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Ottawa, 8 February 2012

File No.: 8620-C141-200906042


Mr. Don Holkestad
Operations Manager
CityWest Telephone Corporation
248 Third Avenue West
Prince Rupert, British Columbia
V8J 1L1

- AND -

Mr. Simon-Pierre Oliver
Director, Regulatory Affairs
Rogers Communications
333 Bloor Street East
Toronto, Ontario
M4W 1G9

Re:  Amtelecom’s and CityWest’s wireless number portability implementation plans for Rogers

Dear Sirs:

In a letter dated 20 May 2011, Rogers Communications (Rogers), on behalf of Rogers Wireless, confirmed that the latter was still interested in obtaining number portability in Amtelecom Telco GP Inc.’s (Amtelecom) Aylmer, Ontario, exchange and in CityWest Telephone Corporation’s (CityWest) Prince Rupert, British Columbia, exchange.  Subsequently, Amtelecom and CityWest filed plans for the implementation of wireless number portability (WNP) in the above-noted exchanges, based on the regulatory framework established in Telecom Decision 2008-122,1 as modified in Telecom Regulatory Policy 2011-291.2

In a letter dated 19 January 2012, Commission staff noted that the terms and conditions for the implementation of WNP in the small incumbent local exchange carriers’ (small ILECs) territories were modified in Telecom Regulatory Policy 2012-24.3  In that letter, Commission staff requested Rogers to indicate whether the company and the small ILEC had agreed to interconnect outside the small ILEC’s territory or directly within the small ILEC’s territory, or whether Rogers would withdraw its request for WNP in that territory.

In a letter dated 26 January 2012, Rogers indicated that it had reached an agreement with Amtelecom to continue to use the Bell Canada’s local and toll transiting services in order to exchange voice calls.  Rogers also indicated that it had not had sufficient time to develop its final position regarding its WNP request in CityWest’s territory and that it required clarification from the Commission on certain matters before a final decision could be taken concerning WNP in CityWest’s territory.

Specifically, Rogers requested clarification as to whether a wireless service provider could establish interconnection as a CLEC and use the bill-and-keep regime within a small ILEC territory, pursuant to Telecom Regulatory Policy 2012-24.  Rogers also indicated that it did not believe that it would be appropriate to deploy toll trunks directly with CityWest’s territory during the interim period pending the outcome of Telecom Notice of Consultation 2011-348,4 as the toll contribution regime for the small ILEC is under review.

Commission staff confirms that a wireless carrier could register as a Type II competitive local exchange carrier (CLEC) within a small ILEC territory and obtain WNP.  Commission staff also confirms that, in accordance with the principles established in Telecom Decision 2010-9085 and reiterated in Telecom Decision 2011-416,6  CLECs are required to route all long distance calls to small ILECs’ customers via toll interconnection trunks.

Rogers is requested to confirm to the Commission its final position regarding its WNP request in CityWest’s territory when it has reached a decision.

If Rogers and CityWest agree that interconnection will take place directly in the small ILEC’s territory, CityWest is to file the parts of its WNP implementation plan that need to be updated to address the changes caused by the agreed-upon arrangement, including revised costs with the methodology, assumptions, and detailed calculations for these costs, within 3 weeks after Rogers confirms its intent to interconnect within CityWest’s territory to the Commission.  Rogers may provide reply comments on the updated plan within the week following CityWest’s filling of its updated implementation plan.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules and Procedure, SOR/2010-277.

Yours sincerely,

‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manager, Tariffs

cc:  William Craig, CityWest,
Laurie Ventura, CRTC (819) 997-4589,
Sylvie Labbé, CRTC (819) 953-4945,
Denise Heckbert, Amtelecom,

[1]  Regulatory framework for the implementation of wireless number portability within the serving territories of the small incumbent local exchange carriers, Telecom Decision CRTC 2008-122, 18 December 2008

[2]  Obligation to serve and other matters, Telecom Regulatory Policy CRTC 2011 291, 3 May 2011, as amended by Telecom Regulatory Policy CRTC 2011- 291-1, 12 May 2011

[3]  Network interconnection for voice services, Telecom Regulatory Policy CRTC 2012-24, 19 January 2012. In that decision, the Commission decided that implementation of WNP was to be conditional on the wireless carrier directly interconnecting with a small ILEC, unless otherwise negotiated.

[4]  Review of regulatory framework for the small incumbent local exchange carriers and related matters, Telecom Notice of consultation CRTC 2011-348, 26 May 2011

[5]  Quebecor Media Inc. and Rogers Communications Partnership – Use of Bell Canada’s local transit service to deliver long-distance calls to small incumbent local exchange carriers’ customers, Telecom Decision CRTC 2010-908, 3 December 2010

[6]  TELUS Communications Company – Application for clarification and expedited relief concerning the manner in which Bell Canada intends to implement Telecom Decision 2010-908, Telecom Decision CRTC 2011-416, 11 July 2011

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