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Decision CRTC 2001-475

Ottawa, 9 August 2001

Allocation of three-digit dialing for public information and referral services

Reference: 8665-C12-12/00

Table of contents

Summary of the decision

Three-digit dialing (e.g. 411 and 9-1-1) is used to provide public access to specific services. Currently, only 211 and 311 are available for other uses in Canada.

In May 2000, the Commission received two applications from the Canadian National Institute for the Blind (CNIB). One application asked the Commission to assign one of the remaining three-digit numbers to the CNIB so it could provide blind and visually- impaired Canadians with access to a national information service. In a second application, the CNIB asked the Commission to approve a cost-recovery proposal for access and provision of this service.

In June 2000, the Commission received an application from a group spearheaded by the United Way of Canada, which asked the Commission to assign 211 as the number Canadians could call to access community, social, health, government information and referral services.

The Commission issued Public Notice 2000-151 on 8 November 2000, inviting comments on these applications and related issues. The public notice also sought comments to develop guidelines for the assignment of three-digit dialing codes.

In this decision, the Commission establishes those guidelines, which the Commission then used to review the merits of the two three-digit applications. As a result of careful consideration, the Commission denies the applications by the CNIB and accepts the proposal of the group spearheaded by the United Way of Canada for the allocation of 211 dialing to provide information and referral services. The Commission encourages the information and referral service providers to help blind and visually-impaired callers to effectively use the information services offered by the CNIB.

Background

1. Within the North American Numbering Plan (NANP), which provides the framework for a continent-wide telephone number system, unique three-digit (N11) codes are assigned as an industry standard to provide specific types of services. For example, the public can access 411 for directory assistance, 611 for repair assistance and 9-1-1 for emergency services, including fire, police and medical emergencies. The 811 code has been assigned for subscribers to contact a telecommunications service provider's business office in Canada. Any Canadian telecommunications carrier can use 411, 611 and 811. 

2. For a number of years, the 511 number has been held in reserve in Canada for access to Message Relay Services (MRS) by hearing persons who wish to communicate with deaf persons. Presently, access to MRS by the hearing is provided by a 1-800 number. Access to MRS by the deaf is provided by a 711 number. Consequently, in Canada, only 211 and 311 are currently available for assignment.

CNIB application for N11

3. In its 15 May 2000 application for N11 dialing, the Canadian National Institute for the Blind (CNIB) requested:

4. The CNIB stated that the ICB is a national network of English and French library and information services that is available to blind and print-impaired Canadians.

5. The CNIB also explained that the telephone access component of the ICB, called VISUNEWS, is now a pilot-project providing access to newspapers, magazines, reference and information services, and reader-advisory services. A menu-driven, interactive, voice response system, VISUNEWS allows users to make choices by voice command or by telephone keypad. User sessions are limited to 35 minutes; users must register with CNIB to use the system, and access requires an identification code and a password. VISUNEWS is also available on the CNIB library's Internet web site.

6. The CNIB maintained that an abbreviated dialing code (such as N11) is essential to the success of telephone access to the ICB service by blind and print-impaired persons.

CNIB's cost recovery proposal

7. In its 15 May 2000 application for cost recovery, the CNIB requested that the costs of the systems and telecommunications resources required to provide access to the ICB be covered through a monthly telephone subscriber per-line charge, similar to that which supports MRS for the deaf.

8. The CNIB submitted that costs include the VISUNEWS platform in Toronto, the 1-800 long-distance access, and the cost of facilities to connect it to the public switched telephone network (PSTN). The CNIB estimated that these costs amount to approximately $0.018 per local telephone line per month.

9. The CNIB asked the Commission to order all LECs to remit the equivalent of $0.02 per local telephone line per month to the CNIB to recover the costs of ICB.

10. The CNIB proposed that LECs would then recover their costs through a subscriber-line surcharge similar to the MRS surcharge and that the MRS and ICB surcharges could be blended into one surcharge.

United Way et al.'s N11 application

11. On 26 June 2000, the United Way of Canada, Inform Canada, United Way of Greater Toronto and Community Information Toronto (United Way et al.) requested that an N11 code be assigned for non-commercial use across Canada to provide access to information and referrals (I & R) for community, social, health and government services. The United Way et al. application was supported by Le Centre de référence du Grand Montréal (Information and Referral Centre of Greater Montreal), Family Services Canada, the City of Edmonton Community Services and many other parties.

12. United Way et al. proposed that:

13. United Way et al. stated that collaborative efforts among social service organizations are now underway in some communities and being planned in others to implement I & R services. These services will be provided according to agreed-upon standards developed by social service organizations and will require endorsement by the appropriate level of government. Standards are in place for a comprehensive database of information about services provided by communities and various levels of government. The standards also call for the use of appropriate call centre technology, accessibility for people with disabilities, multilingual accessibility and trained I & R specialists to assist callers. In addition, I & R services will initially be conducted for 70 hours per week; the objective will be to provide 24-hour, seven-day-a-week service. Funding sources will include United Way organizations, municipalities, provincial governments, and revenue from services and products such as training and directories.

14. United Way et al. proposed that a subcommittee of the CRTC Interconnection Steering Committee (CISC) be formed to address technical issues regarding 211 access.

Public consultation process

15. On 8 November 2000, the Commission issued Public Notice CRTC 2000-151, Seeking public input on three-digit dialing for national agencies' information services. This notice asked for comments on the applications by the CNIB and United Way et al. In addition, the Commission asked for criteria to be used to determine the assignment of N11 codes. In addition, the Commission asked for comments on several issues related to the applications.

Criteria for assignment of N11 codes

16. In PN 2000-151, the Commission asked for comments on whether criteria for the use of the remaining N11 numbers should be established and, if so, what those criteria should be to help the Commission determine the type of organization or services that may be assigned one of the remaining N11 numbers.

17. The CNIB proposed the following criteria for an appropriate use for N11:

18. The CNIB stated that, among other things, these criteria would ensure that limited N11 codes will not be used as a source of revenues that provide advantage to those who would have access as compared with those who do not have access. The CNIB added that its criteria will also ensure that the services provided will aid the community as a whole, including the disabled.

19. United Way et al. proposed that N11 assignment be based on the following criteria:

20. United Way et al. added that a 211 number would provide efficient and effective access to community services without the frustration and confusion associated with identifying what services exist, knowing where to call, and determining which resources would be most useful when searching for information.

21. United Way et al. also proposed that N11 numbers be assigned to organizations that can demonstrate a national affiliation/structure, an intent to support a nationwide N11 implementation, the capacity to manage the N11 resource, and deliver high quality, effective and efficient service.

22. Most commenting parties noted that N11 is a scarce resource and that uniform criteria should serve as the basis for the assignment of unused N11 codes. These parties included Bell Canada, Island Telecom Inc., NewTel Communications Inc., Saskatchewan Telecommunications (collectively, Bell Canada et al.); AT&T Canada Telecom Services Company and AT&T Canada Corp. (collectively, AT&T Canada); TELUS Communications Inc., TELUS Communications (B.C.) Inc., Québec-Téléphone (now known as TELUS Communications (Québec) Inc.) and TELUS Mobility Cellular Inc. (collectively, TELUS). These parties recommended the consistent use of the remaining unassigned N11 codes throughout the NANP.

23. Bell Canada et al. noted that in 1992, the Canadian Steering Committee on Numbering (CSCN) had formulated a general policy outlining criteria for the use of unassigned N11 numbers.

24. These criteria state that the application of N11 should be uniform and consistent throughout the NANP area to the maximum extent practical. In addition, the unassigned N11 codes should be designated primarily for basic, or adjunct-to-basic, telecommunications services of a universal social value rather than for commercial use by certain industry segments.

25. Bell Canada et al. proposed that this policy continue to serve as a benchmark for assessing the appropriateness of N11 code allocations.

The necessity for three-digit dialing

26. Generally, parties were of the view that there should be a sound or convincing rationale for having N11 dialing, instead of a number with seven or more digits and that N11 should be a public interest requirement, not a specific customer requirement. In addition, three-digit dialing should be limited to purposes that require the use of a short, easily-recalled number to access services that meet an urgent need.

27. The Canadian Wireless Telecommunications Association (CWTA) stated that a convincing rationale could be one related to matters of urgency and the avoidance of confusion. The CWTA also stated that simply having a requirement for a unique phone number would not be a convincing reason.

Whether to assign N11 to an organization or a service

28. The view of AT&T Canada, TELUS, CWTA, City of Calgary and a number of individuals was that N11 should not be assigned to any one organization. N11 should be allocated to a service or purpose that reflects universal social values and serves the broad public interest of Canadians.

29. TELUS recommended that N11 be allocated to a public-interest service that is implemented locally in a consistent manner and available nationwide. TELUS also stated that the prospective service providers should provide non-discriminatory access to all available services.

30. Other parties maintained that if an abbreviated dialing code is required to provide information services, the appropriate level of government should administer it. It was argued that such services should be contracted out by government to agencies who would provide the services and be accountable to government. It was also noted that the federal government provides an information service via a 1-800 number (1-800-OCanada) that has the capacity to refer inquiries to other government levels who, in turn, provide information on community-based services; this channel should be used to avoid the service-delivery duplication.

Whether to assign N11 to particular types of organizations

31. A number of parties stated that the criteria for the assignment of N11 should consider whether the N11 service would be delivered by non-profit or "non-commercial" organizations.

32. Call-Net Enterprises Inc. stated that N11 access codes should be used for non-commercial or not-for-profit purposes and that these should not be used to provide a commercial entity with a strategic advantage over its competitors.

33. TELUS and CWTA maintained that the not-for-profit condition is unnecessarily restrictive.

34. The Commission concurs that allocation of N11 should take into account:

35. The Commission notes that both CNIB and United Way et al. stated that allocation of N11 be based on a serious need for such numbers.

36. The Commission considers that guidelines for allocation of N11 should be based on serving the broadest public interest, as opposed to a specific narrow or special interest. The Commission also considers that uses that are designed to provide access to the telephone network to disadvantaged individuals or groups fall within a guideline of serving the broad public interest and would not be merely serving a narrow special interest or need.

37. The Commission considers that N11 should be allocated to services rather than to any specific organization. Assigning an N11 to an organization could be perceived as conferring an undue preference on one organization over another. However, in allocating N11 to services, the Commission's view is that applicants that would provide the services should present some evidence of stable organizational capabilities and plans to sustainably deliver these services.

38. The Commission also considers that the three-digit code to provide access to these services should be widely deployed on a geographic basis, and available not only during normal business hours but extended hours as well.

39. The Commission agrees with CSCN that, where possible, the use of N11 in Canada should be consistent with its use throughout the NANP. The Commission also agrees with CSCN that the code should serve as an adjunct-to-basic telecommunications service in providing a service of a universal social value, as opposed to providing a commercial advantage to certain industry segments.

40. The Commission notes the concerns expressed by some parties that services in the broad public interest provided via N11 should be administered or maintained by the appropriate levels of government. The Commission notes the comments regarding the federal government's toll-free access number and web site that provide information on programs and services that are national in scope, and that may have a local service-delivery component. Some information provided by governments may duplicate those provided by certain service organizations.

41. The Commission's view is that the services provided by community-based organizations can serve to complement those provided by various government sources. In addition, the Commission notes that community-based organizations would also provide users with information on services delivered by various levels of government.

42. Regarding the non-profit status or commercial orientation of the organizations providing services via N11, the Commission's view is that N11 should be used for a broad public good and that the N11 code and the services accessed via this code should be available to all Canadians. The Commission is of the view that the operation of the N11 service should not confer any competitive advantage on the N11 operator. However, the Commission recognizes that services ultimately provided as a result of dialing N11 may include services of profit and non-profit organizations, and this is acceptable.

43. Regarding the Commission's role in the administration of an N11 resource once it has been assigned, the Commission is of the view that, as stated above, N11 codes should be allocated to services, not specific service providers. However, the Commission notes that it would be open to using a public process to re-assign an N11 to another service if it feels the original assignment is not appropriate to the service being delivered.

The guidelines - Conclusion

44. In view of the above and in view of the scarcity of N11 numbers, the Commission concludes that the following guidelines are to be used to consider the allocation of unused N11 codes:

CNIB's proposal for N11 dialing

45. CNIB's application for N11 dialing was then reviewed in the context of the guidelines for the assignment of N11 codes.

46. In explaining the need for abbreviated dial access, the CNIB stated that, based on a National Library of Canada report issued in October 2000, an estimated 3.2 million Canadians are print impaired; all would be entitled to use the ICB. CNIB emphasized that the telephone is the single most relied-upon vehicle for information exchange and that, for blind or print-impaired individuals, memorizing a 10-digit number can be an insurmountable barrier to the regular use of the ICB.

47. The CNIB maintained that N11 access for the blind and print impaired is akin to three-digit dialing for MRS, which allows the hearing impaired to use the telephone network. The CNIB also stated that both provide critical access to communications and information to people who would otherwise not be able to access these services.

48. However, comments received from the Canadian Federation for the Blind (CFB), the Council of Canadians with Disabilities (CCD), the Canadian Council for the Blind, and the National Federation of the Blind (NFB) expressed concerns about the merits of CNIB's arguments. CFB and CCD stated that the blind do not need unusual consideration since most blind persons have used seven-digit dialing all their lives.

49. The CFB noted that the lack of sight does not in any way impede the ability to use a telephone keypad to make a simple phone call. While some elderly or physically-disabled people have difficulty using the keypad, this is equally true for sighted and blind people.

50. The NFB stated that, with the availability of speed dial and voice-activated dialing, it is not overly important that a three-digit code be provided to access the ICB.

51. A number of individuals, including the blind, were divided on this matter. While some rejected CNIB's contention that an abbreviated dialing code is essential to access an information service like ICB, others supported CNIB's efforts to provide simple ICB access.

52. In commenting on CNIB's comparison of N11 access to the ICB with three-digit access by the deaf to MRS, TELUS and Vidéotron Communications Inc. stated that N11 dialing to access ICB would be to provide an enhanced information service for a limited number of users. Three-digit access to MRS is necessary to provide the deaf with basic telephone service access to the PSTN. MRS also ensures that everyone can use the network. Similar views were expressed by AXXENT Corp., CCD and other individuals.

53. Bell Canada et al., AT&T Canada, CWTA, Canadian Advanced Technology Association (CATA) and other parties opposed the assignment of a dedicated N11 code for the CNIB's exclusive use. CATA added that there are other businesses that provide alternative formats to the blind and visually impaired, and suggested that the Commission examine the possibility of opening up N11 service to all suppliers. CWTA noted that the use of additional access codes by the caller to the ICB information service removes the benefits of abbreviated dialing. Bell Canada et al. stated that N11 dialing to the ICB may provide value to the blind community, but there are other similar service organizations that could use N11 codes. The assignment of an N11 dedicated to accessing the ICB's information service may not be the most efficient use of an extremely limited supply of unassigned codes.

54. The Commission notes that a number of parties stated that seven- or 10-digit dialing is widely used and will continue to be used by the blind in their everyday lives. In addition, the Commission notes that, in order to access the ICB, the caller would be obliged to dial even more numbers to enter an identification code and a numeric password. Users of the ICB service would use it regularly, making the seven-digit number easier to remember, whereas an N11 number is more suitable for matters of urgency and may not be used as frequently as calls to the ICB service. In the Commission's view, these considerations appear to negate the CNIB's argument that abbreviated dialing is necessary to access this service. The Commission considers that CNIB has not demonstrated on a satisfactory basis that a three-digit code is necessary to access the ICB. Furthermore, the three-digit access being requested is to serve a specific group and restricted by password access. This does not meet with the Commission's criteria that there must be a compelling need for three-digit access to serve the broadest public interest possible.

55. Regarding CNIB's comparison of its proposed three-digit access with that of 711 access to MRS, the Commission acknowledges that MRS could be reached by the deaf via a seven-digit or an 800 number. However, the Commission notes that three-digit dialing is available to the deaf so that, from whatever their location, the MRS operator will know that they have a teletype (TTY) device, which will enable them to efficiently access the network for not only casual calling, but for emergency and urgent calling as well. MRS ensures that the deaf have access to, and can realize the value of, the telephone system to a degree approximating that of hearing users. Conventional seven-digit dialing by the deaf would not signal the switch and the MRS operator to handle a TTY device. By contrast, the ICB service provides access not to the network, but to content for a specific group of people registered with the ICB.

56. The Commission is of the view that the CNIB's ICB service does not fulfill a compelling need for three-digit access that cannot be satisfied by other dialing arrangements. In addition, should an N11 code be assigned to the ICB, the N11 code would essentially be assigned to a specific organization: the CNIB. The Commission also concludes that the ICB is not analogous to MRS for the reasons set out above. The Commission acknowledges that blind and visually-impaired persons must be able to access information. However, the Commission considers that for regular use of the ICB, a conventional dialing arrangement is sufficient to serve this purpose.

57. Accordingly, the Commission denies CNIB's proposal for three-digit dialing for access to its information service.

CNIB's cost-recovery proposal

58. CNIB proposed that LECs fund the cost of access to the ICB including the platform, 1-800 charges for routing calls to Toronto, and facilities to connect the platform to the PSTN. This implementation would involve the activation of its proposed three-digit code in all local switches of each LEC and WSP, which would incur negligible costs, according to CNIB. Ongoing costs would include local switching and routing to a toll-free number, long haul carriage and local facilities to connect to the ICB. CNIB added that these costs will be borne by the long-distance carrier chosen by the CNIB to provide the service and that this carrier would compensate the caller's LEC for using its network.

59. CNIB proposed that these costs be recovered by the LECs through a charge of $0.02 per month per active telephone number and remitted to CNIB. CNIB claimed that such funding will ensure that the ICB will make newspapers available without the lengthy delay in waiting for the audio tape version. CNIB also maintained that this line charge was similar to that for MRS and suggested it could be blended with that for MRS.

60. Parties who commented on CNIB's cost recovery proposal either supported the proposal or were opposed to it. These parties included Bell Canada et al., TELUS, Call-Net, AXXENT and CWTA, among others.

61. CWTA maintained that the ICB service is not analogous to MRS since the ICB provides content and there is no precedent that requires telecommunications service providers (TSPs) to fund a content service. Vidéotron and other parties expressed similar views that MRS is necessary for access to the network, whereas the ICB provides alternative access to an enhanced information service for a limited number of users.

62. Some individuals who supported the proposal stated that the $0.02 per local telephone line per month would be used to offset or eliminate long-distance charges to persons using the ICB service.

63. Bell Canada et al. stated that CNIB's proposed funding mechanism would need to be assessed relative to the underlying costs incurred by the CNIB to provide the ICB service. Certain administrative details for collection and remittance of these charges from all TSPs in Canada would have to be resolved prior to the implementation of the ICB service. In addition, the billing systems of every TSP would need to be modified to accommodate the surcharge to their subscribers or to blend it with any existing MRS charge. In reply, CNIB maintained that the modifications would be trivial and that telephone companies have mechanisms in place to change billing rates for TTY-711 access, 411 and 9-1-1, without a measurable impact on their operations.

64. AT&T Canada had no objection to CNIB's cost proposal, provided that each LEC be required to pass that charge on a consistent basis to its subscribers. However, AT&T Canada stated that, while incumbent local exchange carriers (ILECs) can recover their costs through an explicit subscriber line charge, most competitive local exchange carriers (CLECs) do not recover their costs this way. AXXENT saw CNIB's cost recovery mechanism as unbalanced; all do not levy an explicit MRS cost recovery charge.

65. The CWTA noted that the proposed CNIB charge of $0.02 per local telephone line per month would provide CNIB with an annual operating profit of $429,600. This would be the difference between the cost of access, $0.018 per local telephone line per month and the proposed per-line charge. In reply, CNIB stated that there were no means by which fractional cents per month could be charged to subscribers and that it did not intend to profit by it. CNIB also noted that the cost estimates are intended to defray the long-distance charges incurred by callers to the ICB; any excess funds would be used to improve the information-service delivery technology.

66. The Commission regards CNIB's cost recovery proposal for telephone access to the ICB service as a separate matter from its request for N11 dialing and considers the two applications as independent of each other. Indeed, the CNIB stated in its reply that the ICB project can provide improved functionality and service with the approval of either proposal.

67. The Commission notes that there are many similar organizations that provide information services to specific disabled groups and other segments of the population. Levying a charge on active telephone numbers to fund the costs of services provided by such organizations would be no different than what is proposed by CNIB.

68. CNIB asserted that Telecom Decision CRTC 99-16, Telephone service to high-cost serving areas, dated 19 October 1999, clearly set a precedent for provision of content, which includes directories, directory assistance and operator services as part of the basic service objective. However, the Commission notes that in Decision 99-16, the basic service objective provides for access to directory information and operator services, and that the focus of such a service is on the effective routing of calls and use of the network. While it is true that 411 operator-provided directory service delivers content in the nature of telephone numbers, the intent of such a service is to allow subscribers to effectively and efficiently access the network. The Commission is of the view thatthe content services of the ICB are not comparable to services provided by directory assistance in terms of their intended purpose.

69. With respect to CNIB's proposal that access to its information service be funded in a similar way to MRS, the Commission notes that there already is subscriber line charge funding for access to MRS as well as emergency 9-1-1 services. However, both MRS and emergency 9-1-1 access differ fundamentally from the information service proposed by CNIB. MRS is meant to put the deaf caller in the same position as the hearing caller in their use of the network. If MRS was not funded, deaf users would have to pay to access MRS. Thus, using the telephone for basic access would cost them more than it costs hearing users. As for 9-1-1 access, the Commission notes that its purpose is fast access to emergency services. Given this, and the fact that the general population is better off in having 9-1-1 access, it is appropriate that subscribers pay for it.

70. In light of the above, the Commission denies CNIB's proposal for a per-line charge on active telephone numbers to recover costs to provide access to ICB services.

United Way et al. - 211 application

71. United Way et al. noted that experience with information and referral (I & R) services in Canada has shown that it often takes several calls before people finally connect with the services they need. Access is also more difficult for people dealing with the challenge of age, language barriers, low levels of literacy, poverty, homelessness, hunger and family crisis. The result is frustration, confusion on the part of callers, and wasted time and effort by people at organizations who are trying to help connect callers with an appropriate service agency representative.

72. United Way et al. provided categories of calls that are consistently among the top 10 reasons for calling community I & R services providers. These include financial assistance, health, housing, children's services, counselling, employment and education.

73. A few parties were opposed to assigning 211 to the model proposed by United Way et al. Although they acknowledged that the proposal meets the requirement of providing an essential public interest service, these parties noted that the 211-service responsibility demands control and accountability by way of government contracts and agreements with chosen service providers.

74. In emphasizing the need for three-digits for I & R, United Way et al. stated that Canadians would benefit from 211 dialing in much the same way as people in the U.S. would for the reasons that the Federal Communications Commission gave in July 2000 when it assigned 211 for I & R:

"…with a large number of toll-free telephone numbers, confusion is inevitable and the increased margin of error in dialing eleven digits creates obstacles to use of community information and referral services, particularly in urgent situations"; and that "directory assistance for toll free numbers does not lessen this confusion because it lists entries by name but not service or need category. In addition, local 7-digit numbers are not viable alternatives because they are difficult to distinguish from other local business and community service numbers and may not help travelers, the recently located, and those with mental and physical limitations who would have to dial various seven or ten digits to get access to help."

75. The Commission notes that in the U.S., 211 for I & R has either been implemented or is being considered in 44 states, and that the volume of calls in some regions has increased significantly compared to the call volumes for I & R services that were accessed by dialing seven digits.

76. United Way et al. stated that its proposal for establishment of 211 for community, health, social and government I & R is supported by a collaborative group of over 90 organizations from across Canada that are working in their communities to develop an interest in and a capacity to implement 211. These organizations include such non-profit and public-sector community I & R services providers as United Ways, municipalities, regional and provincial governments, local distress centres, Kids Help Phone and volunteer centres. Police and emergency medical service agencies are also working in their communities to develop an interest in and a capacity to implement 211. These agencies already have an N11 (9-1-1), but the introduction of 211 would alleviate them of the need to respond to less-urgent I & R calls. Currently, United Way et al. stated that community I & R organizations collect and maintain a comprehensive database of available services, and manage inquiry services to help individuals and families.

77. There was widespread agreement by parties, including the municipal organizations that commented on the United Way et al. proposal, to assign 211 for access to I & R services.

78. The Commission notes that support for United Way et al.'s 211 initiative has been expressed by many volunteer organizations at the national, regional and municipal level, including Epilepsy Canada, Distress Centres, Elizabeth Fry and John Howard Societies, the Canadian Library Association, and municipal libraries such as the Vancouver Public Library, community centres such as Information Windsor and Surrey Community Services, and the Toronto Police Services Board.

79. The City of Toronto stated that the use of a simple and easy-to-remember number will significantly enhance accessibility and effectiveness of its community services, and reduce delays and inappropriate referrals. Historically, Toronto has supported central access to community information. The service is provided via a 10-digit telephone number that must either be looked up in a directory or obtained from police or other social agencies. Toronto stated that 15% of the city's 2.4 million people speak a language other than English at home; any I & R services must be provided in several languages. The Toronto Police Services Board stated that calls to 9-1-1 that are "211-type" calls could be quickly redirected to 211. 

80. The Federation of Canadian Municipalities and the City of Calgary concurred with United Way et al.'s proposal. Calgary stated that, as 211 consolidates access, effective channels will be required to link 211 and various municipal services. The North Eastern Ontario Communications Network Inc. (Neonet) stated that a comprehensive centralized location with an easy-to-remember three-digit number to access service information would greatly benefit the Timmins area. Neonet and United Way hope to establish a 211 program where databases can be combined from a number of fragmented services and trained personnel can refer calls to the appropriate resource.

81. The Commission notes that United Way's proposed model meets the criteria for 211 access in the following ways:

82. In light of the above, the Commission accepts the application by the United Way et al. and approves the allocation of 211 dialing to I & R services based on its proposed model.

Costs for 211 implementation

83. United Way et al. proposed that each telecom carrier would bear the reprogramming switching costs to re-route the 211 number to a seven- or 10-digit number of the I & R services provider, and no additional charge would be levied to the call centre receiving the 211 call. United Way et al. stated that the reprogramming and translation could be done when scheduled with other required work in servicing the affected area and would be spread over many years. United Way et al. added that the service network costs will be incurred incrementally as communities adopt 211 dialing.

84. United Way et al. proposed that there be no charges to the end user for dialing 211 as a local call. If 211 dialing is a long-distance call, the charges would be negotiated with the carrier and paid by the I & R services provider.

85. For wireless callers, United Way et al. proposed that the costs would be recovered by WSPs in their current monthly fee or contract for use. CWTA concurred with this proposal.

86. Bell Canada et al. stated that they are prepared to commit to implement, without additional charge, the switch modifications and network changes required to route 211 calls to the various community call-centre locations and to undertake any internal administrative work activities.

87. TELUS and AT&T Canada proposed that carriers be permitted to recover their start-up and ongoing costs associated with the use of the proposed 211 code.

88. TELUS stated that access to services such as 411, 711 and 9-1-1 are part of the Commission's basic service objective as set out in Decision 99-16. Consistent with the guideline that all future N11 allocations are in the broad public interest, TELUS submitted that all LECs should be obligated to provide their customers with access to the services provided through future allocation of N11 codes. In addition, those LECs must have the opportunity to recover related costs from their customers.

89. United Way et al. replied that telephone companies incur costs of reprogramming switches and other equipment in response to changes in the numbering system (i.e. area codes). The carriers, other service providers (i.e. Internet service providers, resellers) assume the associated costs, and end users with no specific compensation or cost recovery mechanism as directed by the Commission. All carriers and end-users bear these costs to keep up with changes in NANP.

90. The Commission notes that there is broad support from Bell Canada et al. and other parties for United Way et al.'s proposal that the implementation costs of 211 be assumed by the carriers.

91. With respect to the proposal that TELUS be compensated for implementing 211 access, the Commission notes that TELUS did not identify what these costs would be, or even if they would be significant. Furthermore, the Commission notes that 211 dialing will be implemented over a number of years and scheduled with other work on switching. In the absence of any cost details from Bell Canada et al., TELUS, and in the United Way et al. plan, the Commission considers that the cost issue is not significant.

92. In view of the above, the Commission directs the carriers to bear the cost of implementing 211 on an incremental basis.

Technical issues related to the assignment of N11

93. United Way et al. proposed the incremental establishment of 211 dialing, beginning with major urban areas and, in some cases, regions or provinces. For the most part, 211 will provide local access to I & R services. I & R services providers would retain their seven- or 10-digit number, so that people outside the 211 dialing area can still contact them. Calls placed on a wireless phone outside of the regular local calling area would be routed to the local 211 number in the location of the caller.

94. The 211 dialing area will require programming of switches so that 211 calls are routed to the seven- or 10-digit number of the I & R services provider. United Way et al. stated that discussions with wireline and wireless carriers across Canada indicated that if three months' notice is provided, carriers can schedule switch reprogramming with other necessary work to help reduce costs. For these calling arrangements, United Way et al. suggested that a CISC subcommittee could be asked to help resolve any technical issues.

95. With respect to the set up of I & R services, United Way et al. provided an implementation procedure. United Way et al. proposed that the Commission approve this procedure, which would include the identification of an organization's readiness to provide N11 service, an endorsement by the appropriate government authority, consultations with and notification to TSPs, and a public awareness campaign.

96. Bell Canada et al. stated that both the proposed service arrangements submitted by CNIB and United Way et al. are technically feasible. In response to United Way et al.'s suggestion for a CISC forum, Bell Canada et al. stated that they do not foresee a need for a CISC committee to address technical issues regarding N11 access.

97. Bell Canada et al. stated that implementing the proposed 211 service in different communities at different times requires collaboration amongst the community I & R services agencies and the TSPs operating in the 211 access area. To facilitate this, Bell Canada et al. recommended that the I & R services agency that is assigned the 211 code in a particular community will have the overall responsibility for planning, implementation and a consumer awareness program.

98. Bell Canada et al. also stated that, as the time required for 211 implementation planning and roll out would vary from community to community, United Way et al.'s proposed 12-week minimum standard notification period to TSPs may not be appropriate.

99. TELUS stated that, based on geographic coverage, technical and operational requirements for converting an N11 number at the switch to an aggregation point or 1-800 number will differ; delays by a service organization to serve a particular community would delay implementation and increase costs for the TSPs.

100. CWTA stated that it was unable to commit to any activities until all implementation issues for 211 have been resolved. CWTA also stated that the geographic coverage areas would have different implementation requirements with cost implications for both the initial 211 roll out and its ongoing operation. CWTA agreed with Bell Canada et al. that a 12-week notification period to activate 211 might not be sufficient.

101. In reply, United Way et al. stated that it expressly proposed extensive consultations with the telephone companies well in advance of the 12-week formal notice.

102. Both TELUS and CWTA maintained that any technical, operational or process issues associated with three-digit access should be addressed in CISC. The 12-week implementation plan is only acceptable to TELUS if that period follows the resolution of implementation issues at CISC.

103. The Commission notes that the United Way et al. plan for implementing I & R services with 211 access on an incremental basis, as well as the telephone companies' plans to provide 211 dialing appear to be technically feasible.

104. The Commission notes that United Way et al.'s procedure for implementing the provision of I & R services will be coordinated with social service agencies, subject to the organizations' readiness capabilities and delivery standards. The Commission considers that its approval of United Way et al.'s roll out plan is not necessary. The procedure requires the formal endorsement of the I & R services provider from the appropriate level of government for the areas to be served.

105. The Commission notes that TELUS and CWTA argued for the need to call on CISC to address technical issues regarding implementation of three-digit access and sufficiency of the 12-week notification period. However, these technical issues were mentioned in a general way and not detailed in their submissions; neither were the costs associated with these issues. Nevertheless, the Commission is of the view that, where necessary, such issues should be discussed at CISC and that these and any network issues are likely to be specific to the TSP in that area. The Commission notes that, in its reply, United Way et al. declared a willingness to discuss these issues at CISC.

106. In view of the above, the Commission directs that the parties involved in the implementation of 211 access use CISC as the forum to address any potential difficulties or concerns regarding technical issues.

Common sharing of 211 by CNIB and United Way et al.

107. The CNIB and United Way et al. stated that they jointly examined sharing one N11 code. Both parties determined that this was neither practical nor feasible. Both parties stated that the two services are significantly different in their implementation, technological aspects, the nature of services provided and the population served.

108. CNIB stated the success of both ventures requires marketing and promotional campaigns to stimulate public awareness of the N11 code and the services offered. Two different campaigns could create some public confusion regarding the nature of the services. The ICB would be made available as a national centralized service with all calls routed via a 1-800 number to Toronto while I & R services would be rolled out on an incremental basis, community by community. In CNIB's view, sharing the same code would mean a requirement to route calls for I & R services to Toronto and then to a community answering point; costs would have to be shared. As each new community adds I & R services, the access for the ICB would change and, among other things, existing users of the ICB in the region would need to be alerted to this change. The sharing of one code by both services would hobble both projects before they got off the ground.

109. In conclusion, United Way et al. and CNIB agreed that sharing a code would be impractical, inefficient, and ineffective for both organizations.

110. Bell Canada et al. stated that they are not aware of any technical or operational issues that would preclude the CNIB from participating in the use of the 211 dialing code. In fact, an underlying purpose of the United Way et al. proposal is to provide access to I & R services from a number of agencies within a geographic area. In addition, Bell Canada et al. and Call-Net suggested alternative, technically-feasible network arrangements that would allow CNIB to share the 211 dialing code with United Way et al. CNIB replied that this was not preferable or something it would recommend.

111. The Commission notes that the sharing of a common code is technically feasible. However, such an arrangement is not considered to be preferable or desirable by both applicants. The Commission agrees with CNIB and United Way et al. that, from a logistical standpoint, there is a potential for confusion on the part of callers; this could lead to the reduced effectiveness of the services delivered by both providers.

112. However, the Commission notes that United Way et al. stated that they are "willing to support the efforts of CNIB to ensure that I & R organizations are aware of the ICB service". The Commission considers that I & R services can effectively provide blind and visually-impaired callers with the necessary information and referrals that would connect them to the information services offered by the CNIB, and encourages I & R services to do so.

Secretary General

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

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