ARCHIVED - Public Notice CRTC 2000-52

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Public Notice CRTC 2000-52

Ottawa, 7 April 2000
Solutions sought for North American Numbering Plan exhaust
Reference: 8621-C12-02/00
This public notice seeks input on the technical, social and economic impacts relating to the exhaust of the North American Numbering Plan. It proposes solutions currently under consideration and other related issues.

1.

In initiating this proceeding, the Commission seeks to examine the issues related to the potential exhaust of the North American Numbering Plan (NANP), including:
  • the five NANP expansion options currently under consideration by the Industry Numbering Committee (INC);
  • the two key assumptions identified in the INC report;
  • the Canadian Country Code alternative to NANP expansion presented by the CRTC Industry Steering Committee (CISC) Canadian Steering Committee on Numbering (CSCN); and
  • related issues.

High demand causing area code exhaust

2.

The NANP is the basic 10-digit telephone numbering plan used by Canada, the US and 17 Caribbean nations in Country Code 1.

3.

The current 10-digit format is NXX-NXX-XXXX, where N = digits 2-9 and X = digits 0-9, sometimes expressed as ABC-DEF-GHIJ. The first three digits (ABC digits) reflect the numbering plan area (NPA) or area code. The next three digits (DEF digits) reflect the central office code (CO code) and the last four digits (GHIJ) reflect the line number.

4.

The theoretical capacity of the current plan is 6.4 million numbers. There are 800 area codes, each capable of supporting 800 CO codes, each of which has 10,000 telephone numbers. The actual capacity is less than stated as certain digit combinations are not available for use as area codes or CO codes, such as 9-1-1. Other numbers are used for different applications such as 800, which may cause customer confusion if they were assigned as a CO code.

5.

As the demand for additional phone numbers grows, there is a need to assign more CO codes to augment the available telephone numbers within an area code. Therefore, as more CO codes are assigned, it is the area codes that begin to exhaust. New area codes are required to provide the numbering resources required by consumers and service providers.

6.

Finally, as more area codes are assigned throughout the 19 nations in the NANP, the ongoing ability of the existing plan to meet the needs is reduced.

7.

In the NANP area, the demand for CO codes and area codes has increased significantly due to the proliferation of new services, growth in existing services and the introduction of local competition. This growth trend is not unique to NANP nations and numbering relief plans in a number of other countries will also be required.

8.

In 1993, in anticipation of the exhaust of the plan, the INC began to develop a plan that would add more numbering resources when required. At that time, the NANP was projected to exhaust in the 2025-2030 timeframe.

9.

Since 1993, the INC has examined several numbering plan expansion options and has narrowed them down to five viable options. The INC intends to further analyze these options, and to study new options that may be presented for study, with the goal of recommending a final plan to the regulators of all NANP nations for their approval.

10.

In February 1999, Lockheed Martin IMS, in its role as the NANP Administrator (NANPA), released a report indicating the NANP could exhaust between 2004 and 2012, but most likely in the 2007-2008 timeframe.

11.

With the release of NANPA's report, the CISC CSCN established a task force to examine issues relating to the exhaust of the NANP from a Canadian perspective.

12.

In March 1999, the North American Numbering Council (NANC), an advisory committee reporting to the US Federal Communications Commission (FCC), established an ad hoc committee to work with the NANPA to examine the assumptions considered in NANPA's forecast, in an attempt to confirm the NANP exhaust date.

13.

The NANC ad hoc and the NANPA were unable to reach agreement on the underlying assumptions to be used to forecast the exhaust date and there is currently no consensus.

14.

The Commission expects more information regarding the timing of NANP exhaust by mid-year, when the results of the year 2000 Central Office Code Utilization Survey (COCUS) are available from the NANPA. The COCUS consists of an annual survey of CO code requirements for the next five years from all service providers in the NANP, and is used as the basis for forecasting the exhaust of area codes and the NANP.

15.

Despite the absence of a firm exhaust date, the Commission is of the opinion that a relief plan must be finalized and agreed to by all NANP nations in the next 12 to 18 months at the latest.
It is in preparation for discussions with the other NANP nations that the Commission seeks input from Canadians at this time.

16.

During 1999, the CISC CSCN submitted industry positions to the INC process:
  • requesting that the National Destination Code (NDC) option be retained on the short list of alternatives to be further studied; and
  • establishing that any NANP expansion plan must provide Canadian industry and regulatory authorities with increased flexibility and autonomy in the use of number resources allocated to Canada.

17.

Through the CISC process, the CRTC supported the CISC CSCN positions, and affirmed with INC that the NDC option should remain on the short list of options pending further study.

18.

In December 1999, the CISC submitted a recommendation to the Commission, to secure additional area codes from the NANPA to protect the future needs of Canadians in a pre-NANP expansion environment, before the remaining pool of available area codes was depleted. The Commission agreed with this recommendation and has directed the NANPA to assign 27 additional area codes to Canada, for Canada's exclusive use.

19.

On 21 January 2000, the Commission received the INC Interim NANP Expansion Report accompanied by a letter seeking confirmation of two key assumptions contained in the INC Report. The INC is seeking a response regarding the assumptions used in the analysis of expansion options from all NANP nation regulators as soon as possible, so it is able to continue its work.

20.

On 25 February 2000, the Commission received the CSCN Report to the CRTC on NANP Expansion for its consideration in initiating a public process to examine the issues.

21.

In an effort to streamline this public notice, while providing public access to all the available information, the Commission has posted the INC Interim NANP Expansion Report and the CSCN Report to the CRTC on NANP Expansion, as well as attachments, on its website at http://www.crtc.gc.ca/cisc/eng/cisf3f.htm.

22.

Hard copies of these documents may also be requested by submitting a written request to the Secretary General at the CRTC.

23.

Interested parties are asked to refer to these attachments for specific and additional information pertaining to the issues presented herein.

The INC Interim NANP Expansion Report

24.

In its report, the INC presents the background, technical analysis and status of its activities to date. The INC notes that all policy decisions relating to the NANP project will require the mutual consent of all nations participating in the NANP.

25.

The report identifies two key assumptions considered in assessing the various expansion options considered. These two assumptions are as follows:

a. The Uniform Dial Plan (UDP) must be implemented throughout the NANP, in advance of NANP expansion, in order to transition from the old to the new dial plan. Implementing UDP would require:

  • the elimination of the prefix 1+ in long distance dialing, and as a toll indicator;
  • the elimination of 7-digit dialing; and
  • the introduction of 10-digit dialing on all local and toll calls within the NANP area.
The Commission notes that in order to implement two of the NANP expansion options, a reintroduction of the prefix 1+ is required coincident with expansion.

b. Coincident with the introduction of the new expanded NANP numbering plan, the current D-digit (fourth digit in the 10-digit numbering plan) would be changed from its current "N" format to an "X" format. This change would allow the first digit of the CO code to be a "0" or a "1", resulting in an increase in the number of CO codes and telephone numbers within each area code.

        26. Release of the D-digit can only occur after the Uniform Dial Plan has been implemented, because the digits 0 and 1 as the lead digit in dialing would default a call to an operator or a long distance service.

27.

The "opening" of the D-digit field also provides the network with a trigger to recognize an old 10-digit NANP number from a new NANP expansion number during the transition period. All current internal network uses of a "0" or "1" in the D-digit field must be cleared in advance of, and in preparation for expansion. However, it is also necessary to protect the current "N" format until expansion.

        28.

The INC notes that in order to implement any of the five options discussed in its report, and for it to continue its work, it is necessary for all NANP regulators to establish a policy with regard to UDP and D-digit release as soon as possible.

The CSCN report to the CRTC on NANP Expansion

29.

The CISC CSCN report presents the issues raised in the INC report from a Canadian perspective, and reflects the results of its examination of the five NANP expansion options.

30.

Significantly, the report identifies that opting out of the NANP and securing a unique Canadian Country Code is the only alternative available to participating in the NANP expansion project.

31.

The CSCN report requests the CRTC to confirm Canadian policy that should Canada remain in an expanded NANP, the expansion solution must provide Canadian industry and regulatory authorities with increased flexibility and autonomy to use numbering resources allocated to Canada and to provide greater insulation from external influences and factors that are not applicable to Canada.

32.

In addition, the CSCN requests the CRTC to address the following matters:
  • implementation of UDP;
  • retaining the toll indicator;
  • clearing and releasing the D-digit; and
  • impact of implementing the thousand block number allocation sub-option in Canada.

33.

The CSCN confirms that in order to implement the five options identified in the INC report, the Uniform Dial Plan must be implemented prior to expansion, and the D-digit would need to be released from its current format either coincident with, or following NANP expansion.

34.

In addition, the CSCN comments on the five expansion options presented in the INC report. Finally, the CSCN identifies an alternative to participating in the NANP expansion activities - Canada could opt out of the NANP and secure its own country code.

35.

The CSCN does not attempt to choose any preferred solutions to the issues raised in the INC report and focuses on presenting the options and alternatives available to Canadians instead. The report is a valuable reference document for developing a Canadian position through this proceeding.

36.

Anticipating a public process to address the issues, the CSCN poses a number of questions for the public and Canadian telecommunications service providers. The Commission is of the opinion that the questions proposed by the CSCN will greatly assist in the identification and examination of all the issues in a qualitative and quantitative manner from a Canadian perspective.

37.

The Commission will make direct reference to this report throughout this notice.

Two key assumptions: Implementation of the uniform dial plan and release of D-digit

38.

The Commission seeks public comment on implementation of the two key assumptions contained in the INC report.

39.

In order for it to adequately assess the implications of the two key assumptions for service providers, the Commission requires that all telecommunications service providers file a response to Service Provider (SP) questions 10 and 11 contained in the CSCN report.

Implementation of UDP

40.

With the implementation of UDP, all Canadians will be obliged to change their dialling habits. The changes in the dial plan will include the elimination of 1+ as a toll indicator and the need to dial 10-digits on all calls, whether local or long distance. The Commission encourages Canadians to respond to User questions 7 and 8 contained in the CSCN report, as part of their submissions to the Commission.

41.

The Commission is specifically seeking input from Canadians on the need for a toll indicator, and the viable alternative(s) to the 1+ prefix, should UDP be available, considering the current NANP expansion options being studied.

Release of the D-digit

42.

The issues surrounding release of the D-digit are primarily technical in nature.

43.

The Commission seeks comment on its preliminary view that no drivers exist in Canada that would precipitate release of the D-digit prior to NANP expansion in Canada.

44.

The Commission recognizes that use of the D-digit in the "0" or "1" format is pervasive in individual service provider and private telecommunications networks. These uses are unique to individual networks and release of the D-digit would precipitate the need to explore alternatives to current applications. In order to prepare for the release of the D-digit, all current uses would need to be eliminated well in advance of NANP expansion.
        45. The CSCN report confirms the INC assumptions that in order to implement the expansion options, clearing of the D-digit in advance of expansion is required. In order to understand the feasibility and impacts of releasing the D-digit on various internal networks, the Commission requires that all telecommunications service providers respond to SP question 12 contained in the CSCN report.

46.

The Commission encourages users, including equipment vendors and system administrators affected by this change, to identify concerns and to advise the Commission as to the feasibility of clearing all their current internal uses of the D-digit prior to expansion.

NANP expansion options

47.

The five NANP expansion options, currently under consideration, are fully described in the INC and CSCN reports. A brief description of each option is provided below. Parties are referred to Sections 4.0 through 8.0 of the INC report, and Section 4.0 of the CSCN report for additional details.

48.

All options are referred to by the titles assigned to them by the INC.

49.

Number plan changes that would result from the implementation of the NANP format are identified below as bold underlined text.

50.

Option 1A - 4 digit NPA with new D digit and D digit release:
  • 11-digit format;
  • Requires 11-digit local and toll dialing;
  • NXXX XXX XXXX;
  • Theoretical capacity is 80 billion numbers;
  • Could provide Canada with a unique digit identifier in the new fourth position, and access to 8 billion telephone numbers.

51.

Option 1B - 4 digit NPA with new D digit, 4 digit CO code and D digit release:
  • 12-digit format;
  • Requires 12-digit local and toll dialing;
  • NXXX XXXX XXXX;
  • Theoretical capacity is 800 billion numbers;
  • Could provide Canada with a unique digit identifier in the new fourth position and access to 80 billion telephone numbers.

52.

Option 2A - 4 digit NPA with new A digit and D digit release:
  • 11-digit format;
  • Requires 11-digit local and toll dialing;
  • NXXX XXX XXXX;
  • Theoretical capacity is 80 billion numbers;
  • Does not provide Canada with a unique digit identifier;
  • Reintroduces 1+ prefix.

53.

Option 3A - National Destination Code (NDC) with D digit release:
  • 10-digit within NDC;
  • Permits 10-digit dialing within the NDC and 1+ 11 digit dialing between NDCs;
  • N NXX XXX XXXX;
  • Theoretical capacity is 64 billion numbers;
  • Could provide Canada with a unique digit identifier in the NDC position, would not require a change to dial plan within the NDC and would provide access to 6.4 billion telephone numbers.
  • Reintroduces 1+ prefix on calls between NDCs.

54.

Option 4A - 4 digit NPA with new B digit and D digit release:
  • 11-digit format;
  • Requires 11-digit local and toll dialing;
  • NXXX XXX XXXX;
  • Inserts the digit "9" between first and second digit of existing area codes;
  • Theoretical capacity is 80 billion numbers
  • Does not provide Canada with a unique digit identifier, therefore no particular benefit to Canada;
  • CSCN analysis reflects most difficult from human factors perspective.

Thousand block number allocation sub-option

55.

The CSCN report identifies a sub-option that is under discussion at INC but is not currently represented in the INC report. This sub-option exists for all five options presented. The sub-option enables the allocation of telephone numbers in blocks of one thousand, as opposed to the current assignment of CO codes (10,000 numbers) to telecommunications service providers. The report notes that implementation of this sub-option in any solution would require a change in the current administration and routing systems throughout the entire NANP.

56.

The CSCN recommends that the CRTC address the impacts of implementing this sub-option in Canada, and has included a question to service providers in its report.

57.

With regard to this recommendation, the Commission agrees that input on this issue would be beneficial. The Commission recognizes that without specific details regarding timing, system requirements and processes, input may be limited. The Commission, however, is interested in gaining an early appreciation of the impacts such an NANP-wide change would have on the Canadian telecommunications industry, and therefore, requires telecommunications service providers to respond to SP question 9 in their submissions.

Canadian country code alternative to NANP expansion

58.

The CSCN concludes that the only alternative to NANP expansion available to Canada is the unique Canadian country code alternative. Although a brief description of this alternative is provided below, parties are requested to refer to Section 5.0 of the CSCN report for additional details.

59.

This alternative would require Canada to opt out of the NANP and secure its own country code from the International Telecommunications Union (ITU). With this alternative, the US and the 17 Caribbean nations would remain within the NANP, and calls between Canada and these nations would become "international", requiring originating networks throughout the world to implement a change.

60.

As current ITU policy dictates that new country codes comprise three digits, the CSCN has assumed Canada would be assigned a three-digit country code.

61.

The CSCN notes that, with the cooperation of the other NANP nations, Canada could use country code 100, which would permit it to retain the current 10-digit numbering and its dial plan domestically.
        62. The CSCN report identifies the changes to the dialing plan that would be required, assuming UDP is implemented and agreement on the use of Country Code 100 could be secured:
  • Calls within Canada would be dialed on a 10-digit basis;
  • Calls to other NANP nations would be dialed on a 1+ 11 or 12 digits, depending on the expansion option implemented in the NANP;
  • Calls from other NANP nations would be dialed as 100+10 digits;
  • International calls from other nations (non-NANP) would be dialed as 011+100+10 digit, with 011 reflecting the international access code.

63.

The report notes that should Canada be unable to negotiate the use of Country Code 100, calls between existing NANP nations would be dialed as an international call (e.g, 011+ CC+10-digits).

64.

The CSCN identifies the significant advantages and disadvantages of this alternative, as compared to the five NANP expansion options, as well as the associated dependencies and prerequisites.

65.

Section 6.1 of the CSCN report provides a number of questions it recommends the Commission ask of Canadian carriers. The Commission agrees that responses to questions 1 through 8, as they apply to the five NANP expansion options, and the Canadian country code alternative would assist the Commission in its understanding of the impacts and issues as they relate to Canadian telecommunications providers. The Commission therefore requires that all telecommunications service providers respond to these questions in their submissions.

66.

Section 6.2 of the CSCN report provides a number of questions it recommends the Commission ask of Canadian users. In seeking public input, the Commission encourages Canadian users to respond to User questions 1 through 6, as they apply to the five NANP expansion options, and the Canadian country code alternative.

67.

With the potential exhaust of the NANP, the implementation of any solution under consideration will have a significant impact on Canadians. Through this proceeding, the Commission is interested in hearing from Canadians on all aspects of NANP expansion and the Canadian Country Code alternative, in order to assist it in developing policies that are in the best interest of Canadians.

Procedure

        68. Persons wishing to participate in this proceeding or who otherwise would like to receive the documentation relating to this proceeding, must notify the Commission of their intention by writing to the Secretary General, CRTC, Ottawa, Ontario, K1A 0N2, or by fax: (819) 953-0795, within 30 days of the date of this public notice. Parties are to indicate in their notice their e-mail address, where available. If 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. The Commission will issue a complete list of parties and their mailing addresses (including e-mail addresses if available), identifying those parties who wish to receive disk versions.

With regard to the two key assumptions (UDP and D-digit)

        69. Parties are to file comments with the Commission, serving copies on all other parties, by 19 May 2000.
        70. Parties may file reply comments with the Commission, serving copies on all other parties, by 9 June 2000.

With regard to the five NANP expansion options and Canadian country code alternative

        71. Parties are to file comments with the Commission, serving copies on all other parties, by 8 August 2000
        72. Parties may file reply comments with the Commission, serving copies on all other parties, by 22 August 2000.
        73. During this proceeding, the Commission may address interrogatories to Canadian telecommunications service providers to solicit additional information, if it considers additional information is required to assess the impacts of the various alternatives on service providers and their users.
        74. 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.
        75. The record of this proceeding may be examined, or will be made available promptly upon request, at the Commission's offices in the following locations:
Central Building
Les Terrasses de la Chaudière
1 Promenade du Portage, Room G-5
Hull, Quebec K1A 0N2
Tel: (819) 997-2429 - TDD: 994-0423
FAX: (819) 994-0218
Bank of Commerce Building
1809 Barrington Street
Suite 1007
Halifax, Nova Scotia B3J 3K8
Tel: (902) 426-7997 - TDD: 426-6997
FAX: (902) 426-2721
405 de Maisonneuve Blvd. East
2nd Floor, Suite B2300
Montréal, Quebec H2L 4J5
Tel: (514) 283-6607 - TDD: 283-8316
FAX: (514) 283-3689
55 St. Clair Avenue East
Suite 624
Toronto, Ontario M4T 1M2
Tel: (416) 952-9096
FAX: (416) 954-6343
Kensington Building
275 Portage Avenue
Suite 1810
Winnipeg, Manitoba R3B 2B3
Tel: (204) 983-6306 - TDD: 983-8274
FAX: (204) 983-6317
Cornwall Professional Building
2125 - 11th Avenue
Room 103
Regina, Saskatchewan S4P 3X3
Tel: (306) 780-3422
FAX: (306) 780-3319
Scotia Place Tower Two
19th Floor, Suite 1909
10060 Jasper Avenue
Edmonton, Alberta T5J 3R8
Tel: (780) 495-3224
FAX: (780) 495-3214
530-580 Hornby Street
Vancouver, British Columbia V6C 3B6
Tel: (604) 666-2111 - TDD: 666-0778
FAX: (604) 666-8322
Secretary General
This document is available in alternate format upon request and may also be viewed at the following Internet site: http://www.crtc.gc.ca
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