Major players in the Canadian wireless industry are taking aim at comments made by Virgin Mobile Canada in response to the CRTC’s call for comments (Telecom Public Notice 2005-14) on the implementation of wireless number portability (WNP). The upstart mobile virtual network operator (MVNO) has been highly critical of the industry’s WNP implementation plan and that has three national operators as well as the wireless industry association on the defensive. Last month, the MVNO wrote in comments to the commission that WNP could become available much sooner than the September 2007 date proposed by PricewaterhouseCoopers (PwC) and supported by the Canadian Wireless Telecommunications Association (CWTA).  Second-round comments saw the facilities-based wireless operators take aim at Virgin’s comments and use its own words to defend the two-year implementation plan. The CWTA notes in a letter to Report on Wireless that despite Virgin Mobile’s attempt to provide alternative approaches and new ideas regarding the implementation of WNP in Canada, the company’s comments support the PwC plan.  The CWTA highlights recommendations from Virgin Mobile that mirror those of the PwC report."Overall, it appears Virgin Mobile’s comments support the approach taken by the PwC plan, and only differ in the amount of time the company believes is required to complete the task. However, no evidence or substantiation for a shorter implementation schedule has been offered," states Peter Barnes, president and CEO of the CWTA.  Rogers Wireless Inc., the country’s largest wireless operator, weighs into the debate in its reply comments to the CRTC proceeding, noting that no party advocating a quicker implementation timeframe has provided evidence that it is possible. The company agrees with the CWTA that Virgin Mobile has effectively supported the PwC WNP deployment schedule.  "Specifically, Virgin’s comments are replete with statements of agreement with a number of significant principles and elements of the PwC plan. For example, Virgin agrees that the plan should avoid customer service disruption and should leverage U.S. experiences, porting processes and testing schedules," reads the submission. "Rogers Wireless would note that the PwC plan already incorporates the issues raised by Virgin and the time frames developed by PwC include these items."  Telus Mobility notes in its comments that "there is a complete absence of learned study on the implementation of WNP" except for the PwC report. The company adds there is a lot of uninformed opinion about how fast WNP can be rolled out, but no evidence to support anything contrary to PwC’s suggestions.  "Those parties speak from no personal knowledge and have no person experience with similar implementations in the past...Deviating or meddling with the plan risks interfering with the reliable functioning of wireless services that are currently subscribed to more than 15 million Canadians," writes Telus Mobility.  Rogers Wireless also suggests that Virgin has "vested interest" in a difficult implementation of WNP because "this outcome would significantly increase customer dissatisfaction with incumbent wireless carriers to the benefit of new entrants such as Virgin.  Therefore, Virgin’s claim that a 12-month time frame should be imposed is transparently self-serving and is at odds with Virgin’s claim that it has the customer’s best interest at heart."  Despite the considerable criticism leveled at the CWTA and the wireless industry for the plan, the Yankee Group believes that the two-year implementation schedule is "realistic and rational." The research firm argues in a decision note, released on October 19, that the September 12, 2007 date for "turning on" WNP is fair, "given necessary deployment times for network upgrades, implementation plans and trial testing periods."  The Yankee Group suggests that critics should see the benefits of the plan instead of criticizing it and should ensure the 2007 deadline is achieved: "The deadline provides a buffer against delays and allows the operators some room for unforeseen complications. This is to ensure Canada does not repeat the same mistake that the United States made, expanding a two-year deadline into a seven-year odyssey," writes the telecom research firm. The Boston-based research firm also notes that the implementation deadline isn’t that important because WNP will have little impact on the market. "The Canadian market has always been a highly concentrated industry with three distinct players dominating the landscape, leaving little room for significant competition to threaten any carrier’s subscriber base," writes the company (see box for main reasons).