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Telecom Public Notice CRTC 2004-2
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See also: 2004-2-1
Ottawa, 7 April 2004 |
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Regulatory framework for voice communication services using
Internet Protocol
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Reference:
8663-C12-200402892 and
8663-B2-200316101 |
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The Commission has received both an
application and a letter requesting it to address the regulatory
requirements for the provision of voice communication services using
Internet Protocol (IP). With this public notice, the Commission provides
its preliminary views on the regulatory framework applicable to those
services. The Commission is of the preliminary view that voice
communication services using IP that utilize telephone numbers based on
the North American Numbering Plan and provide universal access to and/or
from the Public Switched Telephone Network (PSTN) (referred to in this
public notice as "VoIP" services) have functional characteristics that
are the same as circuit-switched voice telecommunications services. In
the Commission's preliminary view, its existing regulatory framework
should apply to VoIP services, including its determinations related to
forbearance. The Commission considers, on a preliminary basis, that to
the extent that VoIP services provide subscribers with access to and/or
from the PSTN along with the ability to make and/or receive calls that
originate and terminate within the geographic boundaries of a local
calling area as defined in the Incumbent Local Exchange Carriers' (ILECs)
tariffs, they should be treated for regulatory purposes as local
exchange services, and be subject to the regulatory framework governing
local competition, established in Local competition, Telecom
Decision CRTC 97-8, 1 May 1997 and subsequent determinations. In this
public notice, the Commission also expresses preliminary views on the
following three matters: (i) the applicability of existing tariffs, and
requirements to file tariffs; (ii) the provision of 9-1-1 and enhanced
9-1-1 service, message relay service and privacy safeguards; (iii) the
applicability of the national contribution collection mechanism as
introduced in Changes to the contribution regime, Decision CRTC
2000-745, 30 November 2000. Interested parties are invited to provide
comments on the Commission's preliminary views and any other pertinent
matters and to participate in a public consultation. |
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Introduction
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1. |
Internet Protocol (IP) can be described as
a standardized method of transporting information in voice, video and
data packets over the same network, including the Internet or a managed
network. While packet-based networks were originally designed for the
transmission of data, advances in IP now allow these packet-based
networks also to carry high quality voice traffic on an efficient basis. |
2. |
While the Internet itself is a broadband
network, residential users were initially limited to accessing the
Internet via slow speed, narrowband (dial-up)
connections. The advent of cable modems and digital subscriber loop
(DSL) technology, however has allowed for high-speed access to the
Internet. |
3. |
Until recently, generally available voice
communication services using IP only allowed subscribers to make and/or
receive calls from a computer and communications could only take place
when all parties to the call used the same telephony application
software. These services, referred to as "peer-to-peer" (P2P), do not
connect to the Public Switched Telephone Network (PSTN) and do not
generally use telephone numbers that conform with the North American
Numbering Plan (NANP). |
4. |
The Commission notes that much has changed
since the first systems supporting voice communication services using IP
were introduced. The International Telecommunication Union, the Internet
Engineering Task Force, and the European Telecommunications
Standardization Institute have introduced global standards, for example,
for high-quality speech coders, universal addressing, call control and
signalling. Global standards have allowed for the interoperability among
network components of packet-based networks and have improved
voice communication services using IP. |
5. |
Voice communication services using IP now
allow subscribers to make calls over a broadband connection, for example
with a conventional phone-set attached to an adaptor or an IP telephone.
These services use telephone numbers that conform to the NANP and allow
subscribers to make calls to, or receive calls from, the PSTN. Although
the term "VoIP services" may be used to refer to both these services and
to P2P, it will be used in this public notice to refer only to services
that use NANP-conforming telephone numbers and provide universal access
to and/or from the PSTN. |
6. |
The Commission has received both an
application and a letter requesting the Commission to address the
regulatory requirements for the provision of VoIP services. On 6
November 2003, Bell Canada submitted an application requesting, among
other things, that the Commission commence a proceeding to address the
rules, if any, which govern the provision of telecommunications services
by cable companies and other service providers that offer VoIP services.
On 12 January 2004, Call-Net Enterprises Inc. submitted a letter asking
what regulatory requirements would apply to service providers that are
now offering VoIP services. |
7. |
In light of the availability of voice
services and the calls for clarification of the regulatory rules, the
Commission considers that there is a need to set out its views on the
regulatory regime applicable to the provision of those services. This
public notice contains the Commission's preliminary views in this regard
and invites parties to provide comments and reply comments. The
Commission also provides for a public consultation where those parties
that file written submissions will have the opportunity to present their
views orally. |
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Commission's regulatory framework
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8. |
In Review of regulatory framework,
Telecom Public Notice CRTC 92-78, 16 December 1992 (Public Notice
92-78), the Commission stated that it was of the view that in an
information-based economy, a modern and efficient telecommunications
infrastructure was a fundamental component of, and vehicle for, the
production and consumption of goods and services. The Commission noted
that technological change and increasing competition had significantly
altered the nature of the telecommunications industry, so that, in
addition to fulfilling the basic communications requirements of all
subscribers, telecommunications had evolved into a tool for information
management and a productivity enhancer for business. The Commission also
noted that these changes allowed the telephone companies under its
jurisdiction that provide local exchange service to develop a wide range
of new audio, video and high-speed data services to satisfy the demands
of both business and residential consumers in the local and long
distance markets. |
9. |
Following Public Notice
92-78, 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 telecommunications industry, in accordance
with the telecommunications policy objectives outlined in section 7 of
the Telecommunications Act (the Act) and in light of the
continuing evolution of the industry. In that decision, the Commission
stated that: |
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The digital universe promises a range of telecommunications
services seemingly limited only by the rate of diffusion of new
technology, access to capital and the imagination of users. It is
important, in such a dynamic environment, that regulation encourage,
rather than impede, the provision of efficient, innovative and
affordable services.
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10. |
The Commission further stated that: |
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In brief, telecommunications today transcends traditional
boundaries and simple definition. It is an industry, a market and a
means of doing business that encompasses a constantly evolving range
of voice, data and video products and services. Telecommunications
services range from basic access services connecting subscribers
within a physical area, to multi-media applications where virtual
communities that transcend geographic boundaries are created among
users with common interests. It is this evolution of
telecommunications that has given rise to visions of an information
highway linking Canadians with each other and the world.
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11. |
Although in Decision 94-19 the Commission
did not specifically contemplate the advent of VoIP services, it laid
the groundwork for a future characterized by efficiency, innovation and
affordability, regardless of the technology that was to follow. |
12. |
Over the past decade, in response to the
constantly evolving telecommunications environment, the Commission has
issued a number of determinations, consistent with the Commission's
views in Decision 94-19, permitting telephone companies to provide a
wide range of new services and encourage more competition in all market
segments, including the market for local exchange services. In Local
competition, Telecom Decision CRTC
97-8, 1 May 1997 (Decision
97-8),
the Commission established the regulatory framework allowing for local
competition, creating opportunities for Competitive Local Exchange
Carriers (CLECs) to enter the market in competition with Incumbent Local
Exchange Carriers (ILECs). |
13. |
The regulatory framework established in
Decision 94-19 and subsequent decisions, was intended to assist in the
development of a telecommunications infrastructure that will allow all
Canadians, not just a select few, ubiquitous and affordable access to an
increasing range of competitively provided basic and advanced
information and communications products and services to serve
increasingly diverse user requirements. In order to achieve these
objectives, the Commission has consistently placed greater reliance on
market forces and attempted to ensure that regulation, where required,
is effective. For example, in Decision
94-19, the Commission permitted
the ILECs to bundle tariffed services with other services, provided that
the companies met certain conditions including service bundle pricing
rules. The service bundle pricing rules established in Decision
94-19
have subsequently been modified and extended in a number of decisions. |
14. |
The Commission has also issued a number of
decisions in which it has forborne from regulating certain classes of
services provided by certain classes of service providers, including
Regulation of wireless services, Telecom Decision CRTC
94-15, 12
August 1994, Forbearance – Services provided by non-dominant canadian
carriers, Telecom Decision CRTC
95-19, 8 September 1995, Decision
97-8, and Forbearance – Regulation of toll services provided by
incumbent telephone companies, Telecom Decision CRTC
97-19,
18 December 1997. |
15. |
The Commission notes that since Decision
94-19, competition has led to greater choice of products and services
for both business and residential consumers, and to significant price
decreases for most services, including long distance, Internet, data,
wireless and international services. As competition has been achieved in
these markets, the Commission has refrained from regulating those
elements which market forces are able to discipline. Market forces allow
for greater choice and service provider responsiveness and ensure that
user requirements, not regulators, drive service considerations. The
Commission has maintained the view that regulation of local exchange
services remains necessary given the weak state of competition in the
local exchange services market. |
16. |
In Price cap regulation and related
issues, Telecom Decision CRTC
97-9, 1 May 1997 (Decision
97-9), the
Commission established a price cap regime based on the view that price
regulation, rather than rate base/rate of return regulation, provides ILECs with stronger incentives to minimize costs, to operate
more efficiently and to be more innovative in the provision of services.
Under this revised price regulation regime, ILECs retain the benefits of
their efficiency. |
17. |
The Commission considers that the provision
by ILECs of VoIP services is consistent with the specific objective of
the Commission in Decision 97-9, and maintained in Regulatory
framework for second price cap period, Telecom Decision CRTC
2002-34, 30 May 2002, to "provide incumbents with incentives to increase
efficiencies and to be more innovative". |
18. |
One of the key underlying principles of the
regulatory framework established for local exchange service competition
was that of technological neutrality. The Commission provided the
opportunity for all competitive Canadian carriers, whatever transmission
technology they used and whether their services were fixed or mobile, to
become CLECs, subject to the regulatory obligations established in
Decision 97-8. |
19. |
Similarly, in Regulation under the
Telecommunications Act of certain telecommunications services offered by
"broadcast carriers", Telecom Decision CRTC
98-9, 9 July 1998,
the Commission stated that consistent with its overall approach to
telecommunications regulation, it was not appropriate to define the
market for telecommunications services with reference to technology.
Instead, service attributes should be the focus of analysis. |
20. |
The regulatory framework established in
Decision 97-8 maintained the ILECs' obligation to file tariffs for local
exchange services. CLECs, by contrast, are not required to file tariffs
for retail telecommunications services. Pursuant to Decision
97-8 and
subsequent determinations, ILECs and CLECs, and to a certain extent
resellers providing local service, are required to meet certain
regulatory obligations. The regulatory obligations imposed on ILECs,
CLECs and resellers by the Commission in Decision
97-8 and subsequent
determinations, are listed in tabular form in the Appendix to this
public notice. |
21. |
In the following section the Commission
sets out its preliminary views on certain regulatory obligations of
providers of VoIP services, including those requirements related to the
filing of tariffs; to the provision of 9-1-1 and Enhanced 9-1-1 (E9-1-1)
service, message relay service (MRS), and privacy safeguards; and to
contribution. |
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Commission's preliminary views
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22. |
As indicated earlier, VoIP services utilize
telephone numbers that conform to the NANP and allow subscribers to call
and/or receive calls from any telephone with access to the PSTN anywhere
in the world. In the Commission's preliminary view, these
characteristics of VoIP services are functionally the same as those of
circuit-switched voice telecommunications services. |
23. |
Consistent with the principle of
technological neutrality, in the Commission's preliminary view VoIP
services should be subject to the existing regulatory framework,
including the Commission's forbearance determinations. It follows that
the regulatory requirements imposed on VoIP service providers would
depend on the class of the service provider (e.g., ILEC, CLEC,
non-dominant Canadian carrier, mobile wireless service provider, local
service reseller) and the type of service being offered. |
24. |
Thus when ILECs provide VoIP services in
their incumbent territories, they would be required to adhere to their
existing tariffs or to file proposed tariffs where required, in
conformity with applicable regulatory rules. CLECs, including wireless
CLECs and ILECs out-of-territory, would not be required to file tariffs
for retail local VoIP services; however, they and, to a certain extent
resellers providing local VoIP service, would be required to meet the
regulatory obligations imposed pursuant to Decision
97-8 and subsequent
determinations. ILECs, non-dominant Canadian carriers, and mobile
wireless service providers that are not CLECs would not be required to
file tariffs for VoIP services that fall within the scope of applicable
existing forbearance determinations. |
25. |
To the extent that VoIP services provide
subscribers with access to and/or from the PSTN along with the ability
to make and/or receive calls that originate and terminate within an
exchange or local calling area as defined in the ILECs' tariffs, in the
Commission's preliminary view, these services should be treated as local
exchange services and are referred to as local VoIP services. |
26. |
The Commission recognizes that
certain providers of local VoIP services may not initially be able to
provide 9-1-1, E9-1-1, MRS, or the privacy safeguards set out in the
Appendix. The Commission considers that it is therefore of fundamental
importance that subscribers to local VoIP services are made aware of the
nature and terms of the service being offered to them. The Commission
expects all local VoIP service providers to specifically and clearly
advise potential and existing subscribers of such information, including
for example, the availability of and limitations on 9-1-1/E9-1-1
service, and is of the preliminary view that a condition of service
pursuant to section 24 of the Act should be imposed to that effect.
Further, in the Commission's preliminary view, it should become
mandatory for all local VoIP service providers to provide 9-1-1, E9-1-1
service, MRS, and the privacy safeguards as soon as practicable. |
27. |
The Commission notes that the CRTC
Interconnection Steering Committee (CISC) is currently dealing with a
significant number of issues related to voice communications using IP in
various CISC working groups. Examples include Public Telephone
Networks Interconnections Involving IP Technology (NTTF004.doc) and
Service Delivery Issues for Mobile VoIP 9-1-1 Calls
(ESTF035.doc). The Commission considers that CISC would be the
appropriate forum to address issues related to providing local VoIP
service subscribers with 9-1-1/E9-1-1 service, MRS, and privacy
safeguards. In addition, as the telecommunications industry is in the
early stages of providing VoIP services, the Commission considers that
CISC should also consider issues relating to access to VoIP services by
persons with disabilities. |
28. |
In Decision
97-8, the Commission
established a central fund for the subsidization of high-cost
residential local services in rural and remote areas. In Changes to
the contribution regime, Decision CRTC
2000-745, 30 November 2000,
the Commission introduced a national contribution collection mechanism,
under which all telecommunications service providers that exceed a
certain revenue threshold are required to contribute to the fund based
on a percentage of the total contribution-eligible revenues from
Canadian telecommunications services. Revenues from retail Internet
services are not contribution-eligible.
Definitions for the purposes of
determining contribution-eligible revenues were subsequently approved by
the Commission in Industry Consensus Reports submitted by
the Contribution Collection Mechanism (CCM) Implementation Working
Groups, Order CRTC 2001-220, 15 March
2001 (Order 2001-220). |
29. |
As VoIP services provide access to and/or
from the PSTN, it is the Commission's preliminary view that they are not
retail Internet services, as that term is defined in Order
2001-220, and
that the revenues from VoIP services are accordingly
contribution-eligible. It is also the Commission's preliminary view that
P2P services are retail Internet services and that the revenues from P2P
services are accordingly not contribution-eligible. |
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Call for comments
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30. |
The Commission invites comments on its
preliminary views set out in this public notice, as well as on any other
matters that may be pertinent to the regulatory framework for voice
communications services using IP. The Commission also invites those
parties who submit comments to participate in a public consultation,
where they will have the opportunity to present their views orally and
where the Commission will take the opportunity to clarify parties'
views, as required. Following the consultation, parties will have the
opportunity to submit written reply comments. |
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Procedure
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31. |
Persons wishing to become parties to this
proceeding are required to notify the Commission of their intention to
do so by 16 April 2004 (the registration date) and to provide
their contact information. They should do so by contacting the Secretary
General by mail at CRTC, Ottawa, Ontario, K1A 0N2, by fax at (819)
994-0218 or by email at procedure@crtc.gc.ca. They are to indicate in
the notice their e-mail address where available. If such parties do not
have access to the Internet, they are to indicate in their notice
whether they wish to receive disk versions of hard copy filings. |
32. |
The Commission will issue, as soon as
possible after the registration date, a complete list of parties and
their mailing addresses (including their email addresses, if available),
identifying those parties who wish to receive disk versions. |
33. |
Parties are invited to file comments on the
Commission's preliminary views and on any other matters set out in this
public notice, by 28 April 2004, serving a copy on all other
parties by that date. |
34. |
Any research studies or other material that
parties wish to refer to in this proceeding are to be submitted along
with written submissions filed in accordance with the previous
paragraph. |
35. |
A public consultation will be held on
19-20 May 2004 at 140 Promenade du Portage, Niveau 0, Phase IV,
Gatineau, Quebec. Parties wishing to make an oral presentation at the
consultation are required to file comments pursuant to paragraph 33
above, and to indicate their intention to participate in the
consultation by 16 April 2004. |
36. |
The Commission reserves the right to group
parties of similar views together for the purpose of presenting their
views at the public consultation. |
37. |
The Commission will issue an organization
and conduct letter to outline the process of the public consultation. |
38. |
Any persons who wish merely to file written
comments in this proceeding without receiving copies of the various
submissions may do so by submitting their comments in writing to the
Commission by 28 April 2004. |
39. |
The Commission will not formally
acknowledge comments. It will, however, fully consider all comments and
they will form part of the public record of the proceeding. |
40. |
Parties may file reply comments with the
Commission, serving a copy on all other parties by 28 May 2004.
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41. |
Where a document is to be filed or served
by a specific date, the document must be actually received, not merely
sent, by that date. |
42. |
Parties may file their submissions
electronically or on paper. Submissions longer than five pages should
include a summary. |
43. |
Where the submission is filed by electronic
means, the line ***End of document*** should be entered following the
last paragraph of the document as an indication that the document has
not been damaged during electronic transmission. |
44. |
Please note that only those submissions
electronically filed will be available on the Commission's web site and
only in the official language and format in which they are submitted. |
45. |
Each paragraph of your submission should be
numbered. |
46. |
The Commission also encourages parties to
monitor the record of this proceeding (and/or the Commission's web site)
for additional information that they may find useful when preparing
their submissions. |
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Important
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47. |
All information submitted, including your
name, email address, and any other information not submitted under a
claim for confidentiality, will be posted on the Commission's web site.
Documents received in electronic format will be posted on the
Commission's web site exactly as you send them, and in the official
language and format in which they are received. Documents not received
electronically will be available in .pdf format. |
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Location of CRTC offices
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48. |
Submissions may be examined or will be made
available promptly upon request at the Commission offices during normal
business hours: |
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Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room 206
Gatineau, Quebec J8X 4B1
Tel: (819) 997-2429 – TDD: 994-0423
Fax: (819) 994-0218 |
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Metropolitan Place
99 Wyse Road, Suite 1410
Dartmouth, Nova Scotia B3A 4S5
Tel: (902) 426-7997 – TDD: 426-6997
Fax: (902) 426-2721 |
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405 de Maisonneuve Blvd. East
2nd Floor, Suite B2300
Montréal, Quebec H2L 4J5
Tel: (514) 283-6607
Fax: (514) 283-3689 |
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55 St. Clair Avenue East, Suite 624
Toronto, Ontario M4T 1M2
Tel: (416) 952-9096
Fax: (416) 954-6343 |
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Kensington Building
275 Portage Avenue, Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel: (204) 983-6306 – TDD: 983-8274
Fax: (204) 983-6317 |
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Cornwall Professional Building
2125 – 11th Avenue, Room 103
Regina, Saskatchewan S4P 3X3
Tel: (306) 780-3422
Fax: (306) 780-3319 |
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10405 Jasper Avenue, Suite 520
Edmonton, Alberta T5J 3N4
Tel: (780) 495-3224
Fax: (780) 495-3214 |
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580 Hornby Street, Suite 530
Vancouver, British Columbia V6C 3B6
Tel: (604) 666-2111 – TDD: 666-0778
Fax: (604) 666-8322 |
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Secretary General |
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This document is available in
alternative format upon request and may also be examined at the
following Internet site:
http://www.crtc.gc.ca |
Appendix
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Regulatory framework and other attributes for local
services competition |
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Please note that these charts
have been prepared as a convenience only. The regulatory framework for
local service competition as set out in Decision
97-8 and subsequent
decisions remain the Commission's final determinations. |
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Regulatory framework |
ILECs and CLECs |
Local service resellers |
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Tariffs |
ILECs are required to file
tariffs for local services in accordance with the price cap regime1.
CLECs are not required to file tariffs for retail services2. |
Resellers do not file
tariffs. |
|
9-1-1 and E9-1-1 |
LECs are required to connect
the caller with the appropriate emergency centre for 9-1-1 call
direction and to provide Automatic Location Identification (ALI)
information for E9-1-1 to be passed to the emergency centre where
available3. |
Commission determinations
explicitly assume that resellers, by virtue of the underlying LEC's
obligations, will provide 9-1-14. As a condition of obtaining
services from a LEC, resellers are required to provide to the carrier
ALI information for E9-1-15. |
|
MRS for the hearing impaired |
LECs are required to provide
MRS6. |
Commission determinations
explicitly assume that resellers, by virtue of the underlying LEC's
obligations, will provide MRS7. |
|
Privacy safeguards |
LECs are required to provide
call blocking, call trace and other privacy features8.
LECs are required to abide by Commission rules regarding the
confidentiality of customer information9. |
As a condition of obtaining
services from a LEC, resellers are required to comply with the same
privacy safeguards as the LECs10. |
|
Directory listing |
ILECs are required to
provide a complete directory listing11.
CLECs are required to provide listings to the directory12. |
Resellers are not subject to
any requirements. |
|
Equal access |
LECs13 are
required to provide equal access. |
Resellers are not subject to
any requirements14. |
|
Number portability |
LECs are required to provide
number portability15. |
Resellers do not have the
right to have direct access to administer their own number portability16.
Resellers would arrange with a LEC to port numbers obtained through the
lease of access services from the LEC. |
|
LEC interconnection |
LECs are required to provide
for reciprocal interconnection17, to have bill and keep18
arrangements, and to have a point of interconnection per exchange19. |
Resellers are not subject to
any requirements. PSTN interconnection can be obtained through the lease
of facilities. |
|
Contribution |
LECs are required to pay
contribution based on a percentage of their Canadian telecommunication
services revenues, subject to certain exceptions and less certain
deductions20. LECs are eligible to receive benefits from the
contribution regime on a per NAS basis21. |
Resellers are required to
pay contribution based on a percentage of their Canadian
telecommunication services revenues, subject to certain exceptions and
less certain deductions22. Resellers are not eligible to
receive benefits from the contribution regime23. |
|
Other attributes |
ILECs and CLECs |
Local service resellers |
|
Terms of service |
ILECs are required to abide
by the terms of service approved in their tariffs. CLECs are required to
provide information on certain terms of service to customers prior to
contracting for service24 and are required to provide certain
information upon request25. |
As a condition of obtaining
services from a LEC, resellers are required to comply with the same
obligations as CLECs26. |
|
Quality of service |
ILECs are required to report
on their performance based on the Commission's quality of service
indicators and standards.
CLECs are not subject to any requirements. |
Resellers are not subject to
any requirements. |
|
Power |
LECs generally provide
reliable power but are not subject to any requirements. |
Resellers are not subject to
any requirements. |
|
Alternate format of billing
and services information |
LECs are required to provide
alternate format on request27. |
Resellers are required to
provide alternate format on request28. |
____________________
Footnotes:
1 Regulatory framework for second price cap period, Telecom
Decision CRTC 2002-34, 30 May 2002, established a four-year price cap
regime that applies to the service baskets of the major ILECs.
2 Local competition, Telecom Decision CRTC
97-8, 1 May 1997
(Decision 97-8), (para. 272).
3 Decision 97-8 (para. 279 and 286).
4 Decision 97-8 (para. 279).
5 Follow-up to Order CRTC 2000-500 – Provision of reseller
end-customer information, Order CRTC
2000-1048, 22 November 2000.
6 Decision 97-8 (para. 279 and 286).
7 Decision 97-8 (para. 279).
8 Decision 97-8 (para. 288).
9 Decision 97-8 (para. 289).
10 Consensus report CTEW015, approved by the Commission in letter dated
1 February 2000.
11 Decision 97-8 (para. 229).
12 Decision 97-8 (para. 227).
13 Decision 97-8 (para. 190).
14 Telecom Order CRTC 99-379, 29 April 1999 (para. 29).
15 Competition and Culture on Canada's Information Highway: Managing
the Realities of Transition, submitted to the Government of Canada on
19 May 1995 in response to Order in Council P.C. 1994-1689, dated
11 October 1994 and Implementation of regulatory framework - Local
number portability and related issues, Telecom Public Notice CRTC
95-48, 10 November 1995.
16 Telecom Order CRTC 99-5, 8 January 1999 (para. 10).
17 Decision 97-8 (para. 17).
18 Decision 97-8 (para. 63).
19 Decision 97-8 (para. 32).
20 Changes to the contribution regime, Decision CRTC
2000-745,
30 November 2000 (Decision
2000-745) (para. 93).
21 Decision 2000-745 (para. 133) and Decision
97-8 (para. 173).
22 Decision 2000-745 (para. 93).
23 Decision 97-8 (para. 173).
24 Decision 97-8 (para. 293).
25 Decision 97-8 (para. 292).
26 Consensus report CTEW015, approved by the Commission in letter dated
1 February 2000.
27 Telecom Order CRTC 98-626, 26 June 1998 (para. 20) and
Alternative formats for a person who is blind, Order CRTC
2001-690,
31 August 2001.
28 Extending the availability of alternative format to consumers who
are blind, Telecom Decision CRTC 2002-13, 8 March 2002 (para. 22).
Date Modified: 2004-04-07 |