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Ottawa, 1 June 2010
BY E-MAIL
Glenn Pilley
Director
Canadian Numbering Administrator
1516-60 Queen Street
Ottawa, ON K1P 5Y7
pilleyg@saiccanada.com
RE: Central office code assignment practices
Dear Mr. Pilley:
The purpose of this correspondence is to clarify central office (CO) code assignment practices in circumstances where established competitive local exchange carriers (CLECs) plan to expand into new exchanges.
Background
Entities wishing to operate as new CLECs in Canada must obtain regulatory approval from the Commission by satisfying several entry obligations.[1]
In order to meet these obligations, prospective entrants must conduct a number of activities including, among other things, entering into interconnection arrangements with other carriers, negotiating various types of agreements, and obtaining numbering resources from the Canadian Numbering Administrator (CNA). However, prior to engaging in these activities with a prospective entrant, many of these organizations commonly require the prospective entrant to demonstrate that it has obtained regulatory approval to operate as a CLEC.
In order to facilitate this process, the Commission will, in many cases, issue a letter to the entity granting it “proposed status” as a CLEC. Although not yet approved to operate as a CLEC, prospective entrants may use their “proposed status” to demonstrate to organizations such as the CNA that the prospective entrant has obtained a measure of regulatory support to conduct activities necessary for it to meet its entry obligations.
Once an entity demonstrates to the Commission that it has met the entry obligations, and has Commission approval to operate as a CLEC, it may begin offering service in the exchanges for which Commission approval has been given, provided that it continues to satisfy its entry obligations.
Similarly, if a CLEC that is already operating in Canada wishes to enter or expand into a new market (i.e., a new exchange), it is free to do so provided that it notifies the Commission of its intentions to expand and satisfies the CLEC entry obligations in these new exchanges.
Central office code assignment for existing CLECs
Currently, in order to obtain CO codes for an exchange, the CNA requires that CLECs, including existing CLECs, provide proof of regulatory authorization to expand into a new exchange. As noted above, when existing CLECs plan to expand, they inform the Commission in a notification letter. This same notification letter is generally used by existing CLECs to demonstrate to the CNA that the Commission is aware of its expansion plans.
Once an existing CLEC officially notifies the Commission of its plans to enter or expand into an exchange, that information becomes publicly available to its competitors before it has had the opportunity to fully satisfy its entry obligations and enter that exchange.
Given this situation, Commission staff is of the view that CLECs that are listed on the Commission’s website as having CLEC status should be able to obtain numbering resources from the CNA without having to make their specific expansion plans public. This change would ensure that proposed CLECs and existing CLECs are given the same opportunity to acquire CO codes without having to publicly disclose their expansion plans.
As such, Commission staff considers that for the purposes of assigning CO codes, the CNA is to consider CLECs already operating in at least one exchange in Canada, per the Commission’s website, to have obtained regulatory support to acquire CO codes from the CNA. As such, in order to obtain CO codes in new exchanges, these CLECs are only required to demonstrate to the CNA that they presently operate as a CLEC in at least one other exchange in Canada.
Commission staff notes that all CLEC obligations, reporting requirements and approval processes remain the same.
Sincerely,
Original signed by
Mario Bertrand
Director
Competition Implementation and Technology
Telecommunications
c.c.: CNAC Board Chair (doug.birdwise@bell.ca)
[1] See www.crtc.gc.ca for the full list of CLEC obligations.
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