Telecom Decision CRTC 2016-346

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Ottawa, 26 August 2016

File number: 8698-P8-201505992

The Consumers' Association of Canada, the Council of Senior Citizens' Organizations of British Columbia, and the Public Interest Advocacy Centre – Application to expand the current geographic boundaries associated with local number portability

The Commission denies an application from the Consumers' Association of Canada, the Council of Senior Citizens' Organizations of British Columbia, and the Public Interest Advocacy Centre in which these consumer groups requested that the Commission expand and/or revise the current geographic boundaries for local number portability. Based on the record of this proceeding, it would not be appropriate to expand location portability in Canada, aside from in the Metro Vancouver area as the Commission approved in Telecom Decision 2016-345, also issued today.

Application

1. The Commission received an application from the Consumers' Association of Canada, the Council of Senior Citizens' Organizations of British Columbia, and the Public Interest Advocacy Centre (collectively, the Consumer Groups), dated 15 June 2015, in which the Consumer Groups requested that the Commission expand and/or revise the geographic boundaries for local number portability (LNP)^{Footnote 1} to more accurately reflect the current network and marketplace structure for telephony services. They proposed that new boundaries could be established through a separate public process or that the task could be delegated to the CRTC Interconnection Steering Committee (CISC).
2. The Consumer Groups filed their application on the same date they submitted an intervention regarding TELUS Communications Company's (TCC) application to establish a special location porting zone (LPZ) across 17 exchanges within the Metro Vancouver area.^{Footnote 2}
3. The Consumer Groups submitted that they were not in a position to identify the specific criteria that the Commission should use to define new geographic boundaries for LNP. They argued, however, that expansion of the geographic boundaries of LNP, as TCC proposed for the Metro Vancouver area, elsewhere in Canada, would likely significantly benefit Canadian consumers.
4. The Consumer Groups submitted that competition between wireline and wireless services is undermined by the current LNP rules, particularly given the growing number of Canadians moving from wireline to wireless services. As an example, they submitted that under current rules, a consumer could port his/her number when migrating from a wireline to a wireless service provider, provided the number remains associated with the same exchange. The wireless customer could then move to another location in a different incumbent local exchange carrier (ILEC) exchange, but might not subsequently be able to port his/her number, depending on the type of service provider to which this consumer wished to migrate.
5. They submitted, further, that the current constraints on location portability^{Footnote 3} are not symmetrical or competitively neutral.
6. The Commission received interventions regarding the Consumer Groups' application from Bell Canada, the Canadian Network Operators Consortium Inc. (CNOC), the Independent Telecommunications Providers Association (ITPA), MTS Inc. and Allstream Inc. (collectively, MTS Allstream), Rogers Communications Partnership (RCP),^{Footnote 4} Saskatchewan Telecommunications (SaskTel), Shaw Telecom G.P. (Shaw), and TCC.
7. The public record of this proceeding, which closed on 19 December 2015, is available on the Commission's website at www.crtc.gc.ca or by using the file number provided above.

Positions of parties

8. CNOC and RCP supported the application and agreed that the Commission should delegate CISC to develop the criteria for broadening LNP boundaries across the country. However, Shaw submitted that the Consumer Groups' application was premature and that, should the Commission approve TCC's application, a notice of consultation on broader LNP might be appropriate.
9. The ITPA submitted that the Commission should initiate a public process to investigate the issue in depth and ensure that all industry players have the opportunity to fully participate. RCP submitted that certain constraints must be considered when establishing new LNP boundaries, such as 9-1-1, N-1-1, local calling areas, and the ability to distinguish local and toll calls.
10. Bell Canada, MTS Allstream, SaskTel, and TCC opposed the Consumer Groups' application due to the technical complexity and the costs required to implement the proposed changes.
11. Bell Canada specifically identified a number of potential issues – related to call routing, emergency and other public service calls, and rating and interconnection – that could result from general expansion of the geographic boundaries for LNP as proposed by the Consumer Groups.
12. Bell Canada further submitted that the unique characteristics of TCC's proposed LPZ are inherent to the concentrated and self-contained nature of the Metro Vancouver area exchanges and that it is only the unique confluence of these factors that makes that proposal feasible. Bell Canada emphasized that TCC's proposal does not show that LNP beyond the exchange is generally viable.
13. Similarly, MTS Allstream submitted that beyond TCC's proposed LPZ, expanded geographic boundaries would be highly inefficient for most companies to implement and would not be proportionate to any benefit to consumers or the companies. SaskTel also submitted that the potential public benefit to be gained from the feasibility analysis of broader location portability would not be commensurate with the effort that would be required.
14. MTS Allstream submitted that should there be any other potential LPZs in Canada that share the same characteristics as the one proposed by TCC, the Commission should consider them only if the relevant ILEC is able to develop a positive business case. In TCC's view, the next logical step in the progression of location portability would be for interested parties to apply for new LPZs on a case-by-case basis.
15. Commission staff issued a request for information, dated 6 November 2015, to Bell Canada, MTS Allstream, SaskTel, and TCC, in which the companies were asked (i) to identify any groups of exchanges in their operating territories that would meet the same circumstances as those described in TCC's application, and (ii) whether they had considered making a proposal similar to TCC's application for those exchanges. The companies indicated that they did not have any groups of exchanges in their operating territories that met the criteria identified in TCC's application. They added that they were not currently considering any applications for LPZs in any region in Canada.
16. In supplemental comments regarding the companies' responses, the Consumer Groups submitted that they would leave any future inquiry into the question of expanding LPZs elsewhere in Canada to the Commission or the companies to raise, as appropriate. They also submitted that, given their limited technical knowledge, they were persuaded that there were currently no locations that would be candidates for location porting expansion.

Commission's analysis and determinations

17. The parties that opposed the implementation of broader location portability raised the prospect of significant complexity and feasibility challenges, and significant costs. The large ILECs indicated that there were no other groups of exchanges eligible for an LPZ that meet the criteria identified in TCC's application and that they were not considering submitting any applications to establish an LPZ in any other location.
18. In addition, the Consumer Groups acknowledged that there were currently no locations that would be candidates for location porting expansion.
19. Accordingly, based on the record of this proceeding, it would not be appropriate to expand location portability in Canada, aside from within the Metro Vancouver area as the Commission approved in Telecom Decision 2016-345.
20. In light of the above, the Commission denies the Consumer Groups' application.

Secretary General

Related documents

• TELUS Communications Company – Application to establish a special location porting zone within the Metro Vancouver area, Telecom Decision CRTC 2016-345, 26 August 2016
• Local competition, Telecom Decision CRTC 97-8, 1 May 1997

Date modified:

2016-08-26