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Ottawa, 21 August 2013

Reference no.: 8620-R28-201308734

BY E-MAIL

Simon-Pierre Olivier
Director, Regulatory Affairs
Rogers Communications Partnership
rci.regulatory@rci.rogers.com

 

RE: Request to implement Wireless Number Portability in Wightman’s serving territory

Dear Sir/Madam,

Commission staff is in receipt of a letter from Rogers Communications Partnership (RCP) dated 1 August 2013 in which it requests that Commission staff confirm RCP’s interpretation of a certain portion of Telecom Regulatory Policy 2012-24 (TRP 2012-24) concerning direct interconnection for wireless carriers competing in a small incumbent local exchange carrier (ILEC) operating territory (paragraphs 108-116 of TRP 2012-24).

Specifically, RCP requested that Commission staff confirm that a wireless service provider (WSP) can interconnect directly to a competitive local exchange carrier (CLEC) operating in the territory of a small ILEC in order to implement WNP and to terminate traffic to that small ILEC. RCP argued that this interpretation would be consistent with the interconnection and WNP framework in large ILEC territories. Bragg Communications Inc. (Eastlink) filed a letter supporting RCP’s position.

Commission staff notes that in TRP 2012-24 the Commission specifically addressed the issue as to whether a WSP requesting WNP in order to compete in the territory of a small ILEC ought to be required to connect directly with the small ILEC. After having considered submissions both for and against such a requirement, the Commission set out its decision at paragraphs 115 and 116 as follows:

115. The Commission considers that, consistent with the approach in the large ILEC operating territories, WNP should be made available only to a wireless carrier that is willing to make a direct interconnection within a small ILEC operating territory for the purpose of transferring voice traffic. Based on the record of this proceeding, the Commission considers that, in light of the specific circumstances of the small ILECs, it would be appropriate for a wireless carrier to directly interconnect with the small ILEC in order for WNP to be implemented.

116. The Commission therefore decides that implementation of WNP is to be conditional on the wireless carrier directly interconnecting with a small ILEC, unless otherwise negotiated.

Further, staff notes that TRP 2012-24 does not provide for the interconnection method proposed by RCP. Staff notes that the phrase “consistent with the approach in the large ILEC operating territories” refers to the Commission observations in paragraph 114 that “... in the large ILEC operating territories, it is not possible for wireless carriers to make use of WNP without making a direct interconnection within the large ILEC territories they wish to serve.”

In light of the foregoing, Commission staff is of the view that RCP’s interpretation of TRP 2012-24 is inconsistent with the Commission’s determinations. Should RCP wish to propose changes to an existing regulatory policy, it would be required to file a Part 1 application with the Commission pursuant to the CRTC Rules of Practice and Procedure.

Yours sincerely,

Original signed by:

Mario Bertrand
Director, Dispute Resolution

c.c.: tsullivan@wightman.ca; regulatory.matters@corp.eastlink.ca

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