Rogers requests change to local number routing system

Rogers Communications Inc. has asked the CRTC to change the local number routing (LNR) system. The company says this will better align practices that apply to wireless CLECs with those of wireless service providers (WSPs) in the local interconnection region (LIR) regime. Below is an edited excerpt of the August 30 Part VII. Rogers notes that the case of Fido is instructive in the context of this issue. For example, in the Provinces of Ontario and Quebec, Fido operates as a CLEC in 43 exchanges, covering 18 LIRs. Under the existing rule that CLECs must have at least one CO code per ILEC exchange, Fido will require nearly two hundred additional CO codes, for the sole purpose of creating LRNs in all exchanges that are included in these 18 LIRs. If the commission modifies this requirement such that wireless CLECs will only require one LRN and one CO code for each LIR, Fido will be able to port telephone numbers in the same area without acquiring a single additional CO code. The ordering of CO codes to the extent required under the current CLEC rule would accelerate, if not guarantee, the exhaust of certain numbering plan area (NPA) codes. In light of this, it is clear that the proposed new rule would be far more efficient from a numbering perspective than the unnecessarily wasteful approach associated with the existing rule. Further, Rogers believes that the commission must create a level and more efficient playing field for all Canadian carriers which compete within the same region. For example, Bell-LIR-ON25 contains 7 exchanges. A WSP with a POI and CO code in Milton competes with a wireless CLEC that has a single LIR-POI and a CO code in Burlington (both exchanges are in LIR-ON25). Under the current rule, this WSP would be able to port numbers from the wireless CLEC in Burlington (Milton is within the Burlington LCA) using its Milton POI and LRN. However, under the existing rule, the wireless CLEC would not be able to port numbers from this WSP using its Burlington POI and LRN. This example can be replicated everywhere across the country and illustrates how unnecessarily inefficient the porting regime will be without the changes sought by Rogers. Consistent with the CO code rule modification requested in this application, Rogers also requests that the commission direct the modification of the Canadian LRN selection criteria that are applicable to wireless CLECs so that CO codes can be used more efficiently by wireless CLECs in the creation of LRNs. In connection with this request, Rogers notes that, in Decision 2006-28, the commission requested the CRTC Inter-connection Steering Committee (CISC) Canadian Steering Committee on Num-bering (CSCN) to update the LRN selection criteria to reflect the fact that WSPs will be required to have a CO code and LRN for each LCA where they will port tele-phone numbers. Subsequently, a CSCN committee was formed to update the Canadian LRN selection criteria. Following considerable discussion between the industry participants, the CSCN filed a letter with the commission, dated July 5, 2006 requesting direction regarding the extent to which the Canadian LRN selection criteria should be modified. Specifically, there was disagreement among committee members regarding whether or not Decision 2006-28 directed only that the LRN selection criteria applicable to WSPs should be modified, or whether the criteria applicable to CLECs should also be modified by the CSCN. Rogers respectfully submits that, irrespective of the extent to which the commission intended the LRN selection criteria to be modified for CLECs and, for the reasons provided in this application, it would be entirely appropriate at this time for the commission to modify the LRN selection criteria for wireless CLECs so that they will be permitted to have one LRN for each LIR in which they will port telephone numbers. This course of action would avoid the unnecessarily wasteful consumption of CO codes by wireless CLECs in the creation of LRNs. It would also ensure that the Canadian LRN selection criteria would be more closely harmonized with the practices in the US. In light of the US approach to LRN assignment, and given that the commission has already permitted CLECs to establish a single POI per LIR, it would be appropriate for the commission to direct the modification of the Canadian LRN assignment criteria so that wireless CLECs may assign a single LRN for each LIR. Taking this action will align the CO code requirements and LRN practices that apply to wireless CLECs with the LIR regime that has been established by the commission to increase the efficiency of local interconnection. This action will also contribute to the conservation of scarce telephone number resources in that a significantly smaller number of CO codes will be required by wireless CLECs to provide local service and port telephone numbers within a given area. It will also permit wireless CLECs to port telephone numbers in a manner that is similar to WSPs and will allow them to compete more effectively with WSPs.

Rogers requests change to local number routing system

News | September 8, 2006

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