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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 17 January 2024

Our reference: 8620-R28-201905077

By EMAIL

Distribution List

Subject: Rogers Communication Canada Inc. – Application concerning Bell Canada Billed Number Screening Database Services Charged to Wireless Service Providers and Wireless Competitive Local Exchange Carriers

On 2 July 2019, Rogers Communications Canada Inc. (RCCI) filed a Part 1 Application concerning Bell Canada’s Billed Number Screening (BNS) Database Services Charged to Wireless Service Providers (WSPs) and Wireless Competitive Local Exchange Carriers (WCLECs).

To clarify and develop the record of this proceeding, the parties identified in the distribution list are to file responses to the questions set out in the attachment by 31 January 2024.

Responses are to be provided in a single document to facilitate accessibility and administrative processing. However, any information provided in spreadsheet format should be included as an appendix, in a single document, in MS Excel format.

As set out in section 39 of the Telecommunications 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 person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications sector

c. c. Josiane Lord, CRTC, 819-576-2568, josiane.lord@crtc.gc.ca
Ethan Townsend, CRTC, 873-355-6698, Ethan.Townsend@crtc.gc.ca

Attach (1) : Appendix

Distribution List:

Bell Canada (bell.regulatory@bell.ca)
Rogers Communications Canada Inc. (RCCI) (rwi_gr@rci.rogers.com)
TELUS Communications Inc. (TCI) regulatory.affairs@telus.com)

Requests for Information

Questions for all parties

  1. For each of the years 2021 to 2023, as well as forecasts for 2024 and 2025, for each province/territory, and for each wireless brand your company operates, provide: (i) the total number of wireless customers that you permit to receive collect/Bill-to-Third Party (BTT) calls (i.e. those not included in a BNS database); (ii) the total number of wireless customers that you permit to receive collect/BTT calls as a percent of your total wireless customer base; (iii) the number of collect/BTT calls those customers received; and (iv) revenues associated with those collect/BTT calls.
  2. Do you operate as an interexchange service provider (IXSP)? If so, in your role as an IXSP, provide the following information:
    1. A list of wireless providers that you have a billing and collection agreement with; and
    2. For each of the years 2021 to 2023, as well as forecasts for 2024 and 2025, for each province/territory, and for each wireless service provider, the number of collect/BTT calls connected to a Canadian wireless number.
  1. RCCI proposed that IXSPs should simply stop terminating collect/BTT calls to wireless customers, unless the IXSPs have a billing and collection agreement with the WSPs/WCLECs.
    1. At what point in the call-carrying process does an IXSP determine whether it has a billing and collection agreement with the connecting carrier? Does it occur before, during or after routing a collect/BTT call?
    2. What is the process for determining whether an IXSP has a billing and collection agreement with a wireless carrier while routing collect/BTT calls?
    3. Does the IXSP need access to the BNS database to identify whether the IXSP has a billing and collection agreement with the wireless carrier while routing collect/BTT calls?
    4. At the time of routing a call, if an IXSP identifies that the telephone number is associated with a wireless carrier that it does not have a billing agreement with, does it still complete the call?
    5. Are you aware of a time that an IXSP has connected a collect/BTT call to a wireless number that was associated with a company that it does not have a billing and collection agreement in place with? If so, provide details on how billing and collection was completed in absence of an agreement. If such a scenario has not occurred, indicate how the IXSP would bill and collect in such a circumstance.
  1. RCCI argued that IXSPs could easily use the Local Exchange Routing Guide (LERG) and Canadian Number Portability Administration Center (NPAC) databases to determine whether a number belongs to a wireless subscriber, to which collect/BTT calls should not be terminated.
    1. Could the IXSP determine from the LERG and/or NPAC databases whether the telephone number is associated with a company that it has a billing and collection agreement with; for example, if it can determine (i) which carrier the telephone number is associated with, (ii) whether the telephone number belongs to a wireless customer, and (iii) whether it has a billing and collection agreement with said carrier? If so, would it be possible to use the LERG or NPAC databases to block all telephone calls associated with a company that the IXSP does not have a billing and collection agreement with (or block all telephone calls to wireless numbers, if this requires a different process)?
      1. From a technical perspective, describe how IXSPs would implement such a change, including how calls would be routed.
      2. Would there be any cost implications of implementing such a regime? If so, how do you think those costs should be recovered?
    1. Is it possible for IXSPs to use the LERG and/or NPAC databases to block all collect calls for certain carriers that an IXSP does not have a billing and collection agreement with, while continuing to query BNS databases for wireless providers it does have a billing and collection agreement with?
    2. Is there any other database/source an IXSP can use to identify, at the time of routing, whether the telephone number (i) belongs to a wireless customer and (ii) is associated with a company that it has a billing and collection agreement with, in the absence of using a BNS database? Is there an associated cost?
  1. RCCI indicated the possibility that it would stop entering its wireless telephone numbers into Bell Canada’s BNS database and discontinue paying for Bell Canada’s forborne charges for BNS database services.
    1. What would the impacts of doing so be on IXSPs?
    2. How would the IXSP determine if a wireless telephone number should be routed, knowing that absence of the number from the BNS database could mean either (i) the wireless carrier uses a BNS database and the particular number may receive collect/BTT calls; or (ii) the wireless carrier does not enter its numbers into a BNS database because the wireless carrier does not have a billing and collection agreement with the IXSP.
  1. Do IXSPs use the BNS databases for other types of calls – for instance, to route long-distance calls? If the Commission were to contemplate any changes to the BNS framework, as per Rogers’ application, would there be any impacts on those other uses?

Questions for Bell Canada

  1. Bell Canada indicated that Bell Mobility allows collect calls to certain of its wireless customers. Does Bell Mobility have billing and collection agreements with IXSPs? If so, which IXSPs does it have agreements with?
  2. With respect to BNS databases, RCCI indicated that Bell Canada automatically gathers all information using the LERG and the NPAC databases. Indicate how Bell Canada’s BNS database is currently updated with RCCI’s wireless telephone numbers and whether Bell Canada uses the LERG and NPAC databases to do so. Include information on the technical process Bell Canada uses to update its database (for instance, what is involved in running the query to update the database, how frequently the query is executed, etc). Indicate whether there are any associated costs with updating the BNS database with wireless telephone numbers.

Questions for RCCI

  1. Provide an update on the forborne rate that RCCI pays Bell Canada for its BNS database (“listing”) services.
  2. Provide, for each of the years 2021 to 2023, as well as forecasts for 2024 and 2025, the total BNS database annual fees paid to Bell Canada.
  3. Indicate whether RCCI has attempted to commercially negotiate its BNS transaction rate with Bell Canada or attempted to negotiate with any other BNS database providers. If so, what were the results of those discussions?
  4. Has RCCI considered building and managing its own BNS database? If so, what would it entail and how much would it cost to build the database and maintain it on an annual basis?

Questions for TELUS Communications Inc. (TCI)

  1. TCI indicated that it would support a regime where wireless numbers are not charged for collect/BTT calls by default, where wireless carriers may reject collect/BTT charges to all their customers without liability to the IXSP. Does TCI have any proposals on how such a regime could be implemented, considering that some wireless carriers (such as Bell Mobility) may allow some of their customers to receive collect/BTT calls, while other wireless carriers (such as RCCI) may wish to block all collect/BTT calls. If so, provide a technical explanation of how IXSPs would route calls. Indicate whether such a change would require costs be recovered through the tariffed BNS database query fee.

Questions for Bell Canada et TCI

  1. Provide an estimate on the costs associated with (i) building a BNS database and (ii) maintaining the database on an annual basis.
  2. Provide a list of telecommunications service providers that enter their telephone numbers into your BNS database.
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