Letter
Ottawa, 24 December 2004
Transmitted Electronically
Reference: 8698-C12-17/01 and 8698-C12-14/01
To: All ILECs, including Independent Companies, CLECs, WSPs, proposed CLECs, Resellers, potential VoIP providers as per VoIP Proceeding and the Canadian Numbering Administration Consortium
Subject: 2005 General Numbering Resource Utilization Forecast and Area Code 519 Jeopardy Condition
On 16 December 2004 , the Canadian Numbering Administrator (CNA) issued a request to all current and potential Central Office (CO) code holders to submit the 2005 General Numbering Resource Utilization Survey (G-NRUF). This solicitation for input is based on procedures reflected in the Canadian NPA Relief Planning Guidelines (the guidelines), which were approved by the Commission in Interconnection Steering Committee - Consensus items, Telecom Decision CRTC 2003-55, 13 August 2003.
Additional 2005 G-NRUF requirements
As indicated further in this letter, there is an immediate requirement for all telecommunications service providers, as well as any entity that forecasts a requirement for dedicated CO codes or large quantities of telephone numbers to examine their needs in each Canadian area code and to respond in a complete and timely fashion to the G-NRUF request.
In addition to other CNA responsibilities, the Commission has established the CNA as a neutral third party, responsible for area code relief planning. Staff notes that the Commission has frequently stated that the CNA requires the full co-operation of users of numbering resources in order to have the information it requires to undertake its responsibilities. The Commission notes that parties are required to provide the CNA with their forecast information and that the CNA is required to treat as confidential all company-specific numbering forecast information. Such information is therefore not disclosed to any party other than the Commission and its staff.
By way of this letter, staff reminds all current and potential CO code holders and advises any entity which expects to have numbering resources available to it in the next decade that it is their responsibility to advise the CNA of their needs. Entities that are not current CO Code holders but expect to have entire CO codes, or large quantities of telephone numbers within an area code available for their use in the six year NRUF period ending January 2011, are required to advise the CNA through the G-NRUF process by no later than 7 February 2005. Failure to submit forecast requirements directly to the CNA or indirectly via an access provider could result in the unavailability of numbering resources to such entities and/or their access providers.
To this end, entities are required to complete and submit the G-NRUF report directly to the CNA, or, if appropriate, confirm with their access provider that their forecast requirements have been included in the access providers' G-NRUF submission. If an entity is uncertain as to how it could make its requirements known, it should seek guidance from either Commission staff or the CNA prior to 7 February 2005.
NPA 519 Jeopardy Condition
Parties unfamiliar with the NPA 519 Relief Planning Committee (RPC) activities, its previous recommendations to the Commission, and the Commission's determinations on matters related to area code 519 relief may refer to the CNA website at http://www.cnac.ca/npa_data.htm#NPA519 and to NPA 519 Relief Plan (Southwestern Ontario) Telecom Decision CRTC 2004-62, 27 September 2004 (Decision 2004-62) http://www.crtc.gc.ca/eng/archive/2004/dt2004-62.htm for further information related to the establishment of the current relief date for area code 519.
On 17 December 2004 , the CNA and Commission staff met to review the results of a Special NRUF (S-NRUF) survey for area code 519. The S-NRUF was conducted pursuant to a Commission directive established in Decision 2004-62. In that decision, the Commission required that the CNA solicit new forecasts from all current and potential code holders from area code 519 to complete and submit to the CNA a special NRUF forecast that reflects all known and anticipated demand for each of the next 24 months.
As indicated in its letter of 21 December 2004 , the CNA indicated that Commission staff had confirmed the CAN's conclusion that a jeopardy condition for area code 519 exists. A jeopardy condition exists when there are insufficient CO Codes remaining in an area code to meet the forecast requirements for CO codes prior to when relief is scheduled to occur.
In Decision 2004-62, the Commission confirmed that area code relief would be provided in October 2006, which was the minimum 12-month period prior to the then forecasted exhaust date of October 2007. Based on the submissions received by the CNA and reviewed by staff, the current forecasted exhaust date for area code 519 has advanced by 17 months and is now March 2006.
If relief were to be provided in the minimum timeframe established by the Commission, as set out in the guidelines, the relief date would need to be established as no later than February 2005. Commission staff notes that the introduction of a new area code via an overlay of the existing 519 area code, requires the simultaneous introduction of 10-digit local dialing. In staff's view, there is insufficient time for the industry and consumers to implement such a change within a two month period; however, an advancement of relief in this region is required. Staff is of the view that the industry has had several years' notice of the impending exhaust in area code 519, and as such, it should be well positioned to respond to this jeopardy situation. Staff is concerned however that the changes required by consumers to implement 10-digit local dialing will require time and much work in the area of consumer awareness.
Commission staff notes that in Decision 2004-62, the Commission cautioned TSPs operating in NPA 519 to be well-positioned to react to any further advancement of the relief date, should the special NRUF reflect an advancement in the exhaust date.
Given the urgency in this situation, staff is of the view that if the steps established in the guidelines to address a jeopardy situation were followed, more time than is currently available may be required to develop a contingency plan. To this end, Commission staff requests the CNA to convene an emergency conference call with members of the Relief Planning Committee (RPC) as soon as practicable to discuss how quickly the new area code can be implemented and how quickly a consumer awareness program can be launched. The CNA is to report to the Commission on the results of this meeting, by the end of January 2005.
Staff advises the RPC that it should not spend time debating the accuracy of the latest forecast. Members of the RPC should be prepared to provide to the CNA the earliest possible date for implementing the new area code and launching an aggressive consumer awareness plan. In considering a consumer awareness plan, staff requests that at the meeting that is to be convened by the CNA, the RPC come prepared to discuss the potential for retaining permissive 7-digit dialing within individual exchanges within area code 519 until such time as a new CO Code from the new 226 area code is implemented within the local calling area, for a period of several months after the new NPA is introduced. Although this proposal would require additional effort and close co-ordination between the CNA and the industry, it would offer consumers in certain portions of area code 519 additional time to make the changes necessary to accommodate 10-digit dialing.
Once staff has received the above noted report from the CNA, it shall forward the report and staff's recommendations to the Commission for its consideration. A Commission determination on this matter should be expected shortly thereafter.
With regard to the Jeopardy NRUF (J-NRUF) request released by the CNA on 21 December 2004, staff requests that all entities that are not current CO Code holders but expect to have entire CO codes, or large quantities of telephone numbers within area code 519 available for their use between now and the current relief date of October 2006 to so advise the CNA through the J-NRUF process by no later than 31 January 2005 . Failure to submit forecast requirements directly to the CNA or indirectly via an access provider could result in the unavailability of numbering resources to such entities and/or their access providers.
To this end, entities are required to complete and submit the J-NRUF report directly to the CNA, or, if appropriate, confirm with their access provider that their forecast requirements have been included in the access providers' J-NRUF submission. If an entity is uncertain as to how it could make its requirements known, it should seek guidance from either Commission staff or the CNA prior to 31 January 2005.
CNA Resources and Financial Requirements
Due to the above noted circumstance, the CNA is to assess its total resource requirements, including any additional personnel that may be required to manage this Jeopardy situation, and to provide the Commission and the Canadian Numbering Administration Consortium (CNAC), by 21 January 2005 a report which reflects its financial requirements. Staff recognizes that due to the uncertainty of the situation, the CNA may not have all of the information required to develop a specific budget. However staff requests that the CNA prepare a "best case/worse case" scenario. The CNAC is to examine the submission and advise the Commission of its assessment of the CNA's report, and of the CNAC's ability to appropriately compensate the CNA, from the national CNAC fund, for the additional work that will be required of the CNA. The response from the CNAC is to be filed with the Commission no later than 11 February 2005 . Should the CNAC fund balance be insufficient to appropriately compensate the CNA, the CNAC is requested to identify to the Commission what steps, if any, it recommends that the Commission take to secure the additional funding that will be required. Should the results of the current G-NRUF process indicate that other Jeopardy conditions or area code exhaust advancements are declared, the CNA and the CNAC should be prepared to respond to the Commission in a similar manner.
Should you have any questions regarding the contents of this letter, you may contact Brenda Stevens, Manager Numbering Administration and Regulatory Compliance at 819-953-8882 or Glenn Pilley Director Canadian Numbering Administration at 613-563-7242.
Regards,
Original signed by Scott Hutton for/
Shirley Soehn
Executive Director
CRTC Telecommunications Branch
cc. Mr. Glenn Pilley - Director Canadian Numbering Administration
Mr. Parke Davis - President CNAC for distribution to CNAC members
Date modified: 2004-12-24
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