ARCHIVED -  Telecom Order CRTC 99-1141

Telecom Order CRTC 99-1141

Ottawa, 10 December 1999

SAIC Canada – Request for approval of NPA 416 relief plan

SAIC CanadaInc service providers operating in the 416 Area Code

File No.: 8698-C12-04/99

Summary

In this order, the Commission approves the numbering plan area (NPA) 416 relief plan as submitted. However, it requires the Canadian Numbering Administrator and the service providers operating in the 416 area code to establish the monitoring and reporting mechanisms set out in this order.

Introduction

1. On 23 August 1999, Science Applications International Corporation Canada (SAIC Canada), in their its role as the Canadian Numbering Administrator (CNA), submitted the final NPA 416 relief plan to the CRTC for approval. The plan was developed by the 416 NPA Relief Code Planning Committee (the Committee) and documented by Bell Canada (Bell) and SAIC Canada as the NPA 416 relief co-planners.

2. The 416 area code, which serves over 3.5 million subscribers in the city of Toronto, is projected to exhaust by the fall of 2001.

Background

3. The CNA is responsible for monitoring the assignments of central office (CO) codes and projecting when area codes in Canada will exhaust. When an area code is forecast to exhaust within a five-year time frame, action must be taken to ensure that a new area code is in place well before the existing code is exhausted. This is referred to as "relief planning".

4. Each area code contains a maximum of 792 assignable CO codes or NXX codes, each of which contains 10,000 telephone numbers.

5. Each year the CNA undertakes a Central Office Code Utilization Survey (COCUS). The COCUS provides a means by which all existing and potential code holders can identify their existing and future requirements for CO codes to the administrator. The administrator, in forecasting when an area code will exhaust, uses this information.

6. In March 1996, Bell (before SAIC Canada was the CNA), in its role as the central office code administrator, projected that NPA 416 would exhaust within the five-year planning window, based on the 1996 COCUS. Pursuant to the terms established in the Canadian Steering Committee on Numbering (CSCN) Canadian Central Office Code Assignment Guidelines and the Industry Numbering Committee (INC) NPA Code Relief Planning and Notification Guidelines (the industry guidelines), Bell convened a meeting of the affected parties, and formed the NPA 416 Code Relief Planning Committee. [The CSCN is now an industry working-group of the CRTC Interconnection Steering Committee (CISC).]

7. Following a number of meetings meetings held throughout the year, the Committee reached a consensus on a recommended NPA 416 relief plan (the Plan). The Plan identified a projected exhaust date of second quarter 2000 and recommended that a new NPA be introduced as a distributed overlay in April 2000. The overlay relief method requires mandatory 10-digit dialing for all local calls. Existing subscribers are not required to change their telephone numbers, as is required when an area is split into two NPAs. The Plan was forwarded to Industry Canada, which, at the time, had general responsibilities for numbering in Canada, where it was approved in January 1997.

8. Although the 1997 COCUS for NPA 416 confirmed the projected exhaust date established in the Plan, the 1998 COCUS results suggested that exhaust would not occur until first quarter 2002. Consequently, implementation of the original Plan was deferred.

Areas of concern

11. With regard to the latest projected exhaust date of 29 September 2001, the Commission is concerned with the following:

a) COCUS input has neither been solicited by, nor voluntarily submitted to the CNA from several proposed competitive local exchange carriers (CLECs) who have registered with the Commission. As a result, the projected exhaust date may be earlier than reflected in the Plan.

b) Bell noted that its input to COCUS was overstated; however, no revised input was requested nor submitted to the CNA for consideration in establishing the exhaust date.

c) The Plan contains no contingency factor for unpredicted demand.

d) The CNA proposes to assign N-0-0 codes if necessary to extend the life of the NPA in a jeopardy situation, though such assignments are discouraged due to the customer and dialing plan confusions that may result.

12. In light of the above, and considering the newly competitive local environment, the Commission is of the view that the exhaust date as established is volatile, and does not allow for any sudden increase in demand. The Commission notes that a shift in any of the factors influencing the need for CO codes could result in a situation where CO codes would be in extremely short supply, requiring vigorous CO code conservation measures. Should such measures be required, there is little likelihood that any NXXs will be available in the 416 area code following relief, thereby limiting the choice for new entrants and/or subscribers.

13. With regard to the proposed relief date of 5 March 2001, the Commission notes that the relief date is timed approximately seven months prior to the latest possible exhaust date. The Guidelines recommend that relief be timed six to 12 months prior to the earliest possible exhaust date, but no later than three months before the NPA would exhaust under the highest growth projections. The Commission considers that these timeframes for relief are appropriate in these circumstances.

14. The Commission is of the view that the earliest likely exhaust date is in the May/June 2001 timeframe, based on the assignment rate identified by the CNA. The proposed relief schedule therefore narrowly meets the minimum timeframe for NPA relief planning as recommended in the Guidelines, which the Commission considers appropriate in these circumstances, further contributing to the volatility of the recommended Plan.

15. While considering the volatility of demand, the Committee examined the possibility of advancing the relief date by introducing the new area code much earlier than March 2000. The Committee determined that in order to advance the relief schedule while avoiding the peak calling period associated with the Christmas season, the new NPA would need to be introduced in early fall 2000.

16. Bell established that it is unable to advance relief to the fall of 2000, due to Y2K preparation. Other members of the planning Committee expressed similar positions. Y2K influences, which include a four to six month blackout period, during which time no major switch activities can be scheduled, weighed heavily in the development of the relief schedule.

17. The Committee agreed that an advancement of relief would compress the time available to a point where there would be insufficient time to complete all necessary network changes required to implement a 10-digit dialing plan.

18. The Committee members were of the view that many of their subscribers face similar Y2K preparation pressures. An advancement of relief to the fall of 2000 would limit the time end-users have to undertake the necessary changes to their customer-provided equipment to support mandatory 10-digit dialing and a new NPA. Bell also noted that customer surveys indicate a consumer preference to avoid any other major changes in the year 2000.

19. Finally, in considering an advancement of the relief date, the Committee noted the requirement set out in the Guidelines that the North American telecommunications industry and customers be provided with 12 to 18 months notification of the change. Advancement of the proposed relief date to September 2000 would reduce this notification period to less than 12 months.

20. The Commission notes that the 416 network is already capable of supporting 7-digit and 10-digit local dialing, as is certain customer provided equipment. As a result, customers could begin to implement some of the changes required to establish 10-digit local dialing within NPA 416, should their Y2K schedule permit.

21. The Commission acknowledges that Y2K preparation and blackout periods introduce a particularly unique restriction on the NPA 416 relief planning process. Due to the roadblocks identified, the Commission understands that to order the advancement of NPA relief to September 2000 would not be in the public interest.

22. Accordingly, the Commission concludes that the only viable option available is to closely manage the allocation and use of the resources available to ensure that CO codes are available until relief is provided on 5 March 2001. In Appendix A, which is an integral part of this order, the Commission sets out its directions to the CNA and service providers regarding the monitoring and allocation of resources.

23. With regard to the proposed 10-digit dialing automatic announcement period:

a) The NPA 416 relief plan proposes that the announcement period may begin as early as 8 January 2001 and would end coincident with relief on 5 March 2001.

b) During the announcement period, calls dialed on a 7-digit basis are intercepted during the path of the call, and customers are informed of an impending need to dial all local calls on a 10-digit basis.

24. The Committee debated the merits of establishing a standard announcement period, applicable to all service providers. Certain parties argued against imposing a standard period, stating a need to maintain flexibility in managing their networks. Others countered that absent a standard announcement period, customers who use a number of providers for various services may be confused, and may associate the need to dial 10-digits with a service or a service provider.

25. The Commission considers that a strong and consistent public education program, which includes a standard automatic announcement period, is critical to the successful implementation of an NPA relief plan.

26. To this end, the Commission directs Canadian carriers operating in NPA 416 to begin introducing the 10-digit dialing automatic announcement no later than 8 January 2001, and to maintain the announcement for calls dialed on a 7-digit basis until mandatory 10-digit dialing is introduced on 5 March 2001.

27. The Commission understands that several service providers operating in the 416 area code have formed the Toronto Telecommunications Association (TTA) to co-ordinate communications programs and education materials associated with NPA 416 relief. The Commission encourages all service providers to participate in the TTA program.

28. In order to minimize customer confusion, the Commission directs the CNA to work with the TTA members and other parties to ensure all customer education materials and announcements are co-ordinated. Parties not wishing to become members of the TTA should have access, via the CNA website, to the TTA schedule for advertising and education. Members of the TTA are directed to provide their schedule, including updates, to the CNA. The CNA is directed to post such information on its website.

29. In addition, the Commission directs the CNA to monitor the efforts of the TTA and provide quarterly reports to the CRTC on the progress of customer education and readiness, commencing 1 March 2000. The report should include any customer feedback regarding inability to ready their systems or any other consumer concerns. In addition, the report should identify any major public announcements scheduled for the following quarter.

30. Finally, the Commission directs Canadian carriers operating in the 416 area code to report any major area of consumer concerns to the CNA and the CRTC, as they are identified, along with a proposed plan of action.

31. The Commission notes that the Y2K influences on the NPA 416 relief schedule are unique and absent such influences, the Commission would have sought to advance the timing of relief based on the record.

32. The Commission has identified a number of serious concerns relating to the 416 Plan. The concerns and directions provided herein will help to provide guidance on what the Commission expects in the future from NPA relief planning committees.

33. The Commission is of the opinion that the Guidelines which identify the requirements in the NPA relief planning process require further work to ensure that NPA Relief planning is undertaken in a more timely fashion, with minimal risk of invoking strict conservation measures. Such measures limit the ability of customers and service providers in accessing telephone numbers when they are needed, and as such, should not be used as a substitute for proper NPA relief planning.

34. The CISC/CSCN has undertaken to review and amend the industry guidelines and to recommend to the CISC and CRTC means by which weaknesses in the process can be adequately addressed. Parties are encouraged to participate in this CISC/CSCN undertaking.

Secretary General

This document is available in alternative format upon request and may also be viewed at the following Internet site: www.crtc.gc.ca

Reporting requirements

1. The Commission considers that in order to mitigate the risks associated with the NPA 416 relief plan, it is necessary to:

a) review current utilization levels within each NXX;

b) re-examine all service provider forecasts to ensure all future needs are appropriately captured;

c) implement additional ongoing monitoring mechanisms; and

d) prepare adequately to avoid a jeopardy situation through the early development of code conservation procedures.

2. The NPA 416 relief plan proposes that the CNA will initiate two COCUS per year as a monitoring tool. The Commission agrees that semi-annual COCUS will be helpful but is concerned that the COCUS may not provide sufficient information regarding the current utilization levels necessary to be able to develop adequate contingency plans.

3. Service providers are required to complete and submit a Months to Exhaust Worksheet with their application for additional codes, however these worksheets provide limited information relating to the utilization of telephone numbers within each CO Code.

4. The Commission notes that the CISC/CSCN is developing a methodology for reporting telephone number utilization levels within each assigned NXX; however, this work has just begun and is therefore, not available for current consideration.

5. The Commission is of the opinion that the current processes and reporting requirements are insufficient to address the risks associated with this Plan. The social and competitive repercussions, which would result if the remaining CO codes within NPA 416 exhaust before the new NPA is available for assignment, are significant. Specific and effective monitoring of assignment rates and utilization levels must be introduced immediately, and continue until relief is available.

6. The Commission has examined several means by which code conservation practices can be promoted in the period prior to NPA relief. As set out in this order, the Commission finds it is necessary to invoke strict utilization monitoring/reporting criteria for the CANCNA, code holders and other users. The Commission notes, however, that the implementation of code conservation measures is not a substitute for proper NPA relief planning.

7. Effective immediately, Bell shall cease its remaining role as NPA 416 relief co-planner. The CNA shall continue to undertake all responsibilities established in the Guidelines, in addition to the directions contained herein.

8. The CNA shall undertake an analysis of all potential demand not included in the current COCUS, including future NPA code protection requirements, proposed CLEC requirements, etc. and report these findings to the Commission no later than 29 January 2000. The report should also identify the earliest exhaust date, changes to the latest exhaust date, and any alternate proposals to the assignment of N-0-0 codes that might be used as a contingency.

9. All current code holders, as well as proposed CLECs who have identified NPA 416 as part of their markets, are required to complete and submit a COCUS for the 416 area to the CNA no later than 25 February 2000. To facilitate this process, the CNA shall issue, not later than 15 January 2000, a request for a special COCUS for the NPA 416.

10. The special NPA 416 COCUS will require all actual and identified potential code holders in NPA 416 to report to the CNA the status of all telephone numbers assigned to them as of 1 January 2000. Details are to be submitted, in confidence, to the CNA no later than 4 March 2000 and, as a minimum, shall reflect the following information:

For each NXX assigned, identify telephone numbers that are:

a) assigned and working;
b) assigned and pending;
c) reserved;
d) ported in;
e) ported out;
f) administrative (e.g., test, internal
company use, etc.);
g) spare;
h) other (with explanation).

All values shall be expressed in absolute values with the exception of item g) which should be stated as a percentage of the 10,000 numbers within the CO code.

The CNA shall develop an appropriate telephone number utilization input worksheet and distribute it to all code holders no later than 14 January 2000.

11. Where definitions developed by the industry of the above status categories exist, such definitions are to be used. Absent such definitions, the CNA is to develop and to provide such definitions to ensure consistent and accurate input is received.

12. In those instances where an entire NXX is assigned to one service provider (code holder) for use by another service provider (i.e., incumbent local exchange carrier (ILEC) dedicated NXXs to cellular) the service provider to whom these resources are dedicated is solely responsible for reporting the detailed status of each telephone number directly to the CNA. The code holder shall provide a list to the CNA of all such NXXs in NPA 416 and include the name of the service provider to whom the NXX is dedicated.

13. In those instances where resellers and/or agents are involved (e.g., personal communications service (PCS), pre-paid cellular), the code holder shall be responsible for submitting the utilization information.

14. With respect to pre-paid type services, service providers are to identify to the Commission details as to how and when numbers are recovered and reassigned, no later than 25 February 2000. In addition, providers of pre-paid type services shall identify those numbers assigned to these services which have not been active for a period of three months or more.

15. By 28 April 2000, the CNA shall finalize and file, with the Commission, a single report reflecting the results of its analysis of the telephone number utilization and COCUS submissions. In particular, the CNA shall identify any weaknesses with regard to the way in which telephone numbers are utilized in NPA 416. The CNA shall also include any recommendations it might have as to how to improve utilization levels in under-utilized CO codes or otherwise promote code conservation practices in NPA 416.

16. The CNA is to convene a meeting of the Planning Committee to develop a contingency plan (e.g., an NPA specific code conservation plan) and to file the plan with the Commission no later than 4 March 2000. At a minimum, the code conservation plan should address how new entrants might be assured of receiving an NXX in NPA 416 up to 5 March 2001, and how requests for large blocks of number reservations by consumers might be addressed.

17. Beginning 1 July 2000, all code holders and potential code holders in NPA 416 are required to submit a quarterly jeopardy COCUS (J-COCUS) report to the CNA by the first working day of each quarter. The CNA is to analyze the input, aggregate the results, and file a report of the results with the Commission within 30 days following the scheduled date of receipt of J-COCUS input. The report should identify any areas of concern the CNA might have and propose a resolution for each concern.

18. Effective 1 July 2000, all applications for CO code assignments must include a telephone number utilization report as identified in this order or otherwise by the Commission. Should assignment rates accelerate in the interim and negatively affect the exhaust date, such reporting requirements may be advanced. Code holders shall be required to take whatever steps are necessary, or as further directed by the Commission, to fully maximize telephone number utilization.

19. The CNA shall advise the Commission of the monthly assignment rates of NXXs within 15 working days following each month-end. The CNA shall notify the Commission within two working days of the assignment, when the 700th NXX has been assigned in NPA 416.

20. The Commission recognizes that the reporting requirements identified in this order will require additional effort on the part of the CNA and service providers operating in the 416 area code. These monitoring and reporting requirements, coupled with the development of a contingency plan, are designed to ensure that sufficient NXXs are available to meet the service needs of all existing and new service providers, as well as customers between now and the spring of 2001.

21. All service providers are to provide advance notice to the Commission of all public announcements including billing inserts, etc. for review prior to release. Members of TTA who follow a common program need only submit a single notice. A TTA membership list should be attached to such notices.