The Canadian Wireless Telecommunications Association (CWTA) raises some concerns with respect to an application from the Intelligent Transportation Systems Society of Canada requesting use of the 511 three-digit dialing code. ITS Canada wants to use the N11 number to provide weather and traffic information to the public. The CWTA is concerned that the proposal doesn’t follow existing guidelines as set out by the CRTC.  CWTA filed comments in response to Public Notice CRTC 2000-151, the proceeding that led to Decision CRTC 2001-475, Allocation of three-digit dialing for public information and referral services. CWTA’s recommendations with respect to the assignment of N11 resources were as follows:• Proposed services should serve as many members of society as possible. • N11 resources are allocated to telecommunication services for which there is a demonstrated, persuasive rationale, such as urgency or avoidance of confusion, why the caller should only have to dial three rather than seven or more digits. • Wireless carriers must be permitted to charge subscribers regular airtime rates for access to N11 services. Implementation CWTA notes that the Application does not contain many specific details about how the services will be deployed or operate. In fact, the Application itself highlights that deployment guidelines have not been created, and "the development of these standards and guidelines is a necessary early priority." Previous applications for assignment of N11 numbers (such as from the CNIB, United Way, and the Municipalities) have included detailed proposals for at least the initial deployment of the service. Without more detail, it is difficult to provide comprehensive comments about the Application. For example, some mechanism will be required to allow callers to select between traveler and weather information, but it is not clear how such a system will be set up, or more importantly, who will be responsible for it. If the two systems are not implemented concurrently, the possibility arises that the Proponents may wish to modify the way calls are routed to accommodate different call selection mechanisms. This could significantly increase the complexity and costs for Telecommunication Service Providers (TSPs) to implement 511.  On the subject of implementation by TSPs, CWTA submits that the Application does not conform to the determinations in Decision CRTC 2001-475, Telecom Decision CRTC 2004-71, or the more recent Telecom Decision CRTC 2005-39. At page 12, the Application states: "The objective is to have 511 available across Canada, with weather forecasts and warnings available within 90 days after approval to use 511, and traveler information added as data providers are able to implement." This statement implies that TSPs will be expected to make all necessary switching routing modifications within 90 days of the Commission Decision. This is inconsistent with the manner in which previous N11 services have been implemented. If the Commission were to approve this proposal, it would impose considerable costs on TSPs.  When the Commission determined that TSPs would "bear the cost of implementing 211 on an incremental basis" it did so with the understanding that the changes required would be "implemented over a number of years and scheduled with other work on switching". The Commission repeated this reasoning when it assigned 311 for municipal government services, pointing out that "311 implementation should be similar to 211 implementation, and the costs should also be similar." Clearly, the Commission did not intend to impose significant costs on TSPs.  CWTA submits that if the Commission approves the Application, it would be inappropriate for TSPs to bear the costs of implementing switching and routing changes as described by the Proponents. Without further details about the services, it’s not possible to provide cost estimates. Costs would be greater, however, if work could not be conducted as part of ongoing work, as the Commission expected for 211 and 311. Further, the proposed 90 days is half that of the minimum notice period the Commission established in Telecom Decision CRTC 2004-71. TSPs first require a reasonable opportunity to investigate and determine the routing implications of the Proponents’ detailed proposals. After that, a six-month notification period, like that for 311, would likely allow sufficient time for wireless carriers to plan for implementation.  Cost recovery CWTA notes that the Proponents no longer seek to apply a cost recovery charge to the provision of weather information. In CWTA’s view, this is appropriate. The costs of services such as this should not be borne solely by telephone subscribers, nor should TSPs be required to fund any service that has as its sole purpose the distribution of information and / or the provision of content.  With the removal of the cost recovery charge, the Application now contains a discrepancy with respect to the manner in which wireless carriers may bill their customers.  The Application states: "Costs for 511 calls for wireless providers (local and long distance) would be recovered from callers as part of the monthly charge for use of a wireless service, or otherwise as part of a service contract with a wireless carrier." But then goes on to say:"Weather forecasts and warnings of imminent severe weather would be available without charge to all users of 511." CWTA submits that wireless carriers must be able charge regular rates — including regular airtime usage charges for prepaid subscribers or monthly-billed subscribers who exceed monthly minute bundles — for all calls to 511. This is consistent with both Decision CRTC 2001-475 and Telecom Decision 2004-71. Traveler information The Proponents have the stated objective to provide users with up-to-date information about such things as the status of roadway construction, accident locations, and alternate routes. CWTA understands that this information will be provided through the use of IVR systems. The wireless industry has devoted considerable resources to the issue of driver distraction and the responsible use of mobile phones while driving. CWTA encourages the Proponents to work to ensure that information of interest to drivers does not create its own distraction.