ARCHIVED - Telecom - Commission Letter - 8698-C12-14/01 - 2002 G-NRUF submissionsReporting of NXXs used to provide wireless service

File #: 8698-C12-14/01

Ottawa, 25 March 2002

To: Distribution List

Re: 2002 G-NRUF submissions Reporting of NXXs used to provide wireless services

Dear Sir or Madam:

As you know, the General Numbering Resource Utilization Forecast (G-NRUF) is conducted annually to provide data that is used to assist in forecasting the exhaust of geographic Canadian area codes. While undertaking the review of the 2002 G-NRUF, Commission staff have noted that a number of code holders are submitting a single G-NRUF encompassing multiple lines of business rather than a separate G-NRUF for each Operating Company Number (or line of business) as is required. For example, some Local Exchange Carriers (LECs) have submitted a single G-NRUF which encompasses its wireline and wireless lines of business, as well as data for other service providers.

There are several concerns associated with the submission of G-NRUF data in this manner. First, it inaccurately portrays a company's actual and forecast use of numbering resources if its data is combined with that of another company.

This limits the ability of the Commission and the Canadian Numbering Administrator (CNA) to analyze these forecasts and identify trends or other changes to the ways in which these resources are used.

Secondly, Section 5, paragraph 8 of the Canadian Numbering Resource Utilization Forecast Guideline requires that all code holders:

Submit separate C-NRUF data to the CNA for each of its Operating Company Numbers (OCNs) . An entity with multiple OCNs shall submit detailed C-NRUF data only for OCNs where it currently has CO Code assignments and/or reservations or where the entity intends to request CO Codes during the C-NRUF six year forecast period. Entities with multiple OCNs that have no intention of requesting CO Codes for an OCN during the C-NRUF six year forecast period shall advise the CNA accordingly.

Third, Section 2.0 of the Canadian Central Office Code (NXX) Assignment Guidelines states:

Code Applicants and Code Holders must obtain Operating Company Numbers (OCN), Revenue Accounting Office Codes (RAO) and Common Language Location Identifier (CLLI) Codes, and comply with the requirements for the assignment and use of such codes.

According to guidelines related to the assignment and use of OCNs, the same OCN can not be used to identify, for example, both a LEC and a WSP. Section 2.0 of the North American Country Code Assignment Procedures summarizes this requirement:

Separate and distinct codes are required for incumbent local exchange carriers, facilities-based certified local exchange carriers, unbundled local exchange carriers, local exchange resellers, competitive access providers, interexchange carriers, wireless and PCS carriers. Companies offering more than one type of service are required to obtain multiple codes, regardless if a separate legal entity is created.

Further, OCNs uniquely identify and associate a company with certain records in industry databases (e.g., rating and routing databases) that are used by all service providers throughout the North American Numbering Plan (NANP). Central Office codes assigned and dedicated for use in providing a particular type of service should be entered into these databases using an OCN that has been assigned to a company for that type of service. Assuming that this information has been correctly entered, the data contained in G-NRUF submissions should correspond with these records by accurately reflecting the actual number of NPA/NXX records that relate to a particular OCN in a particular NPA as of 1 January of that year.

Commission staff requests that your company assess its 2002 G-NRUF submission to determine whether the data provided was submitted under the appropriate OCN. You are encouraged to use the OCN guidelines located at the site below to assist you in this assessment:

http://www.necaservices.com/content/compcode/na_asign.pdf

If you are satisfied that your company has correctly submitted all G-NRUF data, please confirm this fact with the CNA and Commission staff by no later than 30 April 2002. Data that has been submitted using an inappropriate OCN should be resubmitted to the CNA with a copy to Commission staff by no later than 30 April 2002. This data should indicate which CO Codes or NXXs are assigned or forecast for use under the appropriate OCN for each year of 2002 to 2008.

If for some reason, your company has not been assigned a separate OCN for a distinct line of business as per the guidelines above, staff expects that a request for such an assignment will be made shortly. Following the assignment of a new OCN, it will be necessary for your company to alter industry database records so as to migrate NXX codes to the correct OCN. If such a migration is necessary, staff request that your company confirm with Commission staff and the CNA that these changes have been made by no later than 30 June 2002. In any event, a new 2002 G-NRUF should be submitted to the CNA with a copy to Commission staff by no later than 30 April 2002. If the any new OCN numbers are not available by 30 April 2002, the new G-NRUF should be submitted indicating that the new OCN has not yet been assigned.

Yours sincerely,

Brenda Stevens
Manager
Consumer Policy and Numbering Administration
Telecommunications

c.c.: Sheehan Carter, CRTC
Glenn Pilley, SAIC Canada