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Telecom Decision CRTC 2006-35
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Ottawa, 29 May 2006 |
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Follow-up to Trunking arrangements for the interchange of traffic
and the point of interconnection between local exchange carriers,
Telecom Decision CRTC 2004-46
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Reference: 8638-C12-200410465,
8740-T42-200411182,
8740-T46-200411190,
8740-A53-200500414,
8740-S22-200500464,
8740-B2-200500498
and 8740-M59-200501678 |
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The Commission approves the
amended definitions of the local interconnection regions (LIRs) proposed
by each incumbent local exchange carrier (ILEC) and approves on a
final basis, effective the date of this Decision, the
interconnection rates for the termination of competitive local exchange
carrier (CLEC) intra-LIR traffic for each ILEC, as adjusted by the
Commission. The Commission modifies the rate structure to include
10 percent traffic imbalance increments, and removes the six-month
settling-in period and the subsequent three-month traffic imbalance
measurement period to permit billing to commence on the date of
commercial launch of a CLEC within an LIR. The Commission maintains the
existing interconnection rates for termination of CLEC intra-exchange
traffic for the grandfathered exchange-based regime. The Commission
specifies the trunking arrangements for extended area service (EAS)
transport and transit services in the LIR-based interconnection regime.
The Commission also modifies the existing interconnection framework to
permit the carriage of toll-terminating traffic on EAS transport and
transit services, and permits the ILECs to file, within 90 days of the
date of this Decision, cost studies and associated proposed revised
rates for EAS transport and transit services if warranted. The
Commission directs each ILEC to issue, within 45 days of the date of
this Decision, revised tariff pages that reflect the determinations of
this Decision. |
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Introduction
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1. |
In Trunking arrangements for the interchange
of traffic and the point of interconnection between local exchange
carriers, Telecom Decision CRTC 2004-46,
14 July 2004 (Decision 2004-46),
the Commission modified the regulatory framework for the interconnection
of local exchange carriers (LECs) by consolidating exchanges to form
larger local interconnection regions (LIRs), and to provide increased
efficiencies and lower costs of interconnection for local service
competitors. |
2. |
In Decision 2004-46,
the Commission determined that traffic interchange between LECs was
to be provided through shared-cost interconnecting trunks between
each LEC's point of interconnection (POI) site within an LIR, and
that the termination of traffic that was both interchanged and terminated
within the LIR would be subject to the bill-and-keep mechanism, and,
where appropriate, mutual compensation. The
Commission notes that in this Decision, the shared cost trunks between
LECs are referred to as bill-and-keep trunks and the interconnection
service for termination of competitive local exchange carrier (CLEC)
intra-LIR traffic is hereinafter referred to as the LIR-based traffic
termination service. |
3. |
In Decision 2004-46,
the Commission also set out rules for the incumbent local exchange
carriers (ILECs) to follow in defining their LIRs. In addition, the
Commission directed the ILECs to file, within 90 days of the date
of that decision, cost studies and proposed rates for the LIR-based
traffic termination service. These rates are used to determine the
level of compensation between a CLEC and an ILEC based on the level
of traffic imbalance on the shared-cost interconnecting trunks.
These rates are also referred to as mutual compensation rates. |
4. |
In Decision 2004-46,
the Commission also directed the ILECs to identify the designated
POIs for those LIRs within which a CLEC was already operating. The
Commission further directed the ILECs to amend and file for approval
proposed common channel signalling number 7 (CCS7) A-link tariffs
to designate a signalling point of interconnection (SPOI) within each
numbering plan area (NPA) for the interconnection of A-links. |
5. |
In Decision 2004-46,
the Commission further determined that extended area service (EAS)
transport and termination, transit, toll originating, 9-1-1, and message
relay services would remain on separate trunks and that all other
aspects of the existing interconnection framework and associated rates
would be grandfathered. In addition, the Commission mandated the provision
of shared-cost POI diversity when requested by a CLEC, unless an ILEC
could demonstrate to the Commission's satisfaction that POI diversity
was not required. |
6. |
The Commission also permitted the ILECs to
file updated cost studies for EAS transport, transit, access tandem (AT)
and direct connection (DC) services if the cost changes due to the
introduction of LIRs so warranted it. |
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Process
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7. |
Pursuant to the Commission's directives in
Decision 2004-46, Bell Canada
filed, on 12 October 2004, its cost study, proposed rates for its
LIR-based traffic termination service, proposed LIRs, associated default
POIs, and designated SPOIs. |
8. |
On 12 October 2004, TELUS Communications
Inc. (now TCC)1
filed tariff notices for each of TCC operating in Alberta (TCC-AB) and
TCC operating in British Columbia (TCC-BC). In these tariff notices, TCC
proposed common rates for its LIR-based traffic termination service
along with revised tariff pages. By separate letter dated 12 October
2004, TCC identified its proposed LIRs, default POIs, and designated
SPOIs within its serving territory. |
9. |
On 12 October 2004, Aliant Telecom Inc.
(Aliant Telecom), Société en commandite Télébec (Télébec), and TELUS
Communications (Québec) Inc. (TCQ) filed their proposed LIRs and default
POIs within their serving territories. By letter dated 13 October 2004,
MTS Allstream Inc. (MTS Allstream) filed its proposed LIRs and default
POIs within its serving territory. On the same date, Saskatchewan
Telecommunications (SaskTel) filed its proposed LIRs, the associated
default POIs, and designated SPOIs. |
10. |
On 25 October 2004, Cogeco Cable Inc.
(Cogeco) filed comments related to its withdrawal from a CRTC
Interconnection Steering Committee (CISC) working group dealing with the
under-utilization of 9-1-1 facilities for new entrants. Xit telecom inc.
(Xit telecom) filed comments related to the 9-1-1 issue on 26 October
2004. |
11. |
Call-Net Enterprises Inc. (Call-Net)2
filed comments dated 11 November 2004. The Canadian Cable
Telecommunications Association (the CCTA), Microcell Telecommunications
Inc. (Microcell), now part of Rogers Wireless Inc., Quebecor Media Inc.
(QMI), Shaw Telecom Inc. (Shaw), and Xit telecom filed comments on 12
November 2004. |
12. |
On 14 December 2004, the Commission issued
a process letter to ensure that all ILECs provided revised tariff pages
and rates required to support the LIR-based interconnection regime, and
to allow parties to comment on these changes in a timely manner. |
13. |
On 14 January 2005, |
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- Bell Canada filed proposed modifications to its tariff pages along
with proposed traffic termination service rates that applied to both
LIR-based and exchange-based interconnection;
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- Aliant Telecom filed proposed revisions to its tariff pages to
incorporate LIRs, proposed traffic termination service rates for
LIR-based interconnection, and the associated cost study; and
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- SaskTel filed proposed revisions to its tariff pages and on
28 January 2005 it filed proposed traffic termination service rates
for LIR-based interconnection and the supporting cost study.
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14. |
QMI, the CCTA, MTS Allstream, Rogers
Communications Inc. (Rogers), TCC, and Xit telecom filed comments in
late January 2005. MTS Allstream filed revised comments on 7 February
2005. |
15. |
Bell Canada and Aliant Telecom, jointly,
and SaskTel filed reply comments on 7 February 2005. |
16. |
On 17 February and 29 March 2005,
MTS Allstream filed proposed revisions to its tariff pages to support
LIR-based interconnection. On 17 March 2005, TCC filed comments related
to MTS Allstream's 17 February 2005 submission. |
17. |
By letter dated 27 June 2005, Commission
staff proposed amendments to the ILEC-proposed LIRs, and set out a
process to allow parties to address these proposed amendments. |
18. |
MTS Allstream, SaskTel, TCC, the CCTA, and
Xit telecom filed comments on 15 July 2005. Aliant Telecom, Bell Canada,
MTS Allstream, SaskTel, and TCC filed reply comments in late July 2005.
On 26 August 2005, Aliant Telecom proposed modified LIRs that
incorporated Commission staff's proposed amendments along with revisions
to several LIRs in the Aliant Telecom-Newfoundland and Labrador region. |
19. |
In response to the Commission's
interrogatories dated 16 August 2005, Aliant Telecom filed revisions to
its cost studies on 13 September 2005 and responses to the
interrogatories on 16 September 2005. Bell Canada filed its responses to
the interrogatories on 16 September 2005. On 30 September 2005,
MTS Allstream filed comments regarding Aliant Telecom's and
Bell Canada's responses. |
20. |
SaskTel filed responses to the Commission's
interrogatories and modified tariff pages on 7 October 2005. TCC and
MTS Allstream filed responses to the Commission's interrogatories on 21
October 2005. Aliant Telecom and Bell Canada, jointly, and SaskTel filed
comments on 14 November 2005. |
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Items to be addressed in this proceeding
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21. |
After a thorough review of all of the
parties' submissions noted above, the Commission addresses the following
issues within the context of this proceeding: |
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- appropriateness of the ILECs' proposed LIRs;
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- final rates and related issues;
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- settling-in period and traffic imbalance measurement period;
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- high-usage architecture (HUA) for trunking arrangements;
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- trunking arrangements for EAS transport and transit services;
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- evolution from the exchange-based regime to the LIR-based regime;
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- cost sharing for joint-build facilities; and
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- SPOI interconnection arrangements.
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Appropriateness of the ILECs' proposed LIRs
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Background
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22. |
In paragraph 73 of Decision 2004-46,
the Commission established the following rules for ILECs to follow
in defining LIRs: |
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- LIRs were to be established using provincially defined
administrative regions, such as municipalities, counties, regional
districts, etc.;
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- the entire serving territory of Northwestel Inc. and the entire
serving territory of the small ILECs, where local competition was not
yet permitted, would be excluded from the requirement to establish
LIRs;
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- in cases where an exchange was served by a remote switch, the
exchange would be included in the LIR of the exchange of the host
switch; and
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- the civic address of the largest wire centre, based on network
access service (NAS), in each exchange would determine in which LIR
the ILEC exchange belonged.
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23. |
As noted above, as part of this process,
the ILECs filed proposed LIRs and Commission staff subsequently proposed
amendments to the ILEC-proposed LIRs. For ease of reference in this
Decision, the Commission has grouped the parties' submissions into two
groups: ILEC-proposed LIRs and Commission staff-proposed amendments to
the ILEC-proposed LIRs. |
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Positions of parties
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ILEC-proposed LIRs
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24. |
Bell Canada submitted that in specifying
its LIRs it had reassigned exchanges served by remotes to the LIR of the
associated host exchanges. Bell Canada further submitted that it had
addressed specific company network anomalies while keeping with the
essence of defining LIRs based on provincially-defined administrative
regions. |
25. |
MTS Allstream submitted that it had
modified the Commission-defined LIRs in its territory to ensure that
the rules of Decision 2004-46
were followed. MTS Allstream submitted that it was not feasible
to define LIRs that strictly followed provincially-defined administrative
regions because the MTS Allstream network architecture was not
aligned with provincially-defined administrative regions. MTS Allstream
submitted that its proposed LIRs were consistent with the rule that
required exchanges served by a remote switch to be included in the
LIR of the exchange of the host switch. |
26. |
SaskTel submitted that the
Commission-defined LIRs that were based on the Regional Economic
Development Authorities boundary map proved to be an unworkable
solution. SaskTel proposed 10 LIRs based on local communities of
interest (COIs) and SaskTel's host/remote switch arrangements. SaskTel
proposed alternative arrangements for Regina and Saskatoon that, in its
view, simplified interconnection arrangements while keeping LIR sizes
manageable. In each case, SaskTel proposed an urban LIR with a single
POI to serve the urban exchange and a rural LIR with its own POI to
serve the rural exchanges. SaskTel submitted that this arrangement
provided a CLEC with flexibility in serving rural or urban LIRs. |
27. |
Aliant Telecom proposed a set of LIRs and
designated POIs for each of its four operating regions: New Brunswick
(NB), Nova Scotia (NS), Prince Edward Island (PEI), and Newfoundland and
Labrador (NL). Aliant Telecom proposed three POIs for its Halifax LIR
and two POIs for its Capital Coast LIR. Aliant Telecom submitted that
the transition to a single POI for these LIRs required time and
investment, and that multiple POIs would better serve small CLECs. |
28. |
Rogers requested that the Commission direct
Aliant Telecom to identify a single POI for CLEC interconnection in the
Halifax and Capital Coast LIRs. |
29. |
In reply, Aliant Telecom submitted that
it declared more than one POI in the case of two LIRs because of existing
arrangements, and because of its intent to minimize overall industry
costs and provisioning delays related to the implementation of Decision
2004-46. Aliant Telecom further
submitted that multiple POIs could be more appropriate for small competitors.
Aliant Telecom submitted that it was prepared to transition to
a single POI over a period of time, depending on competitive demand,
capital costs, and its capability to develop a network plan and to
schedule the required work. |
30. |
TCC submitted examples that, in its view,
demonstrated that Bell Canada, MTS Allstream, and SaskTel had not
followed the Commission's rules for defining LIRs. TCC requested that
the Commission ask the parties to justify any definitions that did not
follow the Commission's rules before accepting them. The examples that
TCC submitted were the following: |
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- Bell Canada had proposed separate LIRs for Ottawa and Hull
(Gatineau); TCC submitted that because Ottawa-Hull was currently a
single exchange, the LIRs should not be developed based on a splitting
of that exchange;
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- MTS Allstream had proposed four new LIRs (Melita, Brandon,
Dauphin, and Swan River) in place of the Westman and Parkland LIRs as
proposed by the Commission; Melita and Brandon were part of the
Commission-proposed Westman LIR, and Dauphin and Swan River were part
of the Commission-proposed Parkland LIR; and
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- SaskTel had proposed urban and rural LIRs for each of Regina and
Saskatoon; TCC submitted that SaskTel had not followed the
Commission's rules in making these proposals.
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31. |
The CCTA submitted that it was generally
supportive of the ILEC-proposed LIRs. The CCTA was concerned that some
specific groupings of exchanges based on host/remote switch combinations
were not necessarily based on COI. The CCTA submitted that the LIRs
should be competitively neutral and reflect COIs, and that competitive
neutrality should take precedence over host/remote switch relationships.
The CCTA provided examples of TCC's and Aliant Telecom's proposed LIRs
that, in its opinion, were based on host/remote switch relationships
rather than COI. In addition, the CCTA submitted that an ILEC should not
be able to unilaterally modify allocation of exchanges to an LIR or
designation of a POI without Commission approval. |
32. |
Microcell submitted that there was a need
for further rationale from TCC and Bell Canada as to how they
chose the composition of their LIRs. In addition, Microcell provided
examples of TCC's LIR proposals that, in its opinion, did not follow
the directives of Decision 2004-46. |
33. |
TCC submitted that it had applied the
Commission's rules for defining LIRs, and that the examples noted by the
CCTA and Microcell followed those rules. |
34. |
Xit telecom submitted examples of municipal
regions in Quebec that were served by multiple LIRs, thus requiring a
CLEC to interconnect to multiple POIs to serve a particular municipal
region. Xit telecom was of the view that there were several occurrences
of COIs that would be left without the benefits of local competition
because of non-economic entry into LIRs that covered these areas. |
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Commission staff-proposed amendments to the ILEC-proposed LIRs
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35. |
In response to the above round of comments,
by letter dated 27 June 2005, Commission staff proposed the following
amendments to the ILEC-proposed LIRs: |
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- Aliant Telecom's proposed Halifax LIR and Capital Coast LIR would
each be served by a single POI on a going-forward basis;
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- SaskTel's proposed urban and rural LIRs for Regina and Saskatoon
would be combined into a single LIR for Regina and a single LIR for
Saskatoon;
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- Bell Canada's proposed Hull LIR would be served at the connecting
LEC's option, from the Ottawa POI via Bell Canada-provided facilities
while maintaining Bell Canada's proposed Ottawa LIR; and
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- MTS Allstream's proposed two LIRs in each of the Westman (Brandon
and Melita LIRs) and Parkland (Dauphin and Swan River LIRs) regions
would be maintained as is, only until CLEC demand materialized in the
Melita or Swan River LIRs.
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36. |
TCC agreed with the Commission
staff-proposed LIR amendments for Aliant Telecom and SaskTel. TCC
submitted that the proposal to maintain Bell Canada's separate Ottawa
and Hull LIRs, with access to both LIRs from the Ottawa POI, did not
provide trunking efficiency and simplicity. TCC submitted that
Bell Canada should allow diverse POIs, either in combination with
Bell Canada-provided facilities at Bell Canada's Ottawa and Hull POIs,
or via a second set of Bell Canada facilities. TCC further submitted
that Bell Canada should bear the expense of resolving difficulties
experienced by entrants related to interconnection that arose because of
the division of the Ottawa-Hull exchange. |
37. |
In reply, Bell Canada submitted that,
consistent with Relief plan for area codes 613 and 819, Telecom
Decision CRTC 2004-55, 18 August
2004 (Decision 2004-55), the Ottawa-Hull
exchange would be split into two separate exchanges when 10-digit
dialling was implemented by the fourth quarter of 2006. In accordance
with the Commission's rules specified in Decision 2004-46,
and in recognition of the impending split of the Ottawa-Hull exchange,
Bell Canada submitted that it had proposed an Ottawa LIR separate
from a Hull LIR. However, in response to the Commission staff proposals,
Bell Canada subsequently indicated that it was willing to provide
a CLEC with access to the Hull POI from the Ottawa POI via Bell Canada-provided
facilities at no additional charge. |
38. |
Bell Canada submitted that TCC's comments
regarding trunking inefficiencies should be discarded because there
would be little or no trunking efficiency loss as a result of splitting
the traffic exchanged by LECs in the Ottawa-Hull area given the current
volumes of traffic in the Ottawa-Hull exchange and the size of the trunk
groups already in place. |
39. |
Bell Canada further submitted that it had
no objection to CLECs establishing diverse POIs in the Hull LIR and that
it was willing to negotiate the establishment and terms and conditions
of additional POIs in the Hull LIR with individual CLECs on a bilateral
basis. |
40. |
TCC submitted that if MTS Allstream were
allowed to split the Westman and Parkland LIRs as it had proposed, the
following conditions should be met: |
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- TCC's toll terminating traffic to exchanges served by the Melita
switch should be accepted at the Brandon local tandem switch over
bill-and-keep trunks prior to the establishment of CLEC demand in
Melita;
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- TCC's toll terminating traffic to exchanges served by the
Swan River switch should be accepted at the Dauphin local tandem
switch over bill-and-keep trunks prior to the establishment of CLEC
demand in Swan River; and,
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- any compensation to MTS Allstream for the inclusion of Melita in
the Westman LIR or Swan River in the Parkland LIR should be recovered
through general interconnection rates.
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41. |
Xit telecom submitted that the proposed
adjustments to LIRs did not address the difficulties that small entrants
faced when providing local competition in smaller communities.
Xit telecom argued that the policy that allowed host/remote switch
relationships for assignment of exchanges to LIRs was in conflict with
the creation of LIRs based on COI. |
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Commission's analysis and determinations
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42. |
The Commission notes that the ILECs' proposals
would result in LIRs that encompass multiple exchanges that provide
competitors with access to more ILEC customers from a single POI than
the existing exchange-based regime, and would reduce the total number
of LIRs from the 337 LIRs defined in Decision 2004-46
to 182 LIRs. The Commission considers that the ILEC-proposed LIRs
achieve a major objective of Decision 2004-46
as they provide access to larger numbers of ILEC subscribers from
a significantly reduced number of POIs. |
43. |
The Commission further notes that differences
between the ILEC-proposed LIRs and the LIRs proposed in Decision 2004-46
primarily arose because of the extensive use of remotes in the ILECs'
current network architectures, and because exchange boundaries were
not aligned with provincially-defined administrative boundaries. |
44. |
The Commission accepts the LIRs proposed by
Aliant Telecom, SaskTel, Bell Canada, and MTS Allstream, as amended
below. |
45. |
Consistent with the directive of Decision
2004-46 that an LIR is to be accessed
from a single POI, the Commission directs Aliant Telecom to amend
its proposed LIRs as follows: |
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- Aliant Telecom's proposed Halifax LIR is to be served by a single
POI (HLFXNS01 – Lorne) instead of three POIs on a going-forward basis;
any existing agreements with CLECs that make use of alternative
arrangements may be maintained; and
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- Aliant Telecom's proposed Capital Coast LIR is to be served by a
single POI (STJHNF01 – Allandale) instead of two POIs on a
going-forward basis; any existing agreements with CLECs that make use
of alternative arrangements may be maintained.
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46. |
Consistent with the directive of Decision
2004-46 that an LIR is to be accessed
from a single POI, the Commission directs SaskTel to amend its proposed
LIRs as follows: |
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- SaskTel's proposed Regina urban and rural LIRs are to be combined
into a single Regina LIR serving both the urban and rural area through
a single POI (REGNSK03 – Regina); and
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- SaskTel's proposed Saskatoon urban and rural LIRs are to be
combined into a single Saskatoon LIR serving both the urban and rural
area through a single POI (SKTNSK01 – Saskatoon).
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47. |
With respect to the Ottawa and Hull LIRs,
the Commission notes that in Decision 2004-46,
it proposed separate Ottawa and Hull LIRs, based on provincial/municipal
boundaries. The Commission also notes that Bell Canada submitted
it had adjusted the Commission-proposed LIRs by applying the LIR definition
rules from Decision 2004-46. The
Commission further notes that TCC submitted that Ottawa-Hull was a
single exchange, and as such, the LIR definition should incorporate
the single Ottawa-Hull exchange and the associated exchanges that
would be grouped with this single exchange according to the rules
of Decision 2004-46, rather than
splitting the exchange with the resulting separate Ottawa and Hull
LIRs. |
48. |
The Commission notes TCC's concerns that
Commission staff's proposed adjustment to Bell Canada's Ottawa and Hull
LIRs would not provide trunking efficiency and simplicity. The
Commission agrees with Bell Canada that there would be little or no
trunking efficiency loss as a result of splitting the traffic exchanged
by LECs in the Ottawa-Hull area given the current volumes of traffic in
that area. |
49. |
The Commission also notes that Bell Canada's
plan to split the Ottawa-Hull exchange into two separate exchanges
is consistent with Decision 2004-55,
and that Bell Canada's proposal to optionally serve the proposed
Hull LIR from the Ottawa POI via Bell Canada-provided facilities
is at no additional charge. The Commission further notes Bell Canada's
stated willingness to negotiate with CLECs to establish additional
POIs in the Hull LIR. In light of the above, the Commission considers
that Bell Canada has satisfactorily addressed TCC's concerns
regarding the proposed separate Ottawa and Hull LIRs. |
50. |
The Commission directs Bell Canada to amend
its proposed Ottawa and Hull LIRs to provide the benefits of competitor
access from a single POI as follows: |
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Bell Canada's proposed Ottawa LIR is to be maintained as is; and
Bell Canada's proposed Hull LIR is to be optionally served at the
connecting LEC's discretion, from the Ottawa POI (OTWAON23 – Ottawa)
via Bell Canada-provided facilities at no additional charge.
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51. |
With respect to MTS Allstream, the
Commission is of the view that the company's proposed LIRs for Melita
and Swan River contain rural communities of low interest to competitors
for local interconnection. Further, the Commission is of the view that
in order to combine the Brandon and Melita LIRs into a single Westman
LIR, and to combine the Dauphin and Swan River LIRs into a single
Parkland LIR as requested by TCC, MTS Allstream would be required to
expand its network infrastructure with little benefit to existing
customers. Accordingly, the Commission considers that when demand for
competitor local interconnection in the rural Melita and Swan River
regions materializes, the requirements for a single POI for each of
Westman and Parkland or alternative arrangements should be revisited. |
52. |
The Commission permits MTS Allstream to
maintain its existing proposed LIRs at this time, with potential
amendments triggered by CLEC demand in rural areas as follows: |
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MTS Allstream's proposed separate LIRs in each of the Westman
(Brandon and Melita LIRs) and Parkland (Dauphin and Swan River LIRs)
regions are to be maintained as is, until CLEC demand materializes in
the Melita or Swan River LIRs; at that time, suitable arrangements to
allow for one POI in each region or alternative arrangements are to be
assessed.
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53. |
The Commission further notes TCC's request
that if the existing MTS Allstream LIRs were maintained, TCC should be
allowed to route toll traffic to MTS Allstream's Melita LIR (via the
Brandon local tandem) and Swan River LIR (via the Dauphin local tandem)
over bill-and-keep trunks prior to the establishment of CLEC demand in
these LIRs. |
54. |
The Commission notes that TCC's request
would permit toll competitors to bypass the payment of toll interconnection
service rates in the Melita and Swan River LIRs. The Commission
further notes that the purpose of revising the local interconnection
regime established in Local competition, Telecom Decision CRTC
97-8, 1 May 1997 (Decision 97-8)
was to promote competition in local services. The Commission also
notes that the primary intention of the LIR interconnection regime
is to provide interconnection for LEC customers within the LIR. The
Commission recognized in Decision 2004-46
that for technical reasons, a CLEC that had established a POI in a
given LIR would be permitted to terminate its toll traffic destined
to that LIR at that POI. The Commission notes that TCC has requested
carriage of toll traffic via bill-and-keep trunks from the POI of
another LIR into an LIR where the CLEC has yet to establish a POI.
The Commission therefore denies TCC's request. However, as noted above,
the Commission will consider consolidating the LIRs in the Westman
region and Parkland region, respectively, or alternative suitable
arrangements, if a CLEC indicates to the Commission and MTS Allstream
that it intends to serve local customers in one of the LIRs within
the region and a POI has already been established by a CLEC in the
other LIR of that region. |
55. |
The Commission notes the CCTA's concerns
that some of Aliant Telecom's and TCC's proposed LIRs were based
on host/remote switch relationships rather than COIs. The Commission
further notes Microcell's examples of TCC-proposed LIRs that did not
follow the directives of Decision 2004-46
to use provincially-defined administrative regions for the specification
of LIR boundaries. The Commission considers that TCC and Aliant Telecom
have followed the rules of Decision 2004-46
in establishing the LIRs for the examples provided by the CCTA and
Microcell. |
56. |
The Commission notes that Xit telecom
provided examples of smaller communities where small entrants faced
inefficiencies and high interconnection costs. Xit telecom noted
that in some scenarios, a CLEC would be forced to connect to multiple
POIs because its serving area would cover multiple LIRs. Xit telecom
submitted that because a CLEC may be interested in serving the particular
COI, rather than the surrounding area covered by the LIRs, the interconnection
costs could make entry into the market uneconomic. The Commission
notes that the proposed LIRs follow the rules specified in Decision
2004-46. The Commission considers
that approaches to provide relief, if any, to CLECs that are targeting
second- or third-tier markets are beyond the scope of this proceeding. |
57. |
The Commission approves the ILECs'
proposed LIRs, as amended to reflect the above noted adjustments of this
Decision. |
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Costing issues
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58. |
The Commission notes that parties to this
proceeding raised issues related to costing methodology, and the
underlying costs of the ILECs' LIR-based traffic termination services.
The Commission's analysis of these issues is provided in the sections
below. |
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Costing methodology
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Positions of parties
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59. |
MTS Allstream submitted that Bell Canada,
Aliant Telecom, and SaskTel changed their costing methodologies for the
LIR-based traffic termination service cost studies in comparison with
their 1997 exchange-based traffic termination service cost studies. More
specifically, MTS Allstream submitted that Bell Canada, Aliant Telecom,
and SaskTel changed the demarcation point between traffic-sensitive
components and traffic-insensitive components resulting in different
costing treatment for the Digital Trunk Controller (DTC)3
and Enhanced Network (ENet)4
interfaces in the LIR-based traffic termination service cost studies.
MTS Allstream asserted that the impact of this change in costing
methodology was to lower the cost of the traffic-insensitive component
between the CLEC and those ILECs and to raise the cost of the
traffic-sensitive portion, resulting in an overall increase in costs for
the service. |
60. |
MTS Allstream submitted that Bell Canada
and Aliant Telecom assumed in their cost studies that all
interconnection traffic passed through a tandem office, thus overstating
costs. MTS Allstream submitted that Bell Canada insisted on the use of
high-usage trunks in the exchange-based regime, and therefore should be
able to incorporate the benefits of high-usage trunking within its cost
study for the LIR-based regime. |
61. |
In reply, Bell Canada and Aliant Telecom
submitted that information relating to the 1997 exchange-based traffic
termination service cost studies was not available and hence they could
not assess whether the demarcation point between traffic-sensitive
components and traffic-insensitive components had changed. |
62. |
SaskTel stated that it was not a party to
the 1997 exchange-based traffic termination service cost study, so it
had not made any changes to its costing methodology. SaskTel submitted
that MTS Allstream had not provided any analysis to prove that
MTS Allstream's approach was superior to SaskTel's approach. |
63. |
Bell Canada, Aliant Telecom, and SaskTel
submitted that the costs for the DTC and ENet components were
traffic-sensitive and had been modelled in this manner in the AT, DC,
and the 2004 LIR-based traffic termination service cost studies.
Bell Canada, Aliant Telecom, and SaskTel further submitted that
MTS Allstream had treated the DTC and ENet as traffic-sensitive
components in its own DC and AT studies, and hence MTS Allstream's
assertion on the appropriate demarcation point between traffic-sensitive
components and traffic-insensitive components was inconsistent with its
own costing methodology. |
64. |
Bell Canada and Aliant Telecom submitted
that LIR traffic could be terminated directly at the office where the
interconnection occurred, through a tandem office to a terminating
office and, if demand warranted it, through high-usage trunks to a
terminating office. Bell Canada and Aliant Telecom further submitted
that the majority of the LIR traffic terminated at the office where the
interconnection with the CLEC occurred. Bell Canada and Aliant Telecom
submitted that it was premature to forecast the extent to which
high-usage trunking would be required, and accordingly had not included
high-usage trunking arrangements in their cost studies. |
|
Commission's analysis and determinations
|
65. |
The Commission notes that Bell Canada,
Aliant Telecom, SaskTel, and MTS Allstream modelled the DTC and ENet as
traffic-sensitive components in their AT and DC cost studies. The
Commission further notes that Bell Canada, Aliant Telecom, and SaskTel
followed the same approach in their LIR-based traffic termination
service cost studies, while MTS Allstream modified its costing
methodology for its LIR-based traffic termination service cost study to
treat the DTC and ENet interfaces as traffic-insensitive components. The
Commission further notes that the AT, DC, and LIR-based traffic
termination services make similar use of the same switching components. |
66. |
The Commission considers that the ILECs'
use of different costing methodologies with respect to DTC and ENet
costs reflect their own networks and provisioning practices, and result
in minimal cost differences. The Commission considers that the
differences in the proposed cost estimates of the LIR-based traffic
termination service across ILECs are acceptable. The Commission further
considers that Bell Canada's, Aliant Telecom's, SaskTel's and
MTS Allstream's costing methodologies are acceptable. |
67. |
With regard to MTS Allstream's assertion
that Bell Canada and Aliant Telecom overstated their costs because they
assumed that all interconnection traffic passes through a tandem office,
the Commission notes Bell Canada and Aliant Telecom's reply that
indicates that most of the traffic passes through a single office and
terminates at that office. The Commission further notes that for the
remaining traffic, Bell Canada and Aliant Telecom's submission indicates
that the remaining traffic is assumed to pass through a tandem office
given the difficulties in forecasting the demands for high-usage
trunking at this time. |
68. |
The Commission notes that the costs for the
LIR-based traffic termination service depend on how much interconnection
traffic is passed through tandem offices, and the decision to use a
tandem switch depends on the traffic volumes between a CLEC and an ILEC,
and on the approach the two parties agree to through negotiations. The
Commission notes that the LIR regime is in its early stages. As such,
the Commission considers that it is difficult to determine the demands
for high-usage trunking, and accordingly, considers that Bell Canada's
and Aliant Telecom's modelling approaches are acceptable. |
|
Costing analysis
|
|
Positions of parties
|
69. |
Bell Canada and Aliant Telecom submitted
that increased costs of switching had resulted in an increase in costs
for LIR-based interconnection as compared to exchange-based
interconnection. |
70. |
The CCTA and Call-Net questioned
Bell Canada's proposed increased rates, and noted that the lower
anticipated transport costs should be passed on to CLECs. The CCTA noted
that SaskTel's proposed reduced rates demonstrated that costs for
LIR-based interconnection could decrease significantly when compared to
the costs for exchange-based interconnection. |
71. |
MTS Allstream questioned the increased
rates proposed by Bell Canada, Aliant Telecom, and TCC, and submitted
that none of these ILECs had provided justification for the increases. |
|
Commission's analysis and determinations
|
72. |
The Commission has conducted a detailed
review of the ILECs' cost studies for the LIR-based traffic termination
service and addresses below the following costing method issues
associated with the ILECs' proposed service costs: |
|
|
|
- equipment life estimates;
|
|
- proposed growth technology costs for switch terminations;
|
|
|
|
|
|
- service provisioning expenses.
|
|
Length of study period
|
73. |
In this proceeding, Bell Canada and
Aliant Telecom used ten-year study periods in determining their proposed
costs for the LIR-based traffic termination service. By contrast, TCC
used a three-year study period, while SaskTel and MTS Allstream used
five-year study periods to develop their proposed service costs. |
74. |
In determining the costs of a particular
Competitor Service, the Commission considers it generally appropriate
to use a common study period across all ILECs to assess these costs.
In the Commission's view, such practice minimizes cost discrepancies
that may arise from differing demand and costing assumptions due to
different study periods. For example, the Commission notes that in
Aliant Telecom, Bell Canada, MTS Allstream, SaskTel
and TCI – Approval of rates on a final basis for Access Tandem service,
Telecom Decision CRTC 2006-22, 27
April 2006 (Decision 2006-22) and
Aliant Telecom, Bell Canada, MTS Allstream, SaskTel
and TCI – Approval of rates on a final basis for Direct Connection
service, Telecom Decision CRTC 2006-23,
27 April 2006 (Decision 2006-23), with
one exception, a five-year study period was used to determine
the costs for the AT and DC services. The Commission further notes
that the AT and DC services are Competitor Services comparable to
the LIR-based traffic termination service. |
75. |
Accordingly, the Commission applies a study
period of five years for each ILEC's cost study for the LIR-based
traffic termination service and adjusts the ILECs' proposed costs as
appropriate. |
|
Equipment life estimates
|
76. |
The Commission notes that Bell Canada and
TCC assumed a three-year life estimate for switching and transmission
system software in their cost studies for the LIR-based traffic
termination service, while all other ILECs used a five-year life
estimate in their cost studies, consistent with the approved accounting
plant life estimates for switching and transmission system software. The
Commission further notes that Bell Canada and TCC did not provide
justification to explain why a three-year life estimate for software
rather than the approved five-year accounting plant life estimate was
necessary. The Commission therefore considers it appropriate to use life
estimates associated with switching and transmission software that are
based on each ILEC's approved accounting lives. |
77. |
Accordingly, the Commission applies a
five-year life estimate for both switching and transmission software,
and adjusts both Bell Canada's and TCC's proposed capital costs for the
LIR-based traffic termination service to reflect these changes in
software life estimates. |
|
Proposed growth technology costs for switch terminations
|
78. |
The Commission notes that in determining
the switching costs for the LIR-based traffic termination service, the
ILECs relied on the DTC and the Spectrum Peripheral Module (SPM) trunk
termination technologies. The Commission notes that TCC and
Aliant Telecom-NL relied on the exclusive use of SPM technology, while
Aliant Telecom-PEI, SaskTel, and MTS Allstream relied on the exclusive
use of DTC technology, and Bell Canada and the other Aliant Telecom
regions relied on a mix of the DTC and SPM technologies for the
estimation of trunk termination capital costs. |
79. |
The Commission notes that the SPM is a
newer technology that has or is expected to replace the DTC technology.
The Commission notes that for Bell Canada and Aliant Telecom,
the resource unit costs for the SPM are higher than the resource unit
costs for the DTC. The Commission also notes that, in Decisions 2006-22
and 2006-23, the Commission noted the
increased capacity of the SPM and determined that the trunk termination
unit costs should not have increased, and accordingly adjusted the
trunk termination unit costs of the ILECs that had proposed the use
of SPM or a mix of DTC and SPM to those based on the exclusive use
of DTC as the least-cost trunk termination technology. The Commission
further notes the similarities of the AT, DC, and LIR-based traffic
termination services, and the similar application of the DTC and SPM
technologies for those services. In light of the above, the Commission
considers that the trunk termination capital costs reflected in the
switching capital costs in the LIR-based interconnection cost studies
of Aliant Telecom-NL, Aliant Telecom-NS, Aliant Telecom-NB,
Bell Canada, and TCC are not appropriate. |
80. |
Accordingly, the Commission adjusts the
switching capital costs of the LIR-based traffic termination service
proposed by Aliant Telecom-NL, Aliant Telecom-NS, Aliant Telecom-NB,
Bell Canada, and TCC to reflect the exclusive use of DTC as the growth
technology for the estimation of trunk termination capital costs. The
Commission considers that a comparable adjustment is not required for
Aliant Telecom-PEI, SaskTel, and MTS Allstream. |
|
Maintenance expenses
|
81. |
The Commission has compared the ILECs'
monthly maintenance expenses. As the maintenance expense relates to
comparable activities undertaken by all ILECs, the Commission considers
that significant differences in these estimates among ILECs, as
expressed on a per-centum call second (CCS) traffic unit basis and as
a percentage of capital, are not appropriate. |
82. |
In light of the significant differences
across the ILECs' maintenance expense estimates, the Commission considers
it appropriate to apply a maintenance expense cap expressed as a percentage
of the present worth of annual capital costs to ensure that maintenance
expenses are reasonable. The Commission notes that this approach is
consistent with the approach adopted in Competitor Digital Network
Services, Telecom Decision CRTC 2005-6,
3 February 2005, Decision 2006-22, and
Decision 2006-23 where the proposed maintenance
expenses of certain ILECs were considered inappropriate and were capped
at a percentage level of the associated capital costs. |
83. |
The Commission notes that TCC's and SaskTel's
proposed maintenance expense estimates, when expressed as a percentage
of capital costs, were significantly greater than those of other ILECs.
The Commission notes that excluding TCC and SaskTel, the ILECs' maintenance
expense estimates, when expressed as a percentage of capital
costs, varied from 4.6 to 10.6 percent, with an average value
of 7.9 percent. The Commission considers that a maintenance expense
cap equal to an average maintenance expense level of 7.5 percent
of the present worth of capital costs would represent an appropriate
maximum level of maintenance expenses for all ILECs. The Commission
notes that it has applied the same maintenance expense cap in Decision
2006-22 and Decision 2006-23
for the comparable AT and DC services. |
84. |
Accordingly, in respect of each ILEC's
LIR-based traffic termination service, the Commission applies a
maintenance expense cap of 7.5 percent of the present worth of capital
costs. |
|
Portfolio expenses
|
85. |
The Commission notes that Bell Canada,
Aliant Telecom, MTS Allstream, and SaskTel have been required
to estimate and include portfolio expenses in their cost studies through
the use of portfolio expense factors as set out in Primary
inter-exchange carrier processing charges review, Telecom Decision
CRTC 2004-72, 9 November 2004
(Decision 2004-72). The Commission
notes that in this proceeding, these ILECs applied the following approved
portfolio expense factors to their respective Phase II expenses:
3.6 percent for Bell Canada and Aliant Telecom,
1.78 percent for MTS Allstream, and 8.25 percent for
SaskTel. |
86. |
The Commission notes that Decision 2004-72
did not require TCC to use a portfolio expense factor, as TCC included
portfolio expenses as part of its direct and indirect expenses under
each expense line item. However, in this proceeding, TCC's proposed
portfolio expenses were determined based on the application of a portfolio
expense factor and were provided separately under the line item expenses
causal to demand – Other. The Commission notes that this constitutes
a change in costing methodology by comparison with previous Competitor
Services cost studies. The Commission further notes that TCC's portfolio
expenses were many times greater than the portfolio expenses of any
other ILEC in this proceeding. The Commission is of the view that
TCC did not adequately justify the level of its proposed portfolio
expenses. The Commission therefore considers that it would be appropriate
to adjust the level of portfolio expenses proposed by TCC in this
proceeding. |
87. |
The Commission notes that in the context
of the Commission's ongoing general review of ILEC Phase II costing
information requirements, TCC estimated an average portfolio expense
factor of 48.65 percent.5
The Commission therefore considers it appropriate to determine TCC's
portfolio expenses for the LIR-based traffic termination service by
applying a portfolio expense factor of 48.65 percent to TCC's
expenses. The Commission notes that it applied this portfolio expense
factor in Decision 2006-23 in determining
the portfolio expenses for the DC service, which is comparable to
the LIR-based traffic termination service. |
|
Service provisioning expenses
|
88. |
The Commission notes that for the LIR-based
traffic termination service, the proposed service provisioning monthly
equivalent costs (MECs) for each of the four Aliant Telecom regions were
significantly higher than the proposed service provisioning MECs of all
other ILECs. Given that these expenses relate to comparable activities
within each ILEC, the Commission is concerned over the significant
differences in the service provisioning costs between Aliant Telecom and
the other ILECs. |
89. |
The Commission notes that in Decision 2006-23
where DC service rates were finalized, the service provisioning costs
of Aliant Telecom's four regions and most other ILECs were similar
in magnitude and were accepted by the Commission. The Commission considers
that the DC and LIR-based traffic termination services have similar
service provisioning requirements. In light of the above, the Commission
considers that Aliant Telecom's costs associated with the service
provisioning activities of the LIR-based traffic termination service
are not acceptable. |
90. |
The Commission notes that because of
differences in practices across ILECs, the costs for similar activities
will not always be the same. Accordingly, the Commission adjusts
Aliant Telecom's costs for service provisioning for the LIR-based
traffic termination service for each of its regions to values that are
set based on the highest proposed service provisioning cost estimates of
any other ILEC for these activities. |
|
Final rates and related issues
|
91. |
The Commission notes that parties raised
several issues with respect to rate harmonization and consolidation, the
rates and the rate structure proposed by the ILECs for their LIR-based
traffic termination services. The Commission's analysis of these issues
is provided in the sections below. |
|
Rate harmonization and consolidation
|
|
Positions of parties
|
92. |
Bell Canada submitted that its proposed
traffic termination service rates should apply to both LIR-based
interconnection and exchange-based interconnection regimes, in order to
minimize costs associated with administering the imbalance mechanism for
both Bell Canada and competitors. |
93. |
TCC provided a single cost study and
proposed traffic termination service rates across both TCC-AB and TCC-BC
territories, based on the blended costs for exchange-based and LIR-based
interconnection. TCC submitted that a common set of rates would be
administratively simpler for both CLECs and TCC. In addition, TCC
submitted that the use of a common set of rates based on current costs
would neither artificially encourage nor discourage migration from the
exchange-based interconnection regime to the LIR-based interconnection
regime. |
94. |
The CCTA, Microcell, Rogers, and
MTS Allstream objected to TCC's use of consolidated traffic termination
service rates in the territories of TCC-AB and TCC-BC. MTS Allstream
submitted that TCC should demonstrate that the costs for LIR-based
interconnection in TCC-AB and TCC-BC territories were sufficiently
similar to justify unifying the rates. The CCTA submitted that the
underlying costs for the exchange-based interconnection for TCC-AB and
TCC-BC differed, and that TCC had not demonstrated that the costs for
its two territories had changed in its latest cost study for LIR-based
interconnection. Microcell submitted that more detailed cost studies
would be required before the Commission could decide on the
appropriateness of TCC's consolidated rates. |
95. |
QMI requested that all ILECs provide a
harmonized set of traffic termination service rates for exchange-based
interconnection and LIR-based interconnection regimes. QMI was of the
view that rate harmonization would simplify billing procedures and
remove any incentives for CLECs to choose one interconnection
architecture over the other. Call-Net supported the harmonized set of
rates across all ILECs. |
|
Commission's analysis and determinations
|
96. |
The Commission notes the CCTA's,
Microcell's, Rogers' and MTS Allstream's concerns relating to
consolidated traffic termination service rates for TCC-AB and TCC-BC.
The Commission notes that the LIR-based traffic termination service
costs for TCC-AB and TCC-BC differ from the blended costs for the
aggregate of TCC-AB and TCC-BC by only 0.22 and 0.29 percent,
respectively. The Commission considers that the costs for the LIR-based
traffic termination service and the proposed rates that are directly
related to the costs of each of TCC-AB and TCC-BC are sufficiently
similar to support TCC's request for a single set of traffic termination
service rates for LIR-based interconnection for the aggregate of TCC-AB
and TCC-BC. Accordingly, the Commission approves a single set of
traffic termination service rates for LIR-based interconnection that are
applicable to both TCC-AB and TCC-BC. |
97. |
The Commission notes that QMI and Call-Net
requested harmonized rates for LIR-based interconnection and
exchange-based interconnection across all ILECs and that both TCC and
Bell Canada proposed harmonized rates in their applications. |
98. |
The Commission notes that it determined in
Decision 2004-46 that the exchange-based
regime was grandfathered, with existing exchange-based traffic termination
service rates available to CLECs with existing exchange-based arrangements. |
99. |
The Commission considers that the requests
to combine the rates for the LIR-based traffic termination service and
the rates for the grandfathered exchange-based traffic termination
service are beyond the scope of this proceeding. Accordingly, the ILECs
are to include in their tariffs, rates for the LIR-based traffic
termination service while maintaining the existing rates for the
exchange-based traffic termination service for CLECs with grandfathered
exchange-based interconnection arrangements. |
|
Rate structure for the LIR-based traffic termination service
|
|
Positions of parties
|
100. |
Bell Canada, Aliant Telecom, and SaskTel
proposed restructured tariffs with per-trunk rates for the LIR-based
traffic termination service having traffic imbalance levels set at
10 percent intervals. Bell Canada submitted that this modified rate
structure was more appropriate for cost recovery and eliminated or
reduced potential gaming opportunities that resulted from a LEC's
ability to manipulate the traffic that was carried on the shared
bill-and-keep trunks. Bell Canada and Aliant Telecom submitted that the
ability to route terminating toll traffic onto the shared bill-and-keep
trunks could be manipulated by a LEC. |
101. |
Microcell and QMI agreed with Bell Canada's
proposal to use rate elements based on 10 percent traffic imbalance
increments and recommended that the proposal be adopted by the other
ILECs. |
102. |
MTS Allstream submitted that since no
parties raised issues associated with the rate structure in the proceeding
leading to Decision 2004-46, no
change to the rate structure was made in that decision. MTS Allstream
further submitted that Bell Canada did not provide evidence on
whether its proposal was justified based on costs of the new billing
and traffic measurement requirements that would have to be implemented
by CLECs and ILECs, and that it would result in reduced flexibility
and new billing and traffic measurement complexities and costs. |
103. |
The CCTA stated that the changes to the
rate structure would increase costs to LECs with no identifiable
benefits being achieved. |
|
Commission's analysis and determinations
|
104. |
The Commission notes that the restructuring
of the traffic imbalance increments from 20 to 10 percent would require
modifications in LEC traffic measurement and billing processes, with a
potential to increase the associated measurement and billing costs. The
Commission further notes that in this proceeding, three of the five
ILECs, along with Microcell and QMI, considered that the proposed
refinements to the rate structure were appropriate. The Commission
considers that the changes required to support the restructuring of the
traffic imbalance increments would not be excessive. |
105. |
In light of the increased flexibility in
routing of toll traffic and the need to ensure that ILECs are adequately
compensated for the termination of toll traffic, the Commission
considers it appropriate to establish more refined traffic imbalance
increments for the purpose of measuring and billing for the traffic
imbalances associated with bill-and-keep trunks. |
106. |
In light of the above, the Commission
approves, for each ILEC, a change in rate structure of the traffic
termination service under the LIR regime to include 10 percent traffic
imbalance increments in place of the 20 percent traffic imbalance
increments currently used in the existing rate structure under the
exchange-based regime. |
|
Settling-in period and traffic imbalance measurement period
|
|
Positions of parties
|
107. |
TCC proposed to amend its tariffs for the
LIR-based traffic termination service by removing the six-month
settling-in period and the subsequent three-month traffic imbalance
measurement period. TCC submitted that because of a CLEC's ability to
terminate toll traffic over bill-and-keep trunks rather than through the
DC service, a CLEC could easily change traffic levels on bill-and-keep
trunks, invalidating the assumptions that led to the existing six-month
settling-in period and the three-month traffic imbalance measurement
period. TCC further submitted that removal of the six-month and
three-month periods would ensure proper compensation for termination of
toll traffic and would also avoid the market distortion that would be
created. |
108. |
Bell Canada, Aliant Telecom, and SaskTel
submitted that the TCC proposal to eliminate the current six-month
settling-in period and the three-month traffic imbalance measurement
period had merit in order to minimize gaming opportunities. |
109. |
MTS Allstream submitted that the six-month
settling-in period and the three-month traffic imbalance measurement
period should be maintained because the original reasons for instituting
these periods were still valid. MTS Allstream further submitted that
TCC's claims regarding potential market distortions were exaggerated. |
110. |
The CCTA requested that the Commission
reject TCC's proposal to eliminate the six-month and three-month allowances
in the rating mechanism for mutual compensation. The CCTA noted that
no party to the proceeding leading to Decision 2004-46
proposed changes to the rating mechanism. The CCTA submitted that
a new CLEC would encounter many of the problems in establishing appropriate
volumes of interconnecting trunks as initially contemplated in Telecom
Order CRTC 98-1190, 30
November 1998. |
111. |
QMI requested that the Commission remove
the six-month settling-in period and the subsequent three-month traffic
imbalance measurement period. |
112. |
Rogers requested that the Commission
confirm that the nine-month period would apply only once, i.e., after a
CLEC initially deployed in a new exchange or LIR. Rogers further
requested that the Commission confirm that the three-month traffic
imbalance measurement period would not be required after the mutual
compensation regime was put in place. |
113. |
TCC submitted that a commercial launch in
an LIR should be the date at which the CLEC notified the Commission that
it had met all CLEC obligations in one of the exchanges in the LIR, not
the date at which it connected its first customer, causing bill-and-keep
traffic to occur. TCC submitted that traffic imbalance payments should
be due from the date that a CLEC entered its first exchange in an LIR
because it would be able to terminate bill-and-keep traffic to all ILEC
customers within that LIR at that time. |
|
Commission's analysis and determinations
|
114. |
The Commission notes that contrary to the
previous exchange-based interconnection regime as described in Decision
97-8, the new LIR-based interconnection
regime permits terminating toll traffic to be routed through the bill-and-keep
trunks used for the LIR-based traffic termination service. |
115. |
The Commission notes that the ability of a
CLEC to direct toll terminating traffic onto bill-and-keep trunks under
the LIR-based regime will allow bypass of the AT and DC toll
interconnection services. Under the current interim LIR-based regime,
when a CLEC establishes interconnection in an LIR, the ILEC is not
compensated for toll-terminating traffic from the CLEC for up to a
nine-month period. After nine months, the ILEC may then be eligible to
receive compensation through the interim tariffs for the LIR-based
traffic termination service as determined by the traffic imbalance on
the interconnecting bill-and-keep trunks. |
116. |
The Commission further notes that when toll
traffic is terminated through the AT and DC services, the ILEC is
permitted to measure and bill for this traffic as soon as the service is
established with an inter-exchange carrier. The Commission notes that
similar technologies are used to provide the AT and DC services and the
LIR-based traffic termination service. |
117. |
The Commission considers that the ILECs
should receive equitable compensation for termination of toll traffic
regardless of whether the toll traffic is terminated by the AT and DC
services or by the LIR-based traffic termination service through
bill-and-keep trunks. The Commission further notes that most CLECs are
seasoned competitors with established capabilities to implement traffic
measurements that rapidly produce reliable results. Accordingly, the
Commission approves the removal of the six-month settling-in
period and the subsequent three-month traffic imbalance measurement
period from the tariffs for the LIR-based traffic termination service. |
118. |
The Commission notes that a CLEC has the
ability to direct toll-terminating traffic onto the bill-and-keep trunks
even though the CLEC has no local customers within an LIR. Accordingly,
the Commission considers it appropriate to set the date of commercial
launch in an LIR as the date at which the CLEC notifies the Commission
that it has met all CLEC obligations in one of the exchanges in the LIR
and at which point the traffic imbalance measurements could begin. |
|
Final rates
|
119. |
The Commission notes that the LIR-based
traffic termination service is classified as a Category I Competitor
Service with rates based on its Phase II costs, plus a mark-up of
15 percent. The Commission has therefore established the rates for the
LIR-based traffic termination service based on the ILECs' proposed cost
studies, as amended to reflect the cost adjustments in this Decision,
plus a mark-up of 15 percent. |
120. |
The Commission approves on a final basis
the rates for the LIR-based traffic termination service set out
in the Appendix to this Decision for each ILEC, effective the date
of this Decision. Consistent with Regulatory framework for second
price cap period, Telecom Decision CRTC 2002-34,
30 May 2002, the Commission finds that the applicable inflation minus
productivity offset (I-X) constraints are to be applied for 2006 and
each year thereafter. In addition, the Commission caps the CLECs'
rates for the LIR-based traffic termination service at the ILECs'
rates for the service. The Commission directs each CLEC to file proposed
corresponding tariff amendments as required, within 60 days of the
date of this Decision. |
|
HUA for trunking arrangements
|
|
Positions of parties
|
121. |
Call-Net, Microcell, QMI, and the CCTA
submitted that an HUA for trunk interconnection, with separate dedicated
trunk groups to individual exchanges within an LIR, should not be
imposed or mandated by the ILECs. |
122. |
Call-Net and Microcell submitted that
separate trunk groups were appropriate for high traffic volumes. Rogers,
supported by QMI, submitted that a CLEC should be able to decide if
separate trunk groups to exchanges were required, or to direct the ILECs
to demonstrate to the Commission's satisfaction that the use of separate
trunk groups to exchanges would be efficient. Microcell submitted that a
CLEC should have the capability to choose the most efficient trunking
architecture by which it would interconnect with the ILEC. |
123. |
Call-Net submitted that the development of
alternative agreements with ILECs based on bilateral agreements rarely
led to mutually agreeable solutions. |
124. |
In its comments dated 12 October 2004,
Bell Canada submitted that trunking arrangements for the termination of
intra-LIR traffic, delivery of traffic within EAS areas, and local
transit would continue to be established for each ILEC exchange within
an LIR. Bell Canada submitted that the trunking would use the
shared-cost facility between the CLEC and Bell Canada. |
125. |
In its comments dated 14 January 2005,
Bell Canada subsequently submitted that if traffic volumes were low, it
would consider alternative routing arrangements based on bilateral
discussions. Bell Canada proposed to establish a shared single
bill-and-keep trunk group serving multiple exchanges within the LIR
where traffic levels were low, and to establish a dedicated high-usage
trunk group to a particular exchange/switch where traffic levels to that
exchange/switch exceeded the traffic capacity of a DS-1. |
126. |
TCC proposed the use of generally
understood industry norms for establishing efficient trunk
interconnection between LECs using a cost-effective mix of high-usage
trunking and tandem switching arrangements. TCC submitted that this
approach would meet needs of both a CLEC and an ILEC where there existed
multiple switches within an LIR that required traffic interchange. TCC
further submitted that neither LEC should unreasonably refuse a request
from the other LEC for a particular trunking arrangement. |
127. |
TCC submitted that the CLECs' proposal
regarding dedicated high-usage trunking would give CLECs the ability to
force ILECs to incur excessive tandeming costs without similar cost
obligations being borne by CLECs. |
128. |
MTS Allstream submitted that an HUA could
be efficient, but should only be put in place when mutually agreed upon
between the CLEC and the ILEC. |
129. |
MTS Allstream disagreed with Bell Canada's
proposal to use a threshold requirement of a single DS-1 to trigger the
use of an HUA because the use of this threshold was not necessarily
efficient, and shifted the cost of implementation to the CLEC.
MTS Allstream submitted that HUA trunking agreements should be optional
but, if mandated, a threshold equivalent to two DS-1s of traffic would
be appropriate for triggering HUA trunking in conjunction with
capabilities to overflow through tandem switches. |
|
Commission's analysis and determinations
|
130. |
The Commission notes that the ILECs have
agreed to negotiate with CLECs efficient interconnection configurations
that reflect an appropriate mix of dedicated and shared trunking. The
Commission further notes the competitors' concerns over their inability
to influence the ILECs to provide the configurations that they want, and
the need for the Commission to give them control to accept or reject
specific ILEC proposals. |
131. |
The Commission considers that both the
ILECs and competitors are aware of the industry principles for
specifying the appropriate efficient interconnection configurations for
shared trunking and/or dedicated high-usage trunking for a particular
network situation. Accordingly, the Commission directs ILECs and CLECs
to resolve trunking issues through bilateral negotiations, applying the
generally accepted industry principles for establishing efficient trunk
interconnection configurations. In the event that parties cannot arrive
at a mutually acceptable negotiated solution, the parties may consult
with the Commission for direction. |
|
Trunking arrangements for EAS transport and transit services
|
|
Positions of parties
|
132. |
QMI submitted that the termination coverage
area of an EAS transport or transit service provisioned within a
particular LIR should encompass all EAS areas for each of the exchanges
within that LIR. QMI submitted that under this configuration, a single
EAS transport or transit trunk group between the CLEC POI and the ILEC
POI would be required to serve all EAS exchanges external to an LIR that
had EAS relationships with exchanges within the particular LIR. |
133. |
Bell Canada submitted that one EAS
transport trunk group should be required for each exchange within an LIR
that had EAS exchanges associated with it. Under Bell Canada's
submission, the EAS transport trunk group would support EAS traffic
between the specific exchange and all of its associated EAS exchanges.
Bell Canada and Aliant Telecom proposed that EAS transport trunking
could be optionally used, instead of bill-and-keep trunks, for
associated EAS exchanges that were located within the LIR. |
134. |
Microcell also proposed an EAS
interconnection configuration that, in its view, would provide trunking
efficiencies when exchanges within an LIR had EAS relationships with
common exchanges external to the LIR. Microcell provided an example in
which one exchange within an LIR had EAS relationships with three
exchanges external to that LIR, and a second exchange within the LIR had
EAS relationships with the same three exchanges external to the LIR.
Microcell submitted that for this example, a CLEC should require an EAS
transport trunk group to only one of the exchanges in the LIR to access
the external EAS exchanges. In Microcell's example, for situations in
which there was no overlap of the EAS exchanges associated with
exchanges within the LIR, Microcell's configuration would be the same as
that proposed by Bell Canada. |
135. |
MTS Allstream supported QMI's proposal that
the termination area of an EAS transport trunk group within an LIR
should include all EAS exchanges for each of the exchanges in the LIR. |
136. |
TCC disagreed with QMI's proposal to
require only one EAS transport or transit trunk group per LIR. |
137. |
TCC submitted that it would continue to
accept CLEC calls to TCC customers in exchanges that fell within both an
EAS area and the LIR on either EAS transport trunks or bill-and-keep
trunks. |
138. |
QMI and Microcell both submitted, and
MTS Allstream agreed, that there should be no call origination
restrictions on traffic carried on EAS transport and transit trunk
groups. |
|
Commission's analysis and determinations
|
139. |
In Decision 2004-46,
the Commission stated that there were continuing requirements for
EAS transport services and for transit services. The Commission notes
that the consolidation of exchanges into LIRs may modify a CLEC's
requirements for EAS transport and transit services in a particular
region, and may cause changes to that CLEC's trunking arrangements. |
140. |
The Commission notes that parties proposed
several trunking arrangements for supporting the EAS transport service
and transit services. QMI proposed the use of a single EAS transport
trunk group and a single transit trunk group per LIR, to serve all
exchanges outside of an LIR that had EAS relationships with exchanges
inside the LIR. For the EAS transport service, Bell Canada proposed the
use of an EAS trunk group to each exchange within an LIR that had EAS
relationships with other exchanges outside the LIR. In Bell Canada's
proposal, each EAS trunk group could carry traffic to the exchanges
having EAS relationships with a particular exchange within the LIR.
Microcell proposed a similar approach that could require fewer trunks or
trunk groups than Bell Canada's proposal. |
141. |
The Commission considers it appropriate to
permit the ILECs to provide a separate EAS transport trunk group for
each exchange within an LIR that has EAS relationships with exchanges
external to that LIR. The Commission further considers that if several
exchanges within an LIR have EAS relationships with common exchanges
outside of the LIR, then ILECs should allow a competitor to interconnect
to any of these common exchanges outside of the LIR through only one EAS
transport trunk group. |
142. |
The Commission considers that if an ILEC
supports CLEC interconnection by means of the EAS transport service to
exchanges that are within a multi-exchange LIR and that are within the
EAS area of another exchange within the LIR, then CLECs can optionally
use the EAS transport service rather than bill-and-keep trunks for this
intra-LIR interconnection. |
143. |
The Commission notes that in the LIR-based
interconnection regime, the transit service coverage includes the entire
LIR and exchanges outside of the LIR that have EAS relationships with
exchanges within the LIR. In this case, ILECs are to provide one transit
service trunk group to interconnect a CLEC to a second CLEC operating in
the same LIR for carriage of traffic within that LIR. Where two CLECs
are operating in different LIRs, the Commission considers it appropriate
that ILECs provide a transit service trunk group to carry a CLEC's
traffic originating at an exchange within an LIR to the second CLEC's
customers in exchanges within the second LIR that have EAS relationships
with the originating exchange. |
144. |
The Commission considers further that LECs
should not be precluded from entering into other EAS transport and
transit trunking arrangements that result in increased networking
efficiencies. In particular, the Commission generally considers
consolidation of trunk groups for the purpose of interconnection to be
appropriate. |
145. |
The Commission notes that several parties
requested that CLECs be allowed to direct terminating toll traffic to be
carried on the EAS transport service and on the transit service, if the
toll traffic was brought to the CLEC POI. These parties were of the view
that because the Commission had allowed toll traffic to be terminated
through the LIR-based traffic termination service if the CLEC had
brought the traffic to the POI, the same principle should apply to EAS
transport and transit services. |
146. |
The Commission considers that if a CLEC
brings toll traffic to the POI in an LIR, the carriage of terminating
toll traffic by the CLEC on the EAS transport service and on the transit
service is similar in principle to the capability of carrying
terminating toll traffic on the LIR-based traffic termination service
through bill-and-keep trunks. The Commission notes that it is difficult
to monitor whether traffic includes or excludes toll calls. With the
growth of carriage of voice traffic over Internet protocol networks, the
capability to distinguish whether a call is a toll call becomes
increasingly difficult. |
147. |
The Commission notes that the EAS transport
service and the transit service are Category I Competitor Services for
which ILECs receive compensation depending on the corresponding service
rates, based on their respective Phase II costs plus a 15 percent
mark-up, and the quantities of trunks provisioned (based on the traffic
volumes carried on them). The Commission further notes that the Phase II
costs of the EAS transport and transit services would not be materially
different whether traffic includes or excludes toll traffic that
has been transported to the POI. |
148. |
In light of the above, the Commission
determines that CLECs are permitted to use the EAS transport and transit
service to carry toll terminating traffic, provided that the CLEC has
brought the toll traffic to its POI. |
149. |
The Commission further notes that the Phase II
costs of the EAS transport and transit services may change because
of the implementation of trunking arrangements for the LIR regime.
In Decision 2004-46, the Commission
allowed the ILECs to submit new cost studies for EAS transport and
transit services if the Phase II costs were expected to change
as a result of the implementation of the LIR regime. Accordingly,
the Commission permits the ILECs to file revised cost studies and
associated tariffs for each of the EAS transport service and the transit
service if an ILEC considers that the changes in the associated Phase II
costs warrant it. |
|
Evolution from the exchange-based regime to the LIR-based regime
|
|
Positions of parties
|
150. |
Call-Net submitted that the ILEC tariffs
should clearly specify whether competitors could continue to use the
exchange-based interconnection regime based on grandfathered
arrangements. In addition, Call-Net submitted that the tariffs should
state that CLECs could migrate from the grandfathered regime to the new
LIR regime without penalty. |
151. |
MTS Allstream submitted that the
designation of an ILEC's default POI should not preclude establishment
of POIs in different exchanges for serving an LIR. MTS Allstream argued
that this approach supported CLECs with an established POI that was not
in the exchange of the ILEC's default POI of the new LIR. MTS Allstream
submitted that CLECs should not be penalized for having constructed POIs
under the former exchange-based regime and being forced to build
additional POIs or to move existing POIs. |
152. |
Microcell submitted that a CLEC should
have the option of connecting at individual exchanges. Microcell submitted
that for an LIR consisting of multiple exchanges, a CLEC might wish
to serve a subset of the exchanges within the LIR. Microcell submitted
that in this situation, the economics of connecting at a distant POI
could be unfavourable. Microcell submitted that the ILEC tariff pages
should be revised to permit two sets of interconnection arrangements
to co-exist and be made available to CLECs. In support of its claim,
Microcell noted that paragraph 75 of Decision 2004-46
set out that existing POIs should remain in place until such time
as a CLEC wished to alter them, and that paragraph 108 of Decision
2004-46 set out that both
LIR-based and exchange-based interconnection regimes should continue
to be offered in parallel. |
153. |
Bell Canada and Aliant Telecom submitted
that it would be inappropriate for CLECs to migrate to the new regime
without paying penalties for violating tariff terms or conditions
associated with the early termination of leases. TCC also submitted that
the waiving of termination fees for migrating from the exchange-based
regime to the LIR-based regime was not appropriate. |
154. |
Bell Canada, Aliant Telecom,
and SaskTel submitted that MTS Allstream's proposal to allow
a CLEC to establish the LIR's POI in the exchange of an LIR where
a CLEC may already have a POI should be rejected because the Commission
had grandfathered the existing exchange-based POIs in Decision 2004-46.
These ILECs argued that this proposal to allow the establishment of
alternate POIs based on a CLEC's best interests would be counter to
Decision 2004-46. |
155. |
Bell Canada submitted that there should be
a minimum of one joint-build interconnection facility per LIR with the
design of the interconnection facility and cost-sharing arrangements
negotiated on a case-by-case basis. Bell Canada submitted that it was
willing to continue to consider the use of existing facilities on a
case-by-case basis. |
156. |
Rogers requested that the Commission affirm
a CLEC's right to use existing interconnection arrangements for the
purpose of interconnecting to an LIR, pursuant to Decision 2004-46. |
157. |
TCC submitted that facilities used for LIR-based
interconnection should be determined through negotiations between
LECs, regardless of whether a CLEC was currently interconnected in
any exchange within a given LIR. TCC was of the view that Decision
2004-46 did not give a LEC the
right to unilaterally reject continued use of existing facilities
and it did not give a CLEC the right to insist that currently used
facilities should be the default for LIR-based interconnection. TCC
further submitted that the designation of a default POI in an LIR
should not preclude the establishment by a CLEC of a POI in different
exchanges for the purposes of serving the LIR. |
158. |
MTS Allstream submitted that these types of
negotiations between an ILEC and a CLEC would leave a CLEC at a
disadvantage. MTS Allstream submitted that a CLEC should have the option
of using an existing POI to serve an LIR even if it was located outside
of the ILEC's default POI exchange, unless the ILEC could demonstrate to
the Commission that it was not feasible. |
|
Commission's analysis and determinations
|
159. |
In Decision 2004-46,
the Commission grandfathered the exchange-based interconnection regime,
allowing CLECs to maintain existing exchange-based interconnection
arrangements. The Commission notes that the grandfathering arrangements
applied to CLECs with existing arrangements but did not apply to new
entrants desiring exchange-based entry. The Commission notes that
a new entrant (a CLEC having no presence in any of the exchanges within
an LIR) would be governed by the LIR regime where the LIR-based interconnection
arrangement would occur at the designated POI of the LIR. Accordingly,
the Commission rejects Microcell's request to have the exchange-based
interconnection regime available to CLECs as an alternative to the
LIR-based interconnection regime. |
160. |
The Commission notes that a CLEC with
existing exchange-based interconnection arrangements could be providing
service in a specific exchange that has been included in a
multi-exchange LIR. If the CLEC decides to expand its service to other
exchanges within the LIR, the CLEC would have to interconnect at an
appropriate POI that provides interconnection to all exchanges within
the LIR for the CLEC's expanded service. At the same time, the
Commission considers that the CLEC would be able to maintain its
existing POI at the original exchange until the CLEC wishes to migrate
to the LIR's designated POI. In this situation, the CLEC would be
operating in the exchange-based interconnection regime for one of the
exchanges in the LIR, and in the LIR-based interconnection regime for
the rest of the LIR. |
161. |
The Commission notes MTS Allstream's
concern that CLECs that have constructed POIs under the exchange-based
interconnection regime could be forced to build additional POIs or move
existing POIs if the ILEC's designated POI under the LIR regime was not
in the same exchange as the CLEC's existing POI. |
162. |
The Commission further notes TCC's proposal
for bilateral negotiations between LECs to determine the location of the
default POI and, if necessary, alternative POIs within each LIR. The
Commission considers that CLECs are disadvantaged in these types of
negotiations. Accordingly, the Commission allows a CLEC to use an
existing POI even if it is outside of the default POI exchange of the
LIR, unless the ILEC can demonstrate to the Commission that the
arrangement is not feasible. |
163. |
The Commission notes Call-Net's request to
include language in the tariffs to allow a CLEC to migrate from the
grandfathered exchange-based regime to the LIR-based regime without
penalties. The Commission notes that when a CLEC is operating under the
exchange-based regime, it has in place an agreement for interconnection
with the ILEC that sets out the terms and conditions for early
termination of the agreement, and includes a process for modifying the
interconnection agreement. The Commission further notes the complex and
numerous ILEC activities associated with interconnection rearrangements.
The Commission considers that when a CLEC is planning to migrate from
the exchange-based regime to the LIR-based regime, it must respect the
terms and conditions and the modification process set out in its
existing interconnection agreement with the ILEC. Accordingly, the
Commission rejects Call-Net's request. |
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POI diversity
|
|
Positions of parties
|
164. |
The CCTA expressed concern that Bell Canada
would not provide shared-cost diversity when requested by a CLEC. The
CCTA submitted that bilateral discussions should not be necessary to
establish POI diversity in an LIR. |
165. |
Shaw expressed a need to clearly specify
what POI diversity supported in terms of cost sharing, capacity, and
impacts of failures. |
166. |
Microcell submitted that the Commission did
not specify in Decision 2004-46
whether POI diversity was mandated within an LIR or within the
exchange where the Gateway POI (ILEC local tandem) was located. Microcell
submitted that both scenarios should be available, and that a
CLEC should have the right to keep two or more existing POIs located
in diverse exchanges or not. |
|
Commission's analysis and determinations
|
167. |
The Commission directives regarding the establishment
of POI diversity in the LIR regime are set out in paragraphs
125 and 126 of Decision 2004-46
as follows: |
|
Paragraph 125: "…, 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." |
|
Paragraph 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." |
168. |
In Decision 2004-46,
the Commission did not make any determinations as to which party could
dictate the site for a diverse POI and whether a CLEC could retain
existing POIs established under the exchange-based regime for diversity.
Accordingly, the Commission directs LECs to pursue negotiations in
determining the need for POI diversity within an LIR and in determining
the appropriate site for the second POI. In the event that parties
cannot arrive at a mutually acceptable negotiated solution, the parties
may consult with the Commission for direction. |
|
Cost sharing for joint-build facilities
|
|
Positions of parties
|
169. |
Call-Net submitted that where competitors
were not building facilities to support interconnection of their POI
with the ILEC's POI, they should be able to lease the facility from the
ILEC at half the tariffed rate because both parties were obligated to
share this cost. |
170. |
Bell Canada submitted that each party was
responsible for bearing an equal share of the costs of interconnection
facilities and that a CLEC could lease facilities from an ILEC or third
party, build its own facilities, or share in a joint-build of facilities
with the ILEC. Bell Canada further submitted that if a CLEC leased from
a third party, it would not expect the third party to reduce its rates
to the CLEC by 50 percent, and hence there was no reason for an ILEC to
reduce its rates by 50 percent if a CLEC leased facilities from it. |
|
Commission's analysis and determination
|
171. |
The Commission determines that if a
competitor chooses to lease its facilities from an ILEC, the existing
full rates for the associated facility or Competitor Service should
apply. |
|
SPOI interconnection arrangements
|
|
Positions of parties
|
172. |
The CCTA submitted that with respect to
Aliant Telecom's proposed A-Link interconnection service, Aliant Telecom
was using Bell Canada's CCS7 A-Link service at Bell Canada's Competitor
Service rate, and was then applying its own mark-up. The CCTA argued
that this double mark-up should not be allowed. |
173. |
Aliant Telecom submitted that the CCS7
A-Link service was obtained from Bell Canada at full tariff, and hence
Aliant Telecom should be allowed to include an additional 15 percent
mark-up on the tariff. |
|
Commission's analysis and determinations
|
174. |
The Commission considers it inappropriate
for Aliant Telecom to apply a 15 percent mark-up in addition to
Bell Canada's CCS7 A-Link service rate if Aliant Telecom provides the
service by using Bell Canada's service. |
175. |
Accordingly, the Commission directs
Aliant Telecom to provide the CCS7 A-Link service at the Bell Canada
rate without the addition of a 15 percent mark-up. |
|
Implementation and disposition of tariff notices
|
176. |
The Commission received the following tariff
notice (TN) applications from the ILECs, resulting from the follow-up
process to Decision 2004-46: |
|
- TN 151, by Aliant Telecom, dated 14 January 2005;
|
|
- TN 6849, by Bell Canada, dated 14 January 2005;
|
|
- TNs 553 and 553A, by MTS Allstream, dated 17 February 2005 and
29 March 2005, respectively;
|
|
- TNs 74, 74A and 74B, by SaskTel, dated 14 January 2005, 28 January
2005, and 7 October 2005, respectively;
|
|
- TN 538, by TCC (for Alberta), dated 12 October 2004;
|
|
- TN 4219, by TCC (for British Columbia), dated 12 October 2004.
|
177. |
The Commission approves, with
changes resulting from the determinations of this Decision,
Aliant Telecom's TN 151, Bell Canada's TN 6849, MTS Allstream's TN 553
as amended by TN 553A, Sasktel's TN 74 as amended by TNs 74A and 74B,
TCC's TN 538, and TCC's TN 4219. |
178. |
The Commission directs each ILEC to issue,
within 45 days of the date of this Decision, amended tariff pages,
effective the date of this Decision, that reflect the determinations of
this Decision and include definitions of approved LIRs, including lists
of the exchanges within each LIR, the designated POI for each LIR, and
the designated SPOI within each NPA. |
|
Secretary General |
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This document is available in alternative
format upon request, and may also be examined in PDF
format or in HTML at the following Internet site: http://www.crtc.gc.ca
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Footnotes:
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