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Telecom - Staff Letter addressed to Canadian Local Number Portability Consortium

Gatineau, 11 May 2026

Our reference: 8638-J34-202506246

BY EMAIL

Canadian Local Number Portability Consortium

Subject: ISP Telecom Inc. Part 1 Application for Access to Wireless Local Number Portability as a Full MVNO– Request for Information

The Commission is in receipt of a Part 1 application (“application”) from ISP Telecom inc. (“ISP Telecom”) dated 19 December 2025.  In that application, ISP Telecom, in its capacity as a full-Mobile Virtual Network Operation (“full MVNO”), is requesting that the Commission confirm its right to implement and perform wireless local number portability (WLNP).

In its application (paragraphs 21 to 22), ISP Telecom indicates that its request for access to the Number Portability Administration Center (NPAC) was rejected by the Canadian Local Number Portability Consortium (CLNPC). According to ISP Telecom, CLNPC considers, based on its interpretation of the Commission’s rules, that WLNP is reserved for wireless carriers only and therefore unavailable to full MVNOs.

As you are aware, as defined by the Commission in Regulatory framework for wholesale mobile wireless services, Telecom Regulatory Policy CRTC 2015-177, 5 May 2015 (paragraph 43), a full-MVNO supplies most of the components of a mobile network apart from the Radio Access Network (RAN).  In the application, ISP Telecom expressed the view that it is the full-MVNO (and not the RAN operator) that has the technical ability to perform WLNP. As a result, ISP
Telecom is requesting that the Commission:

  1. Direct the CLNPC to accept ISP Telecom as member, and
  2. Provide ISP Telecom full access to the NPAC.

In addition to the application and the public record that will result from this proceeding, Commission staff would like a better understanding of the issues raised. Therefore, please provide responses to the information requested in the attachment by June 1, 2026. The response is to be received, and not merely sent, by that date.

Your response will be placed on the public record. As set out in section 39 of the Telecommunications Act, 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 likely 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.

A copy of this letter will be placed on the public record of this proceeding.

Sincerely,

Original signed by

Jeremy Lendvay
Senior Manager
Telecommunications Sector

c.c. Distribution List: parties to this proceeding.

Appendix (1)

Appendix: RFI Questions

Please repeat the question when providing your answer.

  1. Please confirm whether the description provided by ISP Telecom regarding the reasons for the rejection of its application by the CLNPC is complete and accurate. If not, provide any clarifications or additional information.
  2. ISP Telecom has indicated that wireless number porting is done at the switch level and that the underlying RAN operator cannot perform number porting on behalf of its MVNO partner because it does not have access to a full MVNO’s switch. Does the CLNPC share this understanding? If not, please explain why not.
  3. If full-MVNOs were granted direct access to the NPAC, identify and describe any anticipated impacts on CLPNC processes and operational activities, if any.
  4. ISP Telecom indicates in its application (at paragraph 24) that it could “leverage its existing wireline LNP capabilities as a CLEC’’ to port wireless customers. For a CLEC that already has access to and is operationally capable of supporting local number portability (LNP), please explain whether there are any operational or technical reasons why that CLEC (if it is also operating as a full MVNO) would not be capable of also supporting WLNP? Put another way, are there any key differences between the processes for LNP and WLNP that would raise potential concerns about ISP Telecom’s ability to implement WLNP?
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