptions - circonscriptions non adjacentes

À partir du 10 février 2023, les circuits DS-0 ne seront plus offert pour de nouvelles installations ou pour des changements d'adresses, des déplacements, des modifications de configuration et des ajouts touchant des installations existantes, et les circuits DS-1 ne seront plus offert pour de nouveaux abonnés, sauf lorsqu'il est utilisé pour interconnexion en vertu d'une Entente Cadre d'Interconnexion Locale entre le Client et l’Entreprise, ou pour le raccordement entre le point de présence du Client et le réseau de l'Entreprise aux fins d'obtenir l'un des services d'interconnexion de l'Entreprise (services interurbains, locaux, sans fil et de transit) énoncés dans la Décision de Télécom CRTC 2008-17, Annexe, Catégorie (e); ou aux fins de raccordement à un espace de co-implantation d’un central établi conformément aux tarifs de l’Entreprise.

TN 568

Item 224.3

Note 3: Effective February 10, 2023, DS-1 Copper CO Link and Other CO Connecting Link are no longer available for new Competitors, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Competitor and the Company, or for connection between the Competitor’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 225.1

Effective February 10, 2023, DS-0 CDN Access is no longer available for new installations, moves, additions or changes; DS-1 CDN Access is no longer available for new Competitors. The destandardization of DS-0 and DS-1 CDN Accesses does not apply when the service is used for interconnection pursuant to a Master Agreement for Local Interconnection between the Competitor and the Company, or for connection between the Competitor and the Company, or for connection between the Competitor’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Item 225.3

Note 5: Effective February 10, 2023, DS-0 CDN Access is no longer available for new installations, moves, additions or changes, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Competitor and the Company, or for connection between the Competitor’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

Note 6: Effective February 10, 2023, DS-1 CDN Access is no longer available for new Competitors, except when used for interconnection pursuant to a Master Agreement for Local Interconnection between the Competitor and the Company, or for connection between the Competitor’s point of presence and the Company’s network for the purposes of obtaining any of the Company’s interconnection services (toll, local, wireless and transiting services) set out in Telecom Decision CRTC 2008-17, Appendix, Category (e); or for the purposes of connecting to a Central Office co-location space established pursuant to the Company's tariffs.

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