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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 31 July 2023

Our reference: 1011-NOC2023-0092

BY E-MAIL 

To: Distribution List

Subject: Call for comments – Implementing thousand-block pooling, Telecom Notice of Consultation CRTC 2023-92, 23 March 2023, as amended by 2023-92-1, and 2023-92-2

Pursuant to section 37 of the Telecommunications Act (the Act) and section 28 of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, all parties listed in the Distribution List are requested by Commission staff to provide comprehensive answers, including any supporting information, to the attached questions by 10 August 2023.

Any party identified below may also file interventions on other parties’ responses to the requests for information with the Commission, serving a copy on all those listed in the distribution list, by 15 August 2023.

The responses provided will become part of the public record and will be posted on the CRTC website. As set out in section 39 of the Act, and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest must be provided, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. In addition to the confidential version, an abridged version of the document omitting only the confidential information must be filed or reasons why an abridged version cannot be filed must be provided.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date. The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover page” located on this web page. 

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c. Jesslyn Mullaney, CRTC,

Distribution List

Bell Canada.bell.regulatory@bell.ca
Canadian LNP Consortium Inc., chantale.neapole@clnpc.ca
Consortium de gestion de la numérotation canadienne inc., bill.barsley@cnacexec.ca
Eastlink, regulatory.matters@corp.eastlink.ca
Independent Telecommunications Providers Association, jonathan.holmes@itpa.ca
Iristel Inc., regulatory@iristel.com
Neustar, marcel.champagne@team.neustar
Québecor Média inc., regaffairs@quebecor.com
Rogers Communications Canada Inc., regulatory@rci.rogers.com
Saskatchewan Telecommunications, document.control@sasktel.com
TekSavvy Solutions Inc., regulatory@teksavvy.ca
TELUS Communicatons Inc regulatory.affairs@telus.com

Attachment (1)

Question for all parties

  1. In section 2.1 of the Canadian Central Office Code (NXX) Assignment Guidelines,Footnote1 it is stated:
    • The North American Numbering Plan (NANP) resources are considered a public resource and are not owned by the assignees. Consequently, the resources cannot be sold, brokered, bartered or leased by the assignee for a fee or other consideration except in a manner consistent with Commission direction (e.g., a Commission-approved tariff).
      1. In light of current central office (CO) Code and telephone number preservation concerns, as expressed in Telecom Notice of Consultation (NoC) 2023-92, is the above restriction effective on an ongoing basis?
      2. Should there be additional restrictions on whether Canadian NANP telephone numbers can be sold or resold or otherwise made available by Canadian carriers to entities including domestic and foreign customers, carriers or resellers?
      3. If yes, explain in what circumstances and how such restriction(s) would best be put in place and enforced?
  2. In their interventions to this proceeding, a number of parties, including Bell Canada (Bell), TELUS Communications Inc. (TELUS) and Rogers Communications Canada Inc. (Rogers) indicated that if thousand-block pooling were to be implemented in Canada, it should be on the basis of 6-digit call routing, and that 7-digit call routing should be avoided as it would drive expenses and extend the implementation period among other risks.
    1. Describe and compare, using examples, the advantages and disadvantages of implementing thousand-block pooling on the basis of both 6-digit and 7-digit call routing, and how both approaches would impact CO Codes and telephone number (TN) preservation to different degrees across Canada?
  3. The Canadian Steering Committee on Numbering (CSCN) Report CNRE135A – Potential Remedies for CO [Central Office] Code and NPA Exhaust states that with respect to CO Code Sharing
    • Conceptually, carriers must have at least one location routing number (LRN) per Local Interconnection Region (LIR) or one LRN within the Local Calling Area (LCA) to obtain a TN block. Local exchange carrier (LEC)/Wireless service provider (WSP) Carriers requesting a TN block in LIR/LCA exchanges with no CO code of their own and no LRN would need to negotiate for the assignment of a facilitated LRN from either an existing incumbent local exchange carrier (ILEC) or competitive local exchange carrier (CLEC) servicing that same exchange.
      1. Explain how a “facilitated LRN” would be achieved. Consider in your response situations where the existing ILEC or CLEC servicing that same exchange both agrees and declines to negotiate.
      2. Do you see a reliance on “facilitated LRN” as being a useful alternative to the current requirement for LRNs if thousand-block pooling is implemented in Canada.
  4. In its submission of 19 May 2023, Rogers sets out its understanding of thousand-block pooling at paragraph 4(e)
    • …….This CLEC could get a 1k block of numbers from its LIR footprint code (e.g. 825-496-0000 to 825-496-0999). Other telecommunications service providers (TSPs) could receive other 1k blocks from the same NXX, but each of them would need to reference an existing LRN from an NXX that they currently own (i.e., from their own LIR footprint code). Under this assumption, 6-digit routing is sustained…
      1. Explain how it is technically feasible for other TSPs to receive other 1k blocks from the same NXX, but that each of them would have to reference an existing LRN from an NXX that they currently own (i.e., from their own LIR footprint code). Along with the explanation, provide a step-by-step network or process flow diagram that explains how this is implemented . If there is more than one possible implementation,, describe and provide details about each of implementation and its pro/cons.
      2. Explain what must occur if a TSP is new to the LIR and does not have an existing LRN from an NXX.
      3. Describe how this scenario, and more broadly the implementation of thousand-block pooling (TBP), might or not create competitive concerns for some carriers or TSPs compared to other carriers or TSPs, including consideration of larger carriers and smaller TSPs entering or competing in the same area.   
  5. In the CSCN Report noted above, Exchange Consolidation was a non-consensus item. On the record, of the NoC 2023-92 proceeding, several parties including Rogers and Quebecor Media inc. (Quebecor) submitted that LIR consolidation should be considered. For instance, Rogers noted that
    • the Metro Vancouver Area is comprised of 17 exchanges.Footnote2 CLECs can use a single LRN within this entire area and under TBP, they could use 1k blocks in 17 exchanges.
    • the Toronto LIR contains a single exchange, and that this LIR could easily be expanded to the entire Toronto LCA. Presently, CLECs can use their Toronto LRNs in the Toronto exchange only, while WSPs can use their Toronto LRN within the entire LCA.
    • similarly, the Montreal LIR is comprised of only 6 exchanges (i.e., the entire island of Montreal). However, the Montreal LCA (used by WSPs under wireless number portability [WNP]) contains 67 exchanges.
    1. Provide your view as to whether both ‘LIR expansion’ and ‘exchanges consolidation’ would effectively contribute to the preservation of CO Codes and telephone numbers and help mitigate numbering exhaust in Canada?
    2. What would be the appropriate milestones, timelines, and roles and responsibilities to achieve ‘LIR expansion’ and ‘exchanges consolidation’ such that it would effectively promote number conservation? If thousand-block pooling is implemented, should ‘LIR expansion’ and ‘exchanges consolidation’ be pursued in parallel?
    3. Even if ‘LIR expansion’ and ‘exchanges consideration’ were not undertaken as a Canada-wide project, could there be benefits to the industry agreeing, working within CISC, to some additional areas of the country where it would make sense to pursue this for significant number preservation impact? What would be key criteria for identifying the relevant areas?
  6. Many parties suggested that the use of geographic NANP telephone numbers should be reserved for certain services (e.g., voice-based services) and that there should be a restriction on the use of geographic NANP telephone numbers for other services (e.g. IoT/M2M or non-voice services). Rogers indicated in its interventions that it has undertaken an important internal study to maximize the use of non-geographic TNs. Commission staff also notes that the CSCN currently has an active TIF looking at non-geographic numbers.
    1. Do you agree that there should be a restriction on the use of geographic CO Codes and TNs for certain services going forward? If yes, specify for which services and why? If such a restriction is not appropriate, explain why?
    2. How should such a restriction be formulated and enforced?
    3. What would be potential unintended consequences of such a restriction and how can this be mitigated?
  7. At paragraph 34 of its intervention, Iristel Inc. (Iristel) indicated that the Commission should look at the rules for non-geographic numbers, and that it is currently not possible to send calls or SMS from and to non-geographic numbers belonging to different providers. Iristel submitted that the Commission could consider mandating interconnection for non-geographic numbers
    1. Are there technical or other reasons why calls or SMS cannot or should not be sent from and to non-geographic numbers belonging to different providers?
    2. Should the Commission consider mandating interconnection for non-geographic numbers? If not, why not? What would be the impact on number preservation of mandating interconnection for non-geographic numbers?
  8. In NoC 2023-92, the Commission indicated a need to address numbering exhaust and to take steps to conserve and maximize the use of Numbering Plan Areas (NPAs) and telephone numbers to help extend the lifespan of the current numbering system. In interventions some parties suggested that the Canadian Numbering Administrator (CNA) should be cautious when releasing CO Codes in order to avoid some TSPs reserving as many codes as possible before an eventual thousand-block pooling deployment deadlineFootnote3. TELUS submitted that it could be argued that the Canadian numbering system itself is nearing a jeopardy condition, and that thousand-block pooling will be ineffective if carriers can be granted as many blocks of numbers as they want just by asking. CNAC submitted that it may be prudent to require TSPs to support their request with customer demand information. On the other hand, other parties expressed reservations about modifying the current assignment process. For example, Iristel indicated that justifying the number of blocks they require would be very detrimental to the voice over IP (VoIP) industry and stifle innovation.
    1. What specific measures could the CNA or the Commission put in place in order to mitigate the above concerns about reserving as many codes as possible before a potential pooling deployment deadline?
    2. While parties have submitted that CISC could be put to task to review assignment rules, are there measures that should be put in place rapidly in the interim which would not be dependent on extensive review within the CSCN?
    3. Comment on the appropriateness of a Commission direction to the CNA that would limit geographic CO Code assignment to certain levels in the interim while a permanent solution is implemented (e.g., Canada-wide freeze at a certain level and any request beyond that requiring Commission or staff involvement). How and to whom could that direction be formulated? What could be some of the unintended consequences of such a direction and ways to mitigate them, including in terms of stifling innovation for the VoIP or other industries?
  9. Some intervenors who discussed this issue, but not all, were supportive of the concept that numbering administration costs should be tied to number usage as opposed to telecommunications revenues.
    1. Do you agree that numbering administration costs should be tied to number usage on a going forward basis and that this would have a meaningful impact on number preservation? If so, how? If not, why not?
    2. What would be potential unintended consequences of such a change in methodology?

Question for Bell, Eastlink, Iristel, Quebecor, Rogers, SaskTel, Teksavvy and , TELUS

  1. In the last 18 months:
    1. Have you requested or obtained geographic NANP CO Codes from the CNA that were ultimately intended or used for services which may not technically require geographic numbers (e.g., services that could work with non-geographic or alternative non-NANP resources)?
    2. If yes, indicate how many CO codes and for what services or uses were the codes requested or obtained that did not require geographic NANP numbers?
    3. In approximately what proportion was that compared to CO codes requested or obtained for services which unquestionably required geographic numbers?
    4. What led you to request geographic numbers where non-geographic numbers or alternative resources would have worked?
    5. Comment on your company’s openness to undertake an internal study to maximize the use of non-geographic TNs, similar to that mentioned by Rogers.

Questions for TELUS

  1. CSCN Report CNRE135A – Potential Remedies for CO [Central Office] Code and NPA Exhaust, at page 25, the CSCN states [it] discussed the need for 7-digit call routing at length. Many believe that Thousand Block pooling require 7-digit call routing, while others believe that it is required only to enable Least Cost Routing (LCR)Footnote4.  Further, in the Report, regarding;
    • the CO Code Sharing option, Table 7 contains a statement that “No changes to Network translations as numbers would remain defined at the NPA-NXX level and final call routing is determined by a Number Portability Database dip”; and
    • the thousand-block pooling (TBP) option, Table 8 contains a statement that “Switch Translations tables limit could be reached”.
  2. At paragraph 4 of its intervention dated 19 May 2023, TELUS states “Since the issuance of the Notice, TELUS has investigated TBP further and has concluded that a key assumption which led to the preference for CO code sharing (namely the assumed TBP requirement for 7-digit call routing, which was a major drawback) is not true.”

TELUS is requested:

  1. To explain on what basis did parties initially believe that TBP required 7-digit call routing;
  2. to explain on what basis were the statements in Table 7 and Table 8 made; and
  3. to provide the details of the investigation that it conducted to conclude the assumption noted above was not true (i.e., that 7-digit routing is not required).

Questions for Iristel

  1. At paragraph 5 of its intervention, Iristel was of the view that implementing thousand-block pooling will have a minor impact on number utilization for the wholesale market which caters largely to VoIP, IoT and SMS applications.
    1. Explain why thousand-block pooling will have such a minor impact, and how do you reconcile this with the concerns expressed in NoC 2023-92 in relation to the declining pool of available CO codes and telephone numbers?
  2. At paragraphs 37 - 42 of its intervention, Iristel suggested that thousand-block pooling should not be the only solution to be looked at by the Commission and suggested other solution such as IP interconnection, interconnection of non-geographic codes, including 0 and 1 digit in the first digit of CO codes, and a change of Canada's country code.
    1. As for the inclusion of 0 and 1 digit in CO codes, Iristel suggested it would increase CO code by 20%. Explain on what basis the 20% was determined.
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