|
Telecom Decision CRTC 2004-46
|
|
Ottawa, 14 July 2004 |
|
Trunking arrangements for the interchange of traffic and the point
of interconnection between local exchange carriers
|
|
Reference: 8643-C25-01/99,
8643-C12-07/01
and Bell Canada Tariff Notice 6597 |
|
In this decision, the Commission
modifies the regulatory framework for the interconnection of local
exchange carriers. The Commission finds that consolidation of exchanges
to form larger local interconnection regions (LIRs) would provide for
more efficiency and lower the costs of interconnection. The termination
of traffic that is both interchanged and terminated within the LIR will
be subject to the bill and keep mechanism and, where appropriate, mutual
compensation. Extended area service transport and termination, toll
originating, 9-1-1 and Message Relay Service traffic will remain on
separate trunks. |
|
The Commission modifies the existing
interconnection framework to permit the termination of traffic that is
both interchanged and terminated within the exchange to be subject to
the bill and keep mechanism and, where appropriate, mutual compensation.
The Commission grandfathers all other aspects of the existing
interconnection framework and associated rates. The incumbent local
exchange carriers (ILECs) are directed to file, within 90 days of this
decision, cost studies for interconnection rates for the newly defined
LIRs. |
|
The Commission mandates the provision of
shared cost point of interconnection (POI) diversity when requested by a
competitive local exchange carrier unless an ILEC can demonstrate, to
the Commission's satisfaction, that the POI diversity is not required. |
|
Introduction
|
1. |
The Commission issued Trunking arrangements
for the interchange of traffic and the point of interconnection
between local exchange carriers, Public Notice CRTC 2001-126,
19 December 2001 (Public Notice 2001-126),
announcing a review of the rules for trunking and points of interconnection
(POI). The Commission initiated the review with the stated objective
of determining whether more efficient and effective arrangements could
be found to provide for a more equitable distribution of the costs,
lower the overall costs for interconnection and further the co-carrier
relationship between competitive local exchange carriers (CLECs) and
incumbent local exchange carriers (ILECs) initially set out by
the Commission in Local competition, Telecom Decision CRTC
97-8,
1 May 1997 (Decision 97-8). |
2. |
In Public Notice 2001-126,
the Commission invited comments on and proposals with regard to: revising
the existing rules to allow for fewer POIs for the interexchange of
traffic between local exchange carriers (LECs) and alternate trunking
arrangements that would reduce the number of trunk groups required
for interconnection. The Commission specifically requested parties'
views regarding the desirability and feasibility of combining
on one trunk group all types of originating and terminating traffic
that was exchanged by LECs in the area served by a POI (hereafter
referred to as the local interconnection region, or LIR) and whether
within the LIR all traffic should be exchanged on a bill and
keep basis1 or some other compensation scheme. In addition,
parties were asked to propose a transition mechanism to any new LIR
arrangement and were invited to comment on any other issue that could
improve on the current interconnection regime. |
3. |
On 29 June 2001, Bell Canada filed an
application under Tariff Notice 6597, proposing to introduce a multi-gateway
point of interconnection (MGP) service for CLECs. In Public Notice 2001-126,
the Commission stated that the record associated with Bell Canada
Tariff Notice 6597 was made part of this proceeding. |
4. |
AT&T Canada Corp. (now Allstream Corp.) on
behalf of itself and AT&T Canada Telecom Services Company (collectively,
Allstream), Call-Net Enterprises Inc., on behalf of itself and Call-Net
Technology Services Inc. and Call-Net Communications Inc. (collectively,
Call-Net), Aliant Telecom Inc., Bell Canada, MTS Communications Inc. (MTS)
and Saskatchewan Telecommunications (collectively, the Companies),
EastLink Telephone (EastLink), Futureway Communications Inc. (doing
business as FCI Broadband), GT Group Telecom Services Corp. (CLEC
operations now known as LondonConnect Inc. (LondonConnect)), Microcell
Telecommunications Inc. (Microcell), the Ontario Telecommunications
Association (OTA), TELUS Corporation (TELUS) and Vidéotron Télécom Ltée
(VTL) filed submissions dated 21 February 2002. |
5. |
On 24 May 2002, Allstream, Call-Net, FCI
Broadband, LondonConnect, Mr. François D. Ménard, Microcell, the OTA,
Rogers Wireless Inc. (RWI), TELUS, the Companies and VTL filed comments
on the submissions. |
6. |
On 7 June 2002, Allstream, Call-Net, the
Companies, Mr. François D. Ménard, FCI Broadband, LondonConnect,
Microcell, TELUS and VTL filed reply comments on the submissions. |
7. |
By letter dated 21 October 2002, additional
information was requested from various parties. On 10 January 2003,
Allstream, Call-Net, Cogeco Cable Canada Inc. (Cogeco), FCI Broadband
and the Companies filed supplementary comments relating to the
additional information. |
8. |
In January 2003, Allstream, Call-Net, the
Companies, Microcell, TELUS and VTL filed supplementary reply comments. |
|
Background
|
9. |
In Review of regulatory framework,
Telecom Decision CRTC 94-19,
16 September 1994 (Decision 94-19),
the Commission established a comprehensive regulatory framework for
the Canadian telecommunications industry, consistent with the policy
objectives of the Telecommunications Act (the Act) and the
evolution of the telecommunications environment. The Commission
expected that the new regulatory framework would promote the development
of a telecommunications infrastructure in Canada that offered
an increasing range of competitively provided services to all sectors
of the public. The Commission concluded in Decision 94-19
that the principles of open access, unbundling, co-location and interoperability
among networks had to be promoted to ensure that the right economic
and technical conditions were in place to facilitate entry into the
local wireline market. The Commission subsequently initiated a number
of proceedings to establish the necessary frameworks to give effect
to these conclusions. |
10. |
In Implementation of regulatory framework
– Local number portability and related issues, Telecom Public
Notice CRTC 95-48, 10
November 1995, the Commission established the CRTC Interconnection
Steering Committee (CISC). CISC was initiated to examine issues associated
with number portability. CISC's mandate was subsequently broadened
to assist the Commission in developing information, procedures and
guidelines necessary for various aspects of the Commission's regulatory
activities, including those associated with competitive issues for
the provision of services in the local exchange market. |
11. |
In Decision 97-8,
the Commission established a framework for local exchange competition.
In accordance with the objectives of the Act and the regulatory principles
initially set out in Decision 94-19,
the local competition framework was designed to balance the interests
and needs of consumers, competitors and incumbent telephone companies,
while maintaining universal access to affordable telecommunications
services. |
12. |
The framework for local exchange
competition determined that CLECs were carriers equal in stature to the
ILECs in the local exchange market and encouraged efficient,
technologically neutral interconnection arrangements to the benefit of
all subscribers. |
13. |
The Commission further set out interconnection
rules in Decision 97-8,
including the terms and conditions governing interconnection arrangements
between the networks of ILECs and those of CLECs. Noting in Decision
97-8
that these networks would vary both in architecture and traffic characteristics,
the Commission provided carriers the flexibility to negotiate certain
terms and conditions of the interconnection arrangements between their
respective networks. |
14. |
In Decision 97-8,
the Commission addressed the issue of serving area boundaries for
CLECs. The Commission noted that with respect to the ILECs' existing
serving areas, the local exchange was the basic unit for the administration
and provision of telephone service. The local exchange normally encompassed
a city, town or village and adjacent areas. The Commission concluded
that CLECs should be permitted to establish their own contiguous local
serving areas for the purpose of setting rates for retail services
but that the ILECs' exchanges would be designated as the LIR and maintained
as the elementary unit for the purposes of interconnection. Accordingly,
the Commission determined that each LEC providing service in an exchange
must designate one switch or establish a POI as its gateway for purposes
of interconnecting to each of the other LECs operating in the exchange. |
15. |
In Decision 97-8,
the Commission mandated the equal sharing of the costs of interconnecting
trunks between LECs who were providing service within a LIR (i.e.,
the ILEC exchange). The Commission directed that the bill and keep
approach would be used for traffic that was interchanged between and
terminated within the same exchange over these interconnecting trunks.
The trunks that were equally shared and subject to the bill and keep
approach were known as bill and keep trunks. Additionally, the Commission
concluded that in those instances where it was demonstrated that traffic
between LECs was not balanced for a significant period of time, mutual
compensation would be implemented and the rate should be capped at
the ILEC rate which was mandated at essential services prices. |
16. |
In Decision 97-8,
the Commission directed ILECs to terminate a CLEC's traffic that originated
in an exchange but was to be delivered to ILEC subscribers in
other exchanges that have extended area service (EAS)/extended flat
rate calling with the originating exchange. This service, known as
EAS transport service, was to be provided over a period of five years.
The Commission also directed ILECs to unbundle the functions necessary
to provide a transiting service to CLECs, including CLEC-to-CLEC,
CLEC-to-wireless service provider, CLEC-to-interexchange carrier (IXC)
and common channel signalling no 7 (CCS7) transiting services over
a similar period of five years. Transit traffic was traffic that
an ILEC received from one carrier and switched to another carrier. |
17. |
In Transiting and points of interconnection,
Telecom Order CRTC 98-486,
19 May 1998 (Order 98-486),
the Commission clarified the interconnection rules set out in Decision
97-8.
In Order 98-486, the Commission
addressed the rules related to POIs, trunk group requirements, transiting
rules and CCS7 interconnection. In particular, the Commission stated
that the bill and keep shared cost trunks were for, among other things,
originating and terminating intra-exchange traffic between ILEC and
CLEC subscribers. A separate trunk group to be paid for by the CLEC
was to be used for transit traffic and EAS transport service. Two
separate trunk groups were also required to terminate IXC to CLEC
traffic and to transit CLEC to IXC traffic to an ILEC access
tandem. The costs of these trunks were recovered through the Direct
Connect (DC) and access tandem rates. |
18. |
In Geographical diversity of shared
cost facilities, Order CRTC 2000-164,
1 March 2000 (Order 2000-164),
the Commission found route diversity between a CLEC and an ILEC to
be in the public interest. The Commission was of the view that a balance
should be established between the public interest in constructing
a robust and reliable network and that of constructing efficient interconnection
configurations that do not impose on carriers higher costs than necessary.
The Commission, however, concluded that quality of service was highly
important for competition and that it was important for networks to
function with as few outages as possible. Accordingly, the Commission
directed that geographically diverse facilities between an ILEC and
a CLEC be provisioned on a shared cost basis when requested by the
CLEC unless the ILEC could demonstrate to the Commission's satisfaction
that it was not required. |
19. |
On 8 and 9 June 2000, the Commission
convened an industry workshop (the workshop) to solicit views on
interconnection issues that needed to be addressed in order to
facilitate local competition. |
20. |
On 27 October 2000, Commission staff
established a new CISC Network of Networks ad hoc working group (NNAWG)
to investigate alternatives to: the exchange and transiting of traffic
between ILECs, CLECs and IXCs; establishing POIs for the interchange of
local traffic; and the interconnection for the exchange of CCS7
signalling. |
21. |
On 7 December 2000, Commission staff issued
a report summarizing the status of the various issues raised during the
workshop. |
22. |
In Local competition: Sunset clause
for near-essential facilities, Order CRTC
2001-184, 1 March 2001 (Order
2001-184), the Commission extended the sunset period for near-essential
facilities, without specifying a termination date, until such time
as the market for such facilities is sufficiently competitive. |
23. |
On 30 April 2001, the NNAWG issued a report
summarizing the results of its activities and consultations to that
point, concluding that it was unable to arrive at any consensus on the
specific interconnection issues it was mandated to address. |
24. |
As a result of the industry being unable
to reach a consensus, the Commission issued Public Notice 2001-126. |
25. |
The record of this proceeding raised the
following issues: |
|
|
|
- trunking efficiencies and traffic consolidation;
|
|
|
|
- other issues including, separation of Internet service provider
(ISP) traffic, indirect interconnection, Bell Canada's MGP service,
9-1-1 route diverse connections and CCS7 A-link interconnection.
|
|
Review of LIRs
|
26. |
The Commission has grouped the parties'
submissions on LIRs into three categories: interconnection at the call
termination bottleneck (CTB); status quo; and expansion of LIRs.
Interconnection at the CTB requires that the LIR be defined based on
where the last technically feasible interconnection point in the network
occurs. The status quo represents the existing interconnections rules.
The last category, expansion of LIRs, captures all proposals that argued
for a larger geographic LIR resulting in fewer POIs than required to
date. |
|
SIZE="3">
Position of parties
|
|
SIZE="3">
Interconnection at the CTB
|
27. |
TELUS proposed that interconnection be
required at the CTB. Specifically, TELUS proposed that each carrier be
required to deliver its traffic originating on its network, or make
arrangements for its delivery, to the CTB of the customer for whom the
traffic was destined. With the CTB typically being located at the
end-office switch serving the customer for whom the traffic was
destined, the LIR would be defined as the area served by each of the
ILEC's end-office switches. |
28. |
TELUS submitted that interconnection at the
CTB would allow market forces to: determine interconnection arrangements
beyond the established arrangements; reduce costs and enhance efficiency
by providing carriers with the flexibility to develop custom-made
interconnection arrangements; promote efficiency by enabling the CLECs
to decrease their reliance on the ILECs' networks; clarify the
relationship between carriers; and strengthen the co-carrier
relationship. TELUS further submitted that traffic termination at the
CTB would enhance network reliability by reducing the risk that the
failure of a single network element could disable the entire network. |
29. |
All of the CLECs opposed TELUS's proposal.
Some argued that it would be a retrograde step from that which exists
today, while others argued that it would significantly increase the
costs of interconnection and would exacerbate the competitive inequities
faced by new entrants. It was further noted that the proposal was based
on the existing legacy network architecture of the ILECs and that the
ILECs themselves have been decommissioning end-offices which, based on
TELUS's proposal, would leave CLECs with stranded investment. |
30. |
The CLECs were generally of the view that a
LIR based on TELUS's proposed CTB only benefited the ILECs and would
severely damage the emergence of facilities-based competition in Canada.
They argued that TELUS's proposal failed to meet the stated goals set
out by the Commission for this proceeding, and would impose an
inordinate burden on the CLECs without providing any of the efficiency
and equity benefits that were being sought by the Commission. |
31. |
Call-Net submitted that in some
theoretically perfect world, the interconnection rules proposed by TELUS
would be appropriate. Call-Net submitted however that a new competitor
wishing to provide ubiquitous coverage would have the responsibility to
connect to the 960 wire centres in TELUS territory and to the 2,338 wire
centres in the Companies territory. Call-Net stated that the ILECs would
likely only have to connect to a few dozen locations to meet their
interconnection requirements given that CLECs deploy switches in fewer
locations to cover a broader base of customers. Call-Net argued that
this enormously asymmetric burden dramatically underscores
the impracticality of the TELUS proposal. |
|
SIZE="3">
Status quo
|
32. |
The Companies supported maintaining the existing
exchange-based interconnection regime. They considered that the current
interconnection arrangement on an exchange basis was an efficient
interconnection model and there was no reason to depart from the status
quo. They further considered that the objectives and framework for
local competition established by the Commission in Decision 97-8
remained fundamentally correct and should continue to apply to LIRs.
The Companies submitted that if the CLECs were to construct a local
network today, the resulting network architecture would be substantially
the same as their existing network architecture. |
33. |
The Companies noted that existing CLECs had
already established extensive transport facilities to, and between, the
ILECs' wire centres in all exchanges in which they provide service. The
Companies noted that the CLECs had requested and the Commission allows
CLECs to use their co-location space in an ILEC wire centre for the
purpose of establishing a POI. Noting that a number of CLEC co-locations
in ILEC central offices already exist, the Companies submitted that it
would be most efficient for the CLECs to designate these points as POIs. |
34. |
VTL supported maintaining the ILEC exchange
for purposes of establishing POIs. VTL argued that reducing the number
of POIs would increase CLEC dependence on the ILECs' networks and
would favour CLECs that have deployed the least network. VTL indicated
that it had made substantial investment in its network on the basis
of the interconnection rules set out by the Commission in Decision
97-8
and submitted that any changes to the existing network architecture
would make it difficult for it to recoup those costs. VTL argued that
a reduction in POIs would be prejudicial to it and other CLECs who
have already made substantial investments to implement a network that
conforms to the existing architecture. |
35. |
LondonConnect submitted that if the
interconnection regime failed to promote facilities-based competition or
constrained the network architecture of new CLECs to mimic the legacy
network architecture of the ILECs, the quality, functionality and
capacity of entrants' services would be limited by the corresponding
characteristics of the ILEC's network. |
36. |
LondonConnect stated that the current ILEC
local network architecture was developed as a function of older legacy
technology which required numerous exchanges, some of which served vast
areas, while others served small areas, normally with a single switch in
each wire centre. Modern technology, allows a smaller number of host
switches to provide service to numerous exchanges or wire centres by use
of remotes. |
37. |
LondonConnect noted that data provided by
the Companies and TELUS indicated that the number of ILEC host switches
have decreased while the number of exchanges served by a host switch
have increased. LondonConnect submitted that this evolution supported
moving away from an LIR defined by ILEC legacy network architecture. |
38. |
Call-Net stated that although one POI per
exchange was generally reasonable in large urban areas, in smaller
centres it was detrimental to competition because it was too expensive.
Call-Net submitted that establishing a POI in each ILEC exchange,
regardless of subscriber density and traffic levels results in a less
efficient network architecture because of the large number of POIs
required and the small trunk groups that result. |
39. |
Microcell stated that the choice of the
ILEC exchange as the basis for the LIR had some advantages because the
network architecture was a feature common to all ILECs. Microcell stated
that there were also disadvantages with the existing interconnection
rules because it forced CLECs to build more POIs than the traffic levels
would support and created distortions due to the fact that exchanges
varied so much in size and density. |
40. |
Cogeco argued that the current
interconnection regime was unnecessarily tied to the ILEC network
architecture and technology and that it was neither competitively nor
technologically neutral. Cogeco further argued that the status quo
imposed unjustifiably high costs not only on CLECs but on the industry
as a whole. |
|
SIZE="3">
Consolidating ILEC exchanges
|
41. |
Several parties proposed various criteria
that would lead to a consolidation of ILEC exchanges for purposes of
defining a LIR. |
42. |
Allstream recommended that exchanges should
be consolidated for purposes of defining a LIR on the basis of the ILECs
local calling areas (LCA). Allstream's proposed LIR definition would
encompass all exchanges in which traffic from the originating exchange
can be terminated without incurring long distance charges, including
exchanges, which have EAS with the originating exchange. |
43. |
Allstream submitted that LIRs defined on
the basis of the existing ILEC LCA, as opposed to the ILEC exchanges,
would promote technical and competitive neutrality, maximum efficiency,
and commercial compatibility since both the ILECs and the public have
played an important role in determining the areas in which local calling
occurs. Allstream stated that ILECs are increasingly relying on a
network architecture where many wire centres and exchanges are served
from one host switch, similar to the networks employed by CLECs.
Allstream submitted that in these circumstances there was no difference
between the transport services that ILECs provide to CLECs and vice
versa. Allstream stated that the LCAs, and thus LIRs, should continue to
evolve over time to respond to the changes in community calling
patterns, market and technological developments. |
44. |
Allstream noted that redefining the LIR
beyond the ILEC local exchanges would result in cost changes for CLECs
and ILECs, but submitted that these changes would be symmetrical since
each LEC would be offering the other a similar EAS terminating service.
Allstream estimated that the decreased need for EAS transport and local
transiting would result in $5.8M in savings per year at current traffic
levels, and $14.4M per year when 5% of the market share is held by the
CLECs. |
45. |
Cogeco supported the LCA concept proposed
by Allstream. Cogeco submitted that true co-carrier interconnection did
not require CLECs to interconnect as if they are ILECs and that
differences in their respective use of the technology, network design
and size should be recognized. |
46. |
Call-Net and Microcell supported expanding
the LIR by grouping a number of exchanges. Call-Net considered that
using a larger LIR would increase the efficiency of the network
architecture and lower the costs for all parties regardless of
technology used. Microcell argued that mandating one POI per LCA would
strengthen the CLECs bargaining power in cases where other mutually
satisfactory local interconnection arrangements between LECs might be
reached. Microcell further argued that using the LCA approach would
allow CLECs to achieve trunking efficiencies and lower rollout costs,
which would facilitate the rollout of competitive networks beyond the
main urban areas. |
47. |
FCI Broadband proposed in major
metropolitan areas such as Toronto, Ottawa and Hamilton, that the
Commission designate a core exchange in which CLECs must establish a POI
with the ILEC. This core exchange2 would serve as the
location in which traffic from a larger number of exchanges could then
be exchanged between the ILEC and the CLEC and between CLECs. FCI Broadband
submitted that the ILECs' facilities required to implement the proposed
interconnection arrangement were already in place, and that the ILECs
would incur little additional cost to accommodate the additional traffic
received from CLECs. |
48. |
LondonConnect proposed that the LIR be
established on the basis of an equitable geographic area defined as the
smaller of the provincial boundary or the smallest serving area of
either interconnecting LEC. LondonConnect submitted that CLECs should
not have to deploy their POIs based on legacy technology and supported
grouping smaller exchanges where numbers warrant, allowing
interconnection at network gateways. LondonConnect noted that
Mississauga, Ontario has five separate exchanges and would be a
candidate for this type of grouping, given that Toronto, which is four
times the size of Mississauga, is served by a single exchange. |
49. |
The Companies argued that the grouping of
exchanges based on the LCA or some other similar proposal was based on
an erroneous view that a larger LIR would be more efficient, more
accurately reflect future network architecture and would not create
additional costs to ILECs. The Companies provided estimates of
additional costs of implementing the LCA proposal which ranged from tens
of millions of dollars for a company the size of Bell Canada to tens of
thousands of dollars for MTS. The Companies argued that a transfer of
costs from the CLECs to the ILECs would not increase efficiency. |
50. |
TELUS opposed the mandating of one POI for
a particular region, regardless of how that region was defined. TELUS
argued that using a LCA was arbitrary and not founded on any economic or
regulatory principles. |
51. |
TELUS submitted that to the extent that a
geographical area was to serve as the basis for the resolution of any
regulatory issue (for LCAs or otherwise), the boundary of the area must
be unambiguous, easily determinable, stable over time, free of gaps and
overlaps, and independent of any carrier's service offerings, including
those of the ILEC. TELUS argued that none of the entrants' proposals
offered such a clear, discrete and usable areas, and therefore, much
work would remain to be done before the Commission could move beyond the
exchange as the basic unit of interconnection. |
52. |
VTL submitted that giving any consideration
to enlarging the LIR would necessitate the adoption of equitable
transition measures to minimize any negative economic impact with
respect to those CLECs, like VTL, that have invested substantial capital
to build a network based on existing rules. VTL suggested that should
the interconnection regime be changed to enlarge the LIRs it would
support the metropolitan core exchange being designated as the centre,
or hub, of a region whose minimum size would be the ILEC's LCA. |
53. |
Both Allstream and Microcell stated that a
change to the existing interconnection regime should not require the
removal of any existing POIs which could result in stranded investment.
Allstream, however, did suggest that there could be benefits to both
CLECs and ILECs if some existing POIs were to be decommissioned.
Microcell stated that CRTC decisions were, with limited explicit
exceptions, prospective in nature such that any changes to the LIR would
affect new CLECs and existing CLECs as they enter new markets. Microcell
submitted that the Commission should consider making an explicit
statement that existing arrangements would not be affected by this
ruling. Microcell stated that this would reassure VTL and perhaps other
LECs which have arrived at satisfactory bilateral arrangements through
negotiations. |
|
SIZE="3">
Commission analysis and determination
|
54. |
The Commission's intent in Decision 97-8
was to implement a technologically neutral framework that encouraged
efficient interconnection arrangements for the benefit of all LECs
and their subscribers. In Decision 97-8,
the Commission determined that the ILEC local exchanges were the appropriate
minimum boundaries to be mandated for purposes of establishing interconnection
between LECs. An objective of the proceeding initiated by Public Notice
2001-126 was to determine
whether a more efficient and effective interconnection arrangement
could be achieved with fewer POIs which would result in larger mandated
minimum LIRs. |
55. |
Since the issuance of Decision 97-8,
several significant changes have taken place with respect to the existing
regulatory framework, technology, as well as the marketplace. |
56. |
A primary reason for determining the ILEC
exchange boundary as the elementary unit for the purposes of
interconnection was to maintain the integrity of the toll contribution
system. The Commission found that permitting a CLEC to define serving
areas that encompass more than one ILEC exchange, without making
provision for toll contribution for CLEC calls that cross an ILEC's
exchange boundary, would result in CLEC calls avoiding contribution. |
57. |
In Changes to the contribution regime,
Decision CRTC 2000-745,
30 November 2000 (Decision 2000-745),
a new contribution regime was established on the basis of annual telecommunications
service revenues of all telecommunications service providers, as opposed
to the previous regime that was based on long distance minutes.
Consequently, the distinction between local minutes and long distance
minutes, and the local exchange boundary as the basis to distinguish
the two types of traffic, was no longer relevant for contribution
purposes. |
58. |
The Commission notes that as LECs build new
networks or redesign existing networks, these networks will not
necessarily be based on the existing circuit-based network architecture.
Advances in technologies related to the carriage of traffic have, among
other things, reduced the costs of backhauling traffic. As noted by
parties, as a result of these cost reductions the ILECs have
decommissioned switches and the new entrants have used substantially
different network architectures which all require fewer switches to
cover a broader geographic area than that of the ILEC legacy networks.
The Commission also notes that some of the new entrants entering the
local market are not dependent on the ILECs unbundled loops and
co-location for purposes of offering local service to customers. |
59. |
The Commission considers that in reviewing
the interconnection rules, it must not only continue to balance the
interests of ILECs and established CLECs but consider if more efficient
and effective arrangements can be found to facilitate new technologies
that will be rolled out by both new entrants and established LECs.
Overall, the Commission must take into account the interests of all
parties and balance their needs to ensure the interconnection regime is
one that is in the public interest and best serves the customer now and
in the foreseeable future. |
60. |
With regard to the appropriate size of the
LIRs, the Commission notes that submissions ranged from the TELUS CTB
proposal that would decrease the size of the LIRs relative to that
currently mandated; through maintaining the status quo, as proposed by
the Companies; to substantially increasing the size of the LIRs, as
proposed by some of the CLECs. |
61. |
TELUS submitted that, in support of its CTB
proposal, the Commission should rely on market forces to dictate the
interconnection regime. |
62. |
While subsection 7(f) of the Act calls
upon the Commission to foster increased reliance on market forces
for the provision of telecommunications services, the Commission considers
that the dominance maintained by the incumbents in the supply of near-essential
facilities precludes it from relying entirely on market forces to
establish an efficient and effective interconnection regime at this
time. The Commission notes in this regard that in Order
2001-184, it extended the sunset period for near-essential services
because it determined that the market for such facilities was not
sufficiently competitive. |
63. |
The Commission notes under TELUS's CTB
proposal, the size of the LIR would be substantially reduced and CLECs
would be required to deploy hundreds of additional POIs in order to
mirror the ILEC network architecture. The Commission considers that
connection at the CTB would generally result in extremely underutilized
trunking arrangements for all LECs. Furthermore, it would require
significant capital investment by the CLECs in new trunks or the use of
ILEC trunks and result in an even higher likelihood of stranded
investment for a CLEC should the trend of the ILECs to decommission
end-offices in favour of hubs continue. |
64. |
The Commission finds that the CTB proposal
would increase the overall costs of interconnection for all LECs and
would place an inordinate burden on CLECs. The Commission finds further
that the CTB proposal is not a suitable interconnection regime as it is
neither fair nor cost effective for LECs. The CTB proposal would
ultimately be detrimental to LEC customers who would pay more for
services as the higher interconnection costs would be recovered in the
prices of the services that they obtain. |
65. |
With regard to maintaining the status quo,
as proposed by the Companies and VTL, the Commission is of the view that
current exchange-level LIRs represent a high capital cost for existing
CLECs wishing to expand their geographic coverage and for new service
providers wishing to enter the market. Once established, exchange-level
interconnection facilities are often underutilized or are of a scale
that is not operationally or economically efficient, particularly for
small CLECs. Reductions in the costs and increases in the capacity of
transport networks over the last decade suggest that larger LIRs may be
appropriate. |
66. |
The Commission disagrees with the premise
that if CLECs were to construct a local network today, the resulting
network architecture would be substantially the same as the ILECs. The
evidence provided in this proceeding indicates that the ILECs are moving
away from the legacy network architecture of a switch per wire centre to
one in which a number of exchanges are served by one host switch. The
Commission also notes that this premise fails to take into account those
new CLECs whose network architecture and choice of technology do not
imitate the ILEC circuit-switch architecture. |
67. |
The Commission notes that technological improvements
have greatly reduced the transmission costs of carrying traffic. As
a result, the costs of backhauling of traffic, which would increase
with an expanded LIR, are now less than those that would have been
considered during the proceeding leading to Decision 97-8.
This is supported by the fact that both the size of end-office switches
as well as the LCAs of the ILECs continue to expand. Further, the
Commission notes that not all CLECs are dependent on ILEC co-location
and unbundled loops and, therefore, interconnection at the ILECs central
office is not necessarily the most efficient location for a CLEC POI. |
68. |
The Commission considers that, as a combination
of the introduction of the new contribution regime, the cost
reductions in the transmission costs of carrying traffic, and the
introduction of next generation networks by both the incumbent
carriers and new entrants, the Companies' proposal to retain
exchange-based LIRs does not meet the objective set out in Public
Notice 2001-126. In
particular, the status quo fails to improve the overall efficiency
of interconnection arrangements. |
69. |
The Commission finds that consolidation of
exchanges to form larger LIRs, would generally provide for more
efficiency, lower the overall costs of interconnection and further the
co-carrier relationship between CLECs and ILECs. Consolidating some
exchanges would alleviate the problem of underutilized trunks that are
generally found in less dense exchanges. |
70. |
The Commission notes that those parties who
argued for the consolidation of exchanges not only recommended
consolidation of lower, less dense exchanges, but also recommended
consolidating large exchanges with many of the smaller exchanges. For
example, under Allstream's proposal Toronto which is a large exchange
with very high subscriber density would be consolidated with 36
surrounding exchanges. FCI Broadband's proposal recommended
consolidating the Toronto exchange with 22 other exchanges. The
Commission considers that larger LIRs would generally be more efficient
for all carriers. The Commission, however, considers that the
consolidation of exchanges as proposed in this proceeding would result
in exchanges that are so large that they would force inefficient
transport of local traffic over very large distances or significantly
reduce the robustness of interconnection arrangements and result in
increased economic risks of outages. The Commission, therefore, finds it
appropriate to establish LIRs that are larger than the ILEC exchanges,
but smaller than the various proposed exchange consolidations. |
71. |
The Commission recognizes that by
consolidating some exchanges into larger LIRs there will be some
additional costs imposed on ILECs. However, the Commission considers
that these will not be significant as long as the LIRs are kept within a
reasonable geographic size and density. The Commission is of the view
that while ILEC costs will increase due to the requirement to backhaul
traffic over longer distances, these will be somewhat alleviated by the
cost savings that ILECs will realize by having fewer interconnection
points. The Commission notes also that the ILECs have extensive EAS
trunking arrangements in place for many of the areas that will be
consolidated, which should mitigate additional costs of backhauling. At
the same time, since larger LIRs will increase the costs of terminating
traffic, the Commission considers it appropriate to allow the ILECs to
file revised interconnection rates that take into account the larger
LIRs. |
|
SIZE="3">
Defining the LIRs
|
72. |
In determining which exchanges to
consolidate for purposes of establishing LIRs, the Commission has
decided to broadly align the LIRs to boundaries reflecting a community
of interest. The Commission considers that the most neutral and
appropriate template for determining community of interest is the
existing provincially defined administrative regions. The Commission
notes that these boundaries are not reliant on any network architecture
and are therefore competitively neutral. These boundaries are well
specified, readily identifiable, and are associated with economic,
social and political interests. They also allow the consolidation of
exchanges into LIRs without creating too large an interconnection
region. The Commission, therefore, finds it appropriate to consolidate
exchanges for the purposes of interconnection on the basis of
provincially defined administrative regions. |
73. |
In light of the above, the Commission sets
out the following rules for ILECs to follow in defining LIRs: |
|
- LIRs are to be established using provincially defined
administrative regions, such as municipalities, counties, regional
districts, etc.;
|
|
- the entire serving territory of Northwestel Inc. and the entire
serving territory of small ILECs, those where local competition is not
yet permitted will be excluded from the LIRs;
|
|
- in cases where an exchange is served by a remote switch, the
exchange will be included in the LIR of the exchange of the host
switch; and
|
|
- the civic address of the largest wire centre, based on network
access service (NAS), in each exchange will determine in which LIR the
ILEC exchange belongs.
|
74. |
Using provincially defined administrative
regions, the Commission has defined 337 LIRs nationally. These LIRs are
provided in the Appendix to this decision. Where a CLEC is currently
operating within a newly defined LIR, the corresponding ILEC is directed
to designate a POI within 90 days of this decision. |
75. |
In respect of existing POI arrangements,
since the cost to remove and redeploy POIs may be more expensive than
retaining them and may be particularly burdensome for CLECs, the
Commission considers that the existing POIs should remain in place until
such time as a CLEC wishes to alter them. |
76. |
The Commission considers further that
parties should not be precluded from entering into other arrangements
than those set out in this decision where they consider it to be to
their mutual advantage. In particular, the Commission generally
considers consolidation of exchanges for the purpose of interconnection
to be appropriate, and will accordingly be inclined to approve requests
by parties for the expansion of the LIR boundaries established in this
decision. |
|
Trunking efficiencies and traffic consolidation
|
|
SIZE="3">
Position of parties
|
|
SIZE="3">
Traffic consolidation
|
77. |
The Companies submitted that the current
interconnection rules reflected the principle of equality of status for
LECs and toll interconnection rules reflected the principle that IXCs
must compensate LECs for the cost of providing access to the public
switched telephone network (PSTN). The Companies argued that there was
no support provided for changes to these principles. |
78. |
The Companies noted that there were
separate measurement and/or rating requirements for toll terminating,
transiting and EAS transport service. They argued that these services
could not be consolidated with other traffic types on a single trunk
group. The Companies argued that proposals to consolidate local and toll
terminating traffic were not appropriate because they conflicted with
toll access arrangements and shifted to the ILEC the responsibility and
cost of transporting traffic within the exchange and the LCA. |
79. |
The Companies argued that it would be
inappropriate for an ILEC to provide transport services from the POI to
the access tandem under a charge that combined both the access tandem
rate and the mutual compensation maximum imbalance rate because it would
not account for all cost elements and therefore shifted costs to the
ILEC. The Companies noted that the mutual compensation rate had been
developed on the basis of costs within the exchange whereas the access
tandem rate did not include costs for termination to end-office switches
that are not homed onto the access tandem. |
80. |
The Companies submitted that where it was
technically possible to combine traffic on one trunk, the rates for
local and toll interconnection tariffs would have to be reviewed and if
traffic were to combine on one trunk, the practice of allowing CLECs to
adopt ILEC rates would have to be examined because of differences in
capabilities. |
81. |
VTL opposed the proposal to allow LECs to
combine toll terminating traffic on bill and keep trunk groups,
arguing that it would impose a peer-to-peer model to the IXC-LEC interconnection
framework. VTL submitted that such an important modification cannot
be undertaken without an overall review of the IXC-LEC interconnection
framework and compensation model contained in Competition in the
provision of public long distance voice telephone services and
related resale and sharing issues, Telecom Decision CRTC 92-12,
12 June 1992. |
82. |
Microcell submitted that in Order 98-486,
the Commission added a qualification not initially contained in Decision
97-8,
that the type of traffic that LECs were entitled to route over bill
and keep trunks was "traffic between a pair of LECs that originates
and terminates in the exchange (local traffic) in which the LECs are
directly interconnected." Microcell asserted that this partitioning
of traffic was required to identify contribution-eligible toll traffic.
Microcell argued that there was no longer a need for this segregation
now that the contribution regime had been changed. Call-Net also supported
this view. |
83. |
Microcell objected to the Companies' view
that toll terminating, transiting and EAS transport services prevent
consolidation due to measurement and/or rating requirements. Microcell
argued that ILEC-to-CLEC and CLEC-to-ILEC toll terminating traffic could
be combined with local traffic and be subject to the normal local
compensation regime of mutual compensation in the form of bill and keep
arrangements, supplemented with imbalance charges as necessary. |
84. |
Allstream proposed that existing mutual
compensation rates could continue to be used on an interim basis and
adjusted in a subsequent proceeding. Allstream submitted that
interconnection rates should be based on the cost of interconnection and
should not include the cost of switching and aggregation within the
LEC's LCA as is currently the case with the existing rate structures. |
85. |
Call-Net argued that all terminating
traffic should be treated equally, independently of its point
of origination, because in an area served by a POI, the termination cost
of a minute of traffic is independent of its point of origination.
LondonConnect supported this position. LondonConnect further submitted
that the restricted definition of the type of traffic that may be
exchanged over bill and keep trunks created practical difficulties.
LondonConnect stated that a CLEC that had an LCA that exceeded the
boundaries of the ILEC exchange had to negotiate an arrangement with
the ILEC to terminate this traffic in the LCA terminating exchange or
failing this, pay ILEC toll termination rates for what the CLEC has
defined as local traffic. |
86. |
LondonConnect stated that any changes to
the existing regime must maintain the existing mandated requirement that
the ILECs perform transiting and EAS transport. However, if the ILEC is
compensated on a cost basis, LondonConnect considered that transiting
and EAS transport could also be combined on bill and keep trunks. |
87. |
Cogeco did not support using the mutual
compensation imbalance rate for the tandeming and transport of traffic
within an LCA. Cogeco argued that this traffic should be terminated by
the ILEC without charge to the CLECs since Bell Canada does not require
compensation from independent telephone companies for tandeming and
transport with an LCA. Cogeco argued that Bell Canada would be unjustly
discriminating against CLECs, and this would be in contravention to
subsection 27(2) of the Act. |
88. |
TELUS submitted that traffic exchanged on a
bill and keep basis occurred between parties that were providing each
other with comparable transport services, within the same geographical
area, and incurred comparable costs to do so. TELUS stated that
Allstream's compensation approach was not applicable to EAS transport,
local transit, EAS transit, toll transit, toll trunking and access
tandem services because these services were provided by the ILEC to the
CLEC or the IXC and these parties were not providing similar services to
the ILEC. TELUS stated therefore that Allstream's proposal that such
services be provided over bill and keep trunks was an attempt to shift
costs to the party providing the service, and the suggestion that the
cost of facilities over which one party provides service to another
(without receiving the same service in return) should be shared was
illogical. |
|
SIZE="3">
Toll originating traffic
|
89. |
The Companies stated that technical
limitations of equal access capability prevented the consolidation of
toll originating traffic on local interconnection trunks because toll
traffic from LECs to IXCs could not go through an intermediate local
end-office switch. Microcell, Allstream, LondonConnect and TELUS agreed
with the Companies and indicated that due to technical reasons there was
a need to have separate trunk groups for toll origination traffic. TELUS
further added that it is impossible to send toll traffic on TR/GR 317
trunks between a CLEC and an ILEC. |
90. |
Call-Net stated that it recognized that
additional functionality existed for a toll call that originated on a
direct end-office connection versus a local call (i.e., toll carrier
pre-selection), however, because the cost of this functionality had been
funded through a start-up cost recovery mechanism, the cost for both
originating and terminating were now the same. |
|
SIZE="3">
9-1-1 and Message Relay Service
|
91. |
The Companies noted that the signalling for
9-1-1 and Message Relay Service (MRS) traffic did not use CCS7 and the
9-1-1 traffic had to be delivered to a 9-1-1 tandem switch. These
particular services could not be consolidated with other trunk groups. |
92. |
Microcell, Allstream, LondonConnect and
TELUS supported the Companies' view. |
|
SIZE="3">
Commission analysis and determination
|
93. |
The Commission is of the view that, even
without further changes to the existing trunking arrangements, the
introduction of new larger LIRs will improve the trunking efficiency of
interconnecting LECs. The ability to combine interconnection facilities
previously required to serve individual exchanges into facilities
servicing a single POI for a larger LIR will reduce the total number of
trunks required while improving the trunk groups' performance. |
|
SIZE="3">
Terminating traffic within the LIR
|
94. |
The Commission notes that some new LIRs
will encompass several ILEC exchanges and the termination of traffic
that originates within the LIR will continue to be interchanged on a
shared-cost basis between the LECs. |
95. |
The Commission notes that some parties have
argued that a call that originates outside the LIR should also be
allowed on shared cost trunks, so long as the call is to be terminated
in the LIR. |
96. |
Calls that originate in one LIR for
termination in another LIR would consist of inter-LIR EAS calls or
inter-LIR toll calls. The Commission considers that the question to be
addressed is should a LEC that either carries these calls from their
point of origination to its POI in the terminating LIR be allowed to
place these calls on shared-cost facilities. |
97. |
If a LEC operates in the LIR where a call
originates and in the LIR where the call terminates, the LEC would carry
the call to its POI in the terminating LIR where it would be sent to the
LEC of the terminating customer for termination within the LIR. |
98. |
The Commission finds that termination costs
for all types of calls within the LIR are the same, irrespective of
where the call may have originated. So long as a call is carried up to
the POI in the terminating LIR, the call is exactly the same as an
intra-LIR call being terminated in the LIR. Accordingly, the Commission
finds it reasonable that these calls be routed on the shared-cost trunks
for termination in the LIR. |
|
SIZE="3">
Compensation for shared-cost traffic
|
99. |
The Commission notes that, in Decision
97-8,
it considered mutual compensation at cost-based rates to be generally
more equitable than the bill and keep approach because traffic volumes
could be unbalanced between the LECs. However, given the administrative
burden of mutual compensation, the Commission mandated the bill and
keep approach except in those instances where it was demonstrated
that traffic between LECs was not balanced for a significant period
of time, in which case mutual compensation was implemented. The Commission
notes that no party to the proceeding proposed changes to this rating
mechanism. The Commission directs the ILECs to develop the appropriate
mutual compensation rates that reflect the newly defined LIRs, and
that CLECs mutual compensation rates shall be capped at the ILEC rate. |
|
SIZE="3">
Terminating traffic outside the LIR
|
100. |
The Commission notes that while many
exchanges having EAS with one another will form new LIRs, some exchanges
having EAS with one another will be assigned to different LIRs. The
Commission notes that there will also likely be instances where a CLEC
is operating in one of the LIRs, but not the other. In order for a call
that originates in the LIR where the CLEC is operating to be terminated
in the LIR where the CLEC is not operating, the CLEC would require an
EAS transport and termination service from the ILEC. The Commission
finds that, in this case, it would not be fair or reasonable to have an
ILEC carry this traffic to the terminating LIR without receiving
compensation. Unlike the termination costs within the LIR, where on
balance it is reasonable to have shared cost arrangements because of the
overall efficiency gains and lower costs of termination, the Commission
considers that extending the provision of transport and termination
service beyond the LIR boundaries would place an undue burden on the
ILECs vis-à-vis the CLECs. The costs of providing such a service could
become significant for the ILECs and it would not be reasonable to have
ILECs transport calls beyond what has been determined to be reasonable
geographic areas. The Commission considers that charging for such a
service, which would include the appropriate trunk costs, would also
provide further encouragement to CLECs to deploy facilities.
Accordingly, the Commission finds that EAS transport and termination
service (i.e., the carrying and termination of calls beyond the LIR
boundary by one carrier for another) must be kept on separate trunks to
allow the ILEC the ability to track and charge for the service. |
101. |
The Commission further notes that if as a
result of the newly defined LIRs, the costs of EAS transport and termination
change from that established as a result of Decision 97-8,
the ILECs may file new cost studies for this service. |
102. |
The Commission also considers it reasonable
for LECs to charge for any toll calls that they carry and terminate
outside the LIR. The Commission finds that the LECs can continue to
charge the access tandem rate combined with the DC rate for these
purposes. The ILECs may file new cost studies for these services should
they find the costs have changed as a result of the newly defined LIRs. |
|
SIZE="3">
Transit services provided by ILECs
|
103. |
In respect of transit services including
local, toll and EAS, the Commission continues to be of the view that
these services should be kept on separate trunks. Consistent with
its determination in Order 98-486,
the Commission finds that, given that the CLEC avoids the trunking
between itself and another carrier by having ILECs offer transit services,
the CLEC should be responsible for the trunking costs needed to acquire
these services. |
104. |
As in the case of EAS transport and toll
termination services, should the ILECs determine that the costs of
transiting have changed due to the newly defined LIRs, the ILECs may
file new cost studies for transit services provided within the LIR. |
|
SIZE="3">
Toll originating traffic
|
105. |
The majority of parties agreed that toll
originating traffic should continue to be kept on separate trunks. The
Companies and TELUS cited technical restrictions as one of the major
reasons for keeping these separated. |
106. |
In the Commission's view, the technical
limitations as identified by the parties support the need to keep toll
originating traffic separate. The Commission therefore considers it
appropriate that these trunks remain separate and that the IXC continue
to pay for the cost of the trunks through the DC rate. |
|
SIZE="3">
9-1-1 and MRS
|
107. |
The Commission notes that the Companies
provided evidence demonstrating that the 9-1-1 and MRS traffic must
continue to remain on separate trunks. The Commission also notes that
other parties supported this view. The Commission considers it
appropriate that the 9-1-1 and MRS traffic will remain on separate
trunks. |
|
SIZE="3">
Transition from existing regime and associated tariff filings
|
108. |
As there may be cases where existing
interconnection arrangements on an exchange basis remain in effect, the
Commission considers it necessary for the current bill and keep approach
and mutual compensation rates also remain in effect, to be applied in
cases where these arrangements continue to be in place. Similarly, the
Commission considers it necessary to retain the current EAS transport
and transiting service rates for this purpose. However, the Commission
considers it appropriate to modify the existing interconnection
arrangements to permit the termination of all traffic interchanged and
terminated in the same exchange over the existing bill and keep trunks
pursuant to the existing bill and keep approach and, where appropriate,
the existing rates for mutual compensation. |
109. |
The Commission notes that this decision
does not modify the assignment of numbering resources, the dialing plan
and provision of service to subscribers. Also, local number portability
continues to provide service provider portability on an exchange basis. |
110. |
To give effect to the new regime, the
Commission directs the ILECs to file within 90 days of the release of
this decision, cost studies for interconnection rates based on the newly
defined LIRs. The Commission also directs the CLECs to adopt those rates
approved for interconnection purposes. The Commission notes that until
such time as it approves the new interconnection rates, the existing
interconnection rates used on an exchange basis are to be used as
interim rates for the newly defined LIRs. |
|
POI diversity
|
|
SIZE="3">
Position of parties
|
111. |
The Companies submitted that mandating POI
diversity was entirely inappropriate. The Companies indicated, however,
that POI diversity could be beneficial, as long as the objectives and
the benefits of deploying diversity were commensurate with the
associated costs. The Companies indicated that their experience with
requests for POI diversity was that typically they were asked to create
redundant network facilities only to find out that the requesting CLEC
would not be doing so. The Companies therefore argued that POI diversity
should not be considered unless both parties were prepared to establish
transport redundancy. |
112. |
The Companies and TELUS further submitted
that POI diversity should be considered on a case-by-case basis through
bilateral negotiations and both parties should be required to
establish POI diversity with associated route diversity in cases where
there is agreement to do so. TELUS argued that there may be other ways
to increase the reliability of the network rather than on the basis of
POI diversity, which TELUS referred to as the "weakest link" approach. |
113. |
CLECs generally supported the view that POI
diversity should be mandated and provided on a shared-cost basis where
requested by a CLEC. EastLink, however was of the view that POI
diversity would not be required in situations where the ILEC's POI has
performed flawlessly and the ILEC had a satisfactory action plan to
respond to a significant outage. |
114. |
Allstream, EastLink and FCI Broadband
submitted that they had all experienced POI outages. Allstream stated it
had experienced two outages that were caused by environmental problems
in the space housing fibre optics terminal systems equipment in Ottawa,
and by a fire at Bell Canada's Simcoe office in Toronto. EastLink
reported two POI outages, both occurring in 2001 that were attributed to
ILEC-initiated upgrades to their network. FCI Broadband reported it had
experienced numerous POI outages affecting shared-cost facilities and in
each case it had worked with Bell Canada to implement routing
translations to restore traffic flows through another POI until the
initial trouble was resolved. |
115. |
LondonConnect submitted that for the most
part, the majority of the ILECs had refused to implement any form of POI
diversity on a shared cost basis. LondonConnect stated that only one
ILEC had been cooperative in establishing a limited form of POI
diversity, at extremely low incremental costs for the ILEC. |
116. |
LondonConnect argued that there was no
incentive for a CLEC to demand diversity where it was not justified, and
that no criteria should be established that presupposed that a CLEC's
request for POI diversity was not reasonable. LondonConnect argued that
where shared-cost diversity was requested by a CLEC the onus should be
on the ILEC to show why it should not be implemented. |
117. |
Microcell stated that the dominant ILECs
have both the means and the motive to force CLECs into a "catch-22"
situation, where CLECs must either accept a precarious quality of
service or absorb excessive costs of POI diversity to improve robustness
in the network. |
|
SIZE="3">
Commission analysis and determination
|
118. |
In Decision 97-8,
the Commission mandated the equal sharing of the costs of interconnecting
trunks between LECs within an ILEC exchange. However, the decision
did not address the issue of cost sharing with respect to redundant
facilities. The Commission notes that redundant facilities can involve
geographical route diversity and/or redundant POIs. |
119. |
In Order 2000-164,
the Commission noted that there was an industry consensus that geographically
diverse facilities would not be constructed where both parties agreed
not to do so. There was also general agreement that where both parties
agreed to implement shared-cost facilities on diverse routes, parties
would share equally the cost to construct the facilities. |
120. |
Where a CLEC desired the construction of
geographically diverse facilities and the ILEC did not, however, the
Commission mandated in Order 2000-164
that shared-cost interconnecting trunks be provided by the ILEC unless
the ILEC could demonstrate to the Commission's satisfaction that the
geographically diverse interconnecting circuits were not required. |
121. |
The Commission was of the view that a
balance needed to be established in the public interest between
constructing a robust and reliable network and efficient interconnection
configurations that did not impose higher costs than necessary. The
Commission indicated that for competition to flourish and the network to
function properly with as few outages as possible it was important that
the building of shared cost facilities not take place only where both
LECs agreed. The Commission noted that the incremental costs to
implement geographic diversity were normally higher for new entrants
than ILECs and that CLECs would, accordingly, have very little incentive
to install unnecessary diversity, even where costs were shared. |
122. |
The Commission notes that in Order CRTC 2000-126,
17 February 2000, it did not mandate the provision of geographically
diverse shared-cost facilities when required by an ILEC, or for interconnection
between CLECs, since the costs involved could become a significant
barrier to competitive entry, particularly by small CLECs. |
123. |
With regard to POI diversity, while this
was not considered in Order 2000-164,
the Commission finds that the considerations related to POI diversity
are similar to those regarding route diversity that led to Order 2000-164. |
124. |
The Commission is therefore of the view
that the rationale for mandating geographical diversity is equally
applicable to POI diversity. It is in the public interest to ensure
robustness and reliability in the network and it would be unfair to
impose higher carrier costs on one carrier, the CLEC, who in the
majority of cases would be the carrier requesting the POI diversity. |
125. |
Accordingly, the Commission mandates the
provision of shared cost POI diversity when requested by a CLEC, unless
an ILEC can demonstrate to the Commission's satisfaction that POI
diversity is not required. Both the ILEC and CLEC are to implement a
second POI and the two carriers are to share equally in the
interconnection facilities and trunking costs between the POIs. In cases
where a CLEC has requested POI diversity, the Commission also concludes
that should an ILEC wish to implement an alternative solution, it would
be up to the ILEC to persuade the CLEC to implement the alternative
solution rather than POI diversity. Failing to persuade the CLEC of the
alternative, POI diversity must be implemented. |
126. |
The Commission further determines that
provisioning POI diversity should not be mandated when requested solely
by an ILEC. The Commission finds that POI diversity could be very
expensive and as such, could impose a significant burden on small CLECs
entering the market. |
|
Other issues
|
127. |
Other issues in this proceeding include:
separation of ISP traffic, indirect interconnection, Bell Canada's MGP
service, 9-1-1 route diverse connections and CCS7
A-link interconnections. |
|
SIZE="3">
Separation of ISP traffic
|
128. |
The Companies argued that in the event the
Commission changed the current shared-costs arrangements, the rules
should exclude ISP traffic from any calculation of traffic imbalance
given that it is one-way traffic and is heavily imbalanced towards the
LEC with which an ISP is interconnected. |
129. |
Call-Net disagreed with the Companies on
the need to alter the current regime to exclude ISP traffic. Call-Net
argued that it was the ILECs that had established the bill and keep
rates and they would have taken into account one-way traffic such as
that caused by ISP traffic, call centres and telephone banking services.
Call-Net further argued that dial-up Internet traffic is declining due
to high speed Internet growth and would represent an ever decreasing
volume of traffic on the bill and keep trunks. Call-Net concluded that
there is no reason to separate and measure the dial-up Internet traffic
or any other traffic on the bill and keep trunks. |
130. |
The Commission notes that all LECs have ISP
dial-up traffic on their local network and that the Companies themselves
are major ISPs in the marketplace. The Commission further notes that
there are customers other than ISPs that generate one-way traffic. |
131. |
The Commission considers any distortion
created by dial-up Internet traffic would be insignificant and excluding
it from the bill and keep arrangement would be discriminatory. The
Commission concludes that it is neither necessary nor appropriate to
remove ISP traffic from the calculation of imbalance traffic. |
|
SIZE="3">
Indirect interconnection
|
132. |
The OTA noted that none of the submissions
addressed the scenario where calls that are originated by a CLEC,
transited through a large ILEC and terminated via EAS to a small ILEC,
which the OTA referred to as an "Indirect Connection." |
133. |
The OTA submitted that indirect connections
are happening today in all of the exchanges served by the small ILECs
and that, while the large ILEC receives compensation from the CLEC for
transiting calls, the small ILEC does not receive any compensation for
the call termination. In that context, the OTA submitted that the
intermediary LEC should only receive compensation for transiting traffic
and that compensation for call termination should be paid to the
terminating LEC. |
134. |
The Commission notes the concern raised by
the OTA. However, the Commission considers that there is insufficient
information on the record of this proceeding and, therefore, finds that
it is unable to address the specific matter raised by the OTA in this
decision. |
135. |
The Commission recommends that if the OTA
considers this issue to be significant that it try to resolve the issue
through negotiations between the large ILECs and OTA members. Should
that approach fail, the Commission would be prepared to consider the
matter further. |
|
SIZE="3">
Bell Canada's MGP service
|
136. |
The Companies submitted that Bell Canada
had proposed to make its MGP service available, on a discretionary
basis, as an optional functionality for CLECs that would complement
existing local interconnection arrangements. Bell Canada had filed this
service under Tariff Notice 6597. |
137. |
LondonConnect submitted that Bell Canada's
MGP, rather than enhancing the co-carrier relationship of CLECs and
ILECs, made CLECs customers of Bell Canada, relying on an optional
tariffed service. LondonConnect offered that the general grouping of
exchanges proposed under the MGP might provide some insight into the
possible consolidation of exchanges for the purposes of interconnection,
yet offered no benefit for entrants. LondonConnect submitted that the
MGP proposal ought to be given no weight in the Commission's
determinations. |
138. |
The Commission notes that Bell Canada
originally filed the MGP tariff separate from this proceeding.
The Commission notes that the MGP had implications and was inter-related
with interconnection matters, and as such, the Commission made the MGP
tariff part of this proceeding. |
139. |
The Commission considers that the MGP
tariff contravenes the co-carrier relationship being fostered by the
Commission for interconnection. The Commission further considers that
the determinations made in this decision make the MGP tariff unnecessary
for the CLECs. Accordingly, the Commission denies the application. |
|
SIZE="3">
9-1-1 route diverse connections
|
140. |
In their supplementary comments, Cogeco
raised concerns about Bell Canada's 9-1-1 tariffs which required
route-diverse connections to a pair of 9-1-1 tandems on a DS-1 basis,
rather than on a DS-0 basis. Call-Net extended support to the option of
ordering 9-1-1 access trunks on a DS-0 basis. No other comments were
received on this matter. |
141. |
The Commission notes the concern raised by
Cogeco concerning the Bell Canada 9-1-1 tariffs and the need for route
diversity to a pair of 9-1-1 tandems on a DS-1 basis. In the
Commission's view, there is cause for concern for new entrants who are
providing service in areas where lower population results in severely
underutilized trunks for 9-1-1 service. The Commission also considers
that it is in the public interest to ensure that appropriate trunking
arrangements are put in place to ensure the safety of consumers. |
142. |
The Commission finds that the record of
this proceeding did not provide sufficient evidence to determine what,
if any, revisions should be made to the 9-1-1 interconnecting trunking
arrangements to satisfy the concerns of new entrants while ensuring
public safety. The Commission directs Bell Canada and Cogeco, and any
other party who is interested in the issue of 9-1-1 interconnecting
trunking arrangements, to form a CISC 9-1-1 sub-committee to address
this issue, with the intent of developing a solution, within 120 days
from the date of this decision, that addresses the concern of
underutilized facilities for new entrants, while ensuring that public
safety is not compromised. |
|
SIZE="3">
CCS7 A-link interconnection
|
143. |
EastLink stated that ILECs should make
provisions for interconnection of a switch to a gateway signalling
transfer point (STP) in each numbering plan area (NPA) (A-link
connection). EastLink also stated that interconnection should be on a
shared-cost basis in a similar fashion as the costs of interconnection
between signalling points of interconnection (SPOIs) (D-link
interconnection). |
144. |
The Companies stated that there was no need
for the Commission to mandate each ILEC to provide gateway STPs for CCS7
interconnection in each NPA where it provides service. Currently, all
CCS7 interconnections to the Companies' networks are provided through
the interconnection to two Bell Canada gateway STP pairs, one pair
located in Toronto and the other in Montréal. When one of the Companies
has to provide for CCS7 interconnection in an NPA, the Company would
make arrangements with one or more of the other Companies to establish
the CCS7 interconnection arrangements to a gateway STP. |
145. |
The Companies stated that it disagreed with
EastLink's view and stated that there was no justification or
requirement for all ILECs to deploy gateway STPs. If a CLEC chose not to
deploy STPs, then the CCS7 interconnection arrangements with the ILEC
was not viewed in the context of an interconnection between carriers of
equal status and the provision of signalling links was not subject to
cost sharing. |
146. |
TELUS added that the requirement to provide
a STP in each NPA would cause the ILECs to purchase the required
equipment thereby incurring unnecessary expense that would offer no
apparent benefit. |
147. |
VTL stated that ILECs should make available
gateway STP access for CCS7 A-link interconnection in each NPA rather
than provide a gateway STP. This requirement would not necessarily
require that a STP be provided rather all that would have to be provided
is a SPOI in the NPA. In VTL's view, the provision of a SPOI would allow
small service providers wishing to interconnect with an ILEC in only one
NPA to do so independently of the ILEC's signalling network architecture
and at affordable prices. |
148. |
In Decision 97-8,
the Commission required that each carrier providing service in an
NPA establish a SPOI in the NPA. Each carrier is required to provide
access to the CCS7 network it uses at its SPOI and is responsible
for any costs associated with configuring a gateway STP and for the
cost of the D-link segment between its gateway STP and its SPOI. The
cost of the facilities required to provide the D-link segment between
carrier's SPOIs is shared because this is a peer-to-peer type of interconnection. |
149. |
In Order 98-486,
the Commission determined that an A-link between a local switch and
an STP was not a peer-to-peer relationship because A-links the CLEC
provided under an ILEC tariff did not have its own STP. |
150. |
The Commission finds that the determinations
made in Decision 97-8
and in Order 98-486 with
respect to STP interconnection rules continue to be appropriate. The
Commission agrees that there is no justification or requirement for
all ILECs to deploy gateway STPs in each NPA and requiring STPs
in each NPA would cause unnecessary expense without benefit. The Commission,
therefore, denies EastLink's request to have their A-link interconnection
be on a shared-cost basis. |
151. |
The Commission notes, that should a CLEC
request CCS7 D-link interconnection in any of the NPAs where these ILECs
provide service, the ILEC would not deploy a gateway STP but would be
required to designate a SPOI in the NPA where the CLEC requested
interconnection. The costs of the interconnection between the CLEC SPOI
and the ILEC SPOI in the NPA would be on a shared-cost basis. The CCS7
trunking costs between the ILEC SPOI and its gateway STP would, on the
other hand, not be a shared cost, the ILEC would be responsible for
these costs. |
152. |
In light of the above, and although the
A-link interconnection is not peer-to-peer, the Commission is of the
view that it is discriminatory to have a CLEC who uses A-link
interconnection to incur the entire cost of the CCS7 trunking to
wherever the ILEC determines its gateway STP will be located, when a LEC
using CCS7 D-link interconnection can avail itself of SPOIs in each NPA.
The Commission, therefore, finds that it would be more reasonable to
have the ILEC designate a SPOI within its NPA for purposes of
interconnection of A-links. |
153. |
The Commission, therefore, directs the
ILECs to amend and file for approval proposed CCS7 A-link
interconnection tariffs which designate a SPOI within each NPA for
purposes of interconnection of A-links. |
|
Secretary General |
|
This document is available in
alternative format upon request and may also be examined at the
following Internet site:
http://www.crtc.gc.ca |
_____________________________
Footnotes:
Appendix
|
Provincially defined administrative regions
(proposed as LIRs) |
|
Provinces of Alberta and
British Columbia served by: |
|
|
TELUS Communications Inc., Northwestel
Inc. and Prince Rupert City Telephone (LIRs exclude the serving
territories and the independent telephone companies) |
|
Alberni-Clayoquot, B.C. |
|
Beaver County, Alta. |
|
Birch Hills County, Alta. |
|
Bulkley-Nechako, B.C. |
|
Capital, B.C. |
|
Cardston County, Alta. |
|
Cariboo, B.C. |
|
Central Coast, B.C. |
|
Central Kootenay, B.C. |
|
Central Okanagan, B.C. |
|
Clearwater County, Alta. |
|
Columbia-Shuswap, B.C. |
|
Comox-Strathcona (Island), B.C. |
|
Comox-Strathcona (Mainland),
B.C. |
|
County of Athabasca, Alta. |
|
County of Barrhead, Alta. |
|
County of Camrose, Alta. |
|
County of Forty Mile, Alta. |
|
County of Grande Prairie, Alta. |
|
County of Lethbridge, Alta. |
|
County of Minburn, Alta. |
|
County of Newell, Alta. |
|
County of Paintearth, Alta. |
|
County of Stettler, Alta. |
|
County of St-Paul, Alta. |
|
County of Thorhild, Alta. |
|
County of Two Hills, Alta. |
|
County of Vermilion River,
Alta. |
|
County of Warner, Alta. |
|
County of Wetaskiwin, Alta. |
|
Cowichan Valley, B.C. |
|
Cypress County, Alta. |
|
East Kootenay, B.C. |
|
Flagstaff County, Alta. |
|
Fraser Valley, B.C. |
|
Fraser-Fort George, B.C. |
|
Greater Vancouver, B.C. |
|
Kitimat-Stikine, B.C. |
|
Kneehill County, Alta. |
|
Kootenay Boundary, B.C. |
|
Lac Ste-Anne County, Alta. |
|
Lacombe County, Alta. |
|
Lakeland County, Alta. |
|
Lamont County, Alta. |
|
Leduc County, Alta. |
|
Mount Waddington (Island), B.C. |
|
Mount Waddington (Mainland),
B.C. |
|
Mountain View County, Alta. |
|
Municipal District of Acadia,
Alta. |
|
Municipal District of Big
Lakes, Alta. |
|
Municipal District of Bighorn,
Alta. |
|
Municipal District of Brazeau,
Alta. |
|
Municipal District of
Bunnyville, Alta. |
|
Municipal District of Clear
Hills, Alta. |
|
Municipal District of Fairview,
Alta. |
|
Municipal District of
Foothills, Alta. |
|
Municipal District of Greenview,
Alta. |
|
Municipal District of Lesser
Slave River, Alta. |
|
Municipal District of
Mackenzie, Alta. |
|
Municipal District of Northern
Lights, Alta. |
|
Municipal District of
Opportunity, Alta. |
|
Municipal District of Peace,
Alta. |
|
Municipal District of Pincher
Creek, Alta. |
|
Municipal District of Provost,
Alta. |
|
Municipal District of Ranchland,
Alta. |
|
Municipal District of Rocky
View, Alta. |
|
Municipal District of Smoky
River, Alta. |
|
Municipal District of Taber,
Alta. |
|
Municipal District of Wainright,
Alta. |
|
Municipal District of Willow
Creek, Alta. |
|
Municipality of Calgary, Alta. |
|
Municipality of Edmonton, Alta. |
|
Nanaimo, B.C. |
|
North Okanagan, B.C. |
|
Northern Rockies (formerly
called Nelson-Liard), B.C. |
|
Northern Sunrise County, Alta. |
|
Okanagan-Similkameen, B.C. |
|
Parkland County, Alta. |
|
Peace River, B.C. |
|
Ponoka County, Alta. |
|
Powell River, B.C. |
|
Red Deer County, Alta. |
|
Regional Municipality of Wood
Buffalo, Alta. |
|
Saddle Hills County, Alta. |
|
Skeena-Queen Charlotte, B.C. |
|
Smoky Lake County, Alta. |
|
Sqamish-Lillooet, B.C. |
|
Starland County, Alta. |
|
Stikine, B.C. |
|
Strathcona County, Alta. |
|
Sturgeon County, Alta. |
|
Sunshine Coast, B.C. |
|
Thompson-Nicola, B.C. |
|
Vulcan County, Alta. |
|
Province of Manitoba served
by: |
|
|
MTS Communications Inc. |
|
Central Plains |
|
Eastman |
|
Interlake |
|
Northern |
|
Parkland |
|
Pembina Valley |
|
Westman |
|
Winnipeg |
|
Province of New Brunswick
served by: |
|
|
Aliant Telecom Inc. |
|
Albert County |
|
Carleton County |
|
Charlotte County |
|
Gloucester County |
|
Kent County |
|
Kings County |
|
Madawaska County |
|
Northumberland County |
|
Queens County |
|
Restigouche County |
|
Saint-John County |
|
Sunbury Counties |
|
Victoria County |
|
Westmorland County |
|
York County |
|
Province of Newfoundland and
Labrador served by: |
|
|
Aliant Telecom Inc. |
|
Aurora |
|
Avalon Gateway |
|
Capital Coast |
|
Central Labrador |
|
Coats of Bays |
|
Discovery |
|
Emerald |
|
Exploits Valley |
|
Humber |
|
Hyron |
|
Inukshuk |
|
Irish loop |
|
Kittiwake |
|
Labrador Straits |
|
Long Range |
|
Marine and Mountain |
|
Mariner |
|
Nordic |
|
Red Ochre |
|
Schooner |
|
Province of Nova Scotia
served by: |
|
|
Aliant Telecom Inc. |
|
Annapolis County |
|
Antigonish County |
|
Cape Breton County |
|
Colchester County |
|
Cumberland County |
|
Digby County |
|
Guysborough County |
|
Halifax County |
|
Hants County |
|
Inverness County |
|
Kings County |
|
Lunenburg County |
|
Pictou County |
|
Queens County |
|
Richmond County |
|
Shelburne County |
|
Victoria County |
|
Yarmouth County |
|
Provinces of Ontario and
Québec served by: |
|
|
Bell Canada, TELUS Communications
(Québec) Inc. and Société en commandite Télébec |
|
Abitibi, Que. |
|
Abitibi-Ouest, Que. |
|
Acton, Que. |
|
Antoine-Labelle, Que. |
|
Argenteuil, Que. |
|
Arthabaska, Que. |
|
Asbestos, Que. |
|
Avignon, Que. |
|
Beauce-Sartignan, Que. |
|
Beauharnois-Salaberry, Que. |
|
Bécancour, Que. |
|
Bellechasse, Que. |
|
Bonaventure, Que. |
|
Brome-Missisquoi, Que. |
|
Bruce County, Ont. |
|
Caniapiscau, Que. |
|
Charlevoix-Est, Que. |
|
City of Chatham-Kent (formerly
County of Kent), Ont. |
|
City of Greater Sudbury, Ont. |
|
City of Hamilton, Ont. |
|
City of Kawartha Lakes
(formerly County of Victoria), Ont. |
|
City of Ottawa, Ont. |
|
City of Toronto, Ont. |
|
Coaticook, Que. |
|
County of Brant, Ont. |
|
D'Autray, Que. |
|
Des Chenaux, Que. |
|
Deux-Montagnes, Que. |
|
District of Algoma, Ont. |
|
District of Cochrane, Ont. |
|
District of Kenora, Ont. |
|
District of Manitoulin, Ont. |
|
District of Muskoka, Ont. |
|
District of Parry Sound, Ont. |
|
District of Rainy River, Ont. |
|
District of Sudbury, Ont. |
|
District of Thunder Bay, Ont. |
|
District of Timiskaming, Ont. |
|
Drummond, Que. |
|
Dufferin County, Ont. |
|
Durham Region, Ont. |
|
Elgin County, Ont. |
|
Essex County, Ont. |
|
Frontenac County, Ont. |
|
Grey County, Ont. |
|
Haldimand, Ont. |
|
Haliburton County, Ont. |
|
Halton Region, Ont. |
|
Hastings County, Ont. |
|
Huron County, Ont. |
|
Joliette, Que. |
|
Kamouraska, Que. |
|
La Côte-de-Beaupré, Que. |
|
La Côte-de-Gaspé, Que. |
|
La Haute-Côte-Nord, Que. |
|
La Haute-Gaspésie, Que. |
|
La Haute-Yamaska, Que. |
|
La Jacques-Cartier, Que. |
|
La Matapédia, Que. |
|
La Mitis, Que. |
|
La Nouvelle-Beauce, Que. |
|
La Rivière-du-Nord, Que. |
|
La Tuque, Que. |
|
La Vallée-de-la-Gatineau, Que. |
|
La Vallée-du-Richelieu, Que. |
|
Lac-Saint-Jean-Est, Que. |
|
Lajammerais, Que. |
|
Lambton County, Ont. |
|
L'Amiante, Que. |
|
Lanark County, Ont. |
|
L'Assomption, Que. |
|
Le Bas-Richelieu, Que. |
|
Le Domaine-du-Roy, Que. |
|
Le Fjord-du-Saguenay, Que. |
|
Le Granit, Que. |
|
Le Haut-Saint-François, Que. |
|
Le Haut-Richelieu, Que. |
|
Le Haut-Saint-Laurent, Que. |
|
Le Rocher Percé, Que. |
|
Le Val-Saint-François, Que. |
|
Leeds & Greenville County, Ont. |
|
Lennox and Addington County,
Ont. |
|
L'Érablie, Que. |
|
Les Basques, Que. |
|
Les Etchemins, Que. |
|
Les Jardins-de-Napierville,
Que. |
|
Les Laurentides, Que. |
|
Les Maskoutains, Que. |
|
Les Moulins, Que. |
|
Les Pays-d'en-Haut, Que. |
|
Les-Collines-de-l'Outaouais,
Que. |
|
L'ïle-d'Orléans, Que. |
|
L'Islet, Que. |
|
Lotbinière, Que. |
|
Manicouagan, Que. |
|
Maria-Chapdelaine, Que. |
|
Maskinongé, Que. |
|
Matane, Que. |
|
Matawanie, Que. |
|
Mékinac, Que. |
|
Memphrémagog, Que. |
|
Middlesex County, Ont. |
|
Minganie, Que. |
|
Montcalm, Que. |
|
Montmagny, Que. |
|
Municipalité des Îles-de-la-Madeleine,
Que. |
|
Niagara Region, Ont. |
|
Nicolet-Yamaska, Que. |
|
Nipissing District, Ont. |
|
Norfolk Region, Ont. |
|
Northumberland County, Ont. |
|
Oxford County, Ont. |
|
Papineau, Que. |
|
Perth County, Ont. |
|
Peterborough County, Ont. |
|
Pontiac, Que. |
|
Portneuf, Que. |
|
Prescott and Russell, Unities
Counties, Ont. |
|
Prince Edward County, Ont. |
|
Renfrew County, Ont. |
|
Rimouski-Neigette, Que. |
|
Rivière-du-Loup, Que. |
|
Robert Cliché, Que. |
|
Roussillon, Que. |
|
Rouville, Que. |
|
Sept-Rivières, Que. |
|
Simcoe County, Ont. |
|
Stormont, Dundas and Glengarry
County, Ont. |
|
Témiscamingue, Que. |
|
Témiscouata, Que. |
|
Territoire de Jamésie, Que. |
|
Territoire de Kativik, Que. |
|
Territoire de la
Basse-Côte-Nord, Que. |
|
Thérèse-De Blainville, Que. |
|
Vallée-de-l'Or, Que. |
|
Vaudreuil-Soulanges, Que. |
|
Ville de Gatineau, Que. |
|
Ville de Laval, Que. |
|
Ville de Lévis, Que. |
|
Ville de Longueuil, Que. |
|
Ville de Mirabel, Que. |
|
Ville de Montréal, Que. |
|
Ville de Québec, Que. |
|
Ville de Rouyn-Noranda, Que. |
|
Ville de Saguenay, Que. |
|
Ville de Shawinigan, Que. |
|
Ville de Sherbrooke, Que. |
|
Ville de Trois-Rivières, Que. |
|
Waterloo Region, Ont. |
|
Wellington County, Ont. |
|
York Region, Ont. |
|
Province of Prince-Edward
Island served by: |
|
|
Aliant Telecom Inc. |
|
Kings County |
|
Prince County |
|
Queens County |
|
Province of Saskatchewan
served by: |
|
|
Saskatchewan Telecommunications |
|
Battlefords |
|
Big Gully |
|
Border |
|
Carlton Trail |
|
Cornerstone |
|
Cypress Hills |
|
Entrepreneurs 2000 |
|
Etomami Valley |
|
Gateway |
|
Good Spirit |
|
Great River Lakes |
|
Long Lake |
|
Mainline |
|
Midwest |
|
Moose Jaw |
|
North East |
|
Northwest |
|
Prairie to Pine |
|
Prince Albert |
|
Red Coat |
|
Regina |
|
Saskatoon |
|
South East |
|
South Parkland |
|
Southwest |
|
Touchwood Hills |
|
West Central |
|
Yellowhead |
Date Modified: 2004-07-14 |