Telecom - Staff Letter addressed to Jean-François Dumoulin (Iristel Inc.) and Philippe Gauvin (Bell Canada)

Gatineau, 9 May 2025

Reference: 8698-J64-202500975

BY EMAIL

Jean-François Dumoulin
Vice President Regulatory and Government Affairs
Iristel Inc.
403-16766 TransCanada Hwy
Kirkland, QC H9H 4M7
regulatory@sugarmobile.ca

Philippe Gauvin
Assistant General Counsel
Bell Canada
19th Floor 160 Elgin Street
Ottawa, ON K2P 2C4
bell.regulatory@bell.ca

Subject: Application regarding delays by Bell Canada when routing new central office codes obtained by Iristel – Request for Information

On 10 April 2025, Iristel Inc. (Iristel) filed a Part 1 Application alleging unreasonable delays by Bell Canada (Bell) in routing new central office (CO) codes obtained by Iristel. Having reviewed the application, Bell’s answer filed 31 March 2025, and Iristel’s reply filed 10 April 2025, Commission staff requires additional information. Consequently, Iristel and Bell are to provide responses to the following questionsdirected to them by 23 May 2025, serving their responses on the other party by the same date. Iristel and Bell may then submit replies to each other’s responses by 30 May 2025. These replies must be limited to only the new information provided in the responses to the attached questions. Further, staff expects both parties to disclose as much information as possible on the public record to ensure a definitive understanding of the matter.

Questions for Iristel

The Canadian Central Office Code (NXX) Assignment Guidelines (the Guidelines) provide direction to the Canadian Numbering Administrator (CNA), Code Applicants and Code Holders with respect to the administration, assignment, activation and use of CO Codes and the numbering resources contained therein. Among other things, the Guidelines indicate that once a CO code has been assigned to the Code Applicant by the CNA, the Code Applicant must enter the relevant routing information into the Business Integrated Routing and Rating Database System (BIRRDS) at least 45 days prior to the requested CO code effective date.

Appendix 1 NPANXXs – Failed with Bell Canada_2024_2025 of Iristel’s application provides details relating to several CO codes for which routing issues arose, including the dates on which Iristel requested these codes from the CNA and on which Iristel sent its Global Title Translation (GTT) notifications, and the dates on which routing issues for these CO codes were resolved. However, staff notes that Appendix 1 does not indicate whether or when Iristel entered the relevant routing information for these codes into BIRRDS.

• Q1. Iristel is to provide an updated Appendix 1 indicating, for each CO code
  1. The date on which Iristel entered the relevant routing information into BIRRDS; and
  2. The number of days between the date on which Iristel entered the relevant routing information into BIRRDS and the date on which the CO code was reachable.
• Q2. Iristel is to explain why it considers the GTT notification deadline to be the appropriate milestone on which to base the activation of CO codes, rather than the date on which code applicants enter the relevant routing information into BIRRDS.

In its application, Iristel stated that “[a]s part of the process of putting a CO Code in service, an applicant is required to provide routing information to the iconectiv [BIRRDS] database, and to send a GTT update to Canadian carriers at least 30 days prior to CO Code activation according to the GTT Point Code Industry Notification Process as approved by the Commission. It is expected that upon receipt of a GTT notification, carriers will make the necessary adjustment to their systems to be able to route calls to telephone numbers in the new CO code by the Effective Date specified in the GTT notification.”

Staff notes that, for the majority of codes listed in Appendix 1 to Iristel’s application, the “GTT Sent On” date is less than 30 days prior to the “CNAC Effective Date 66 Days.” For these codes, Iristel is to explain

• Q3. Why it sent GTT notifications less than 30 days prior to the effective date; and
• Q4. Its expectations with regards to CO codes being reachable by the effective date, despite the GTT being provided less than 30 days prior.

Questions for Bell

In its answer to Iristel’s application, Bell acknowledged that “there has been a pattern of lengthier troubleshooting from a third-party carrier with respect to routing issues for new CO Codes in Western Canada,” but that these issues stem from Bell’s indirect connection to Iristel in that region where Bell relies on a third party. As a result, Bell indicated that it has no direct ability to control the associated deployment timelines.

• Q5. Bell is to explain the nature of its relationship with the third-party carrier within the context of the effective routing of new CO codes. In doing so, Bell is to
  1. Provide details on the services the third-party carrier provides to Bell;
  2. Explain how this third-party carrier is involved in the deployment and routing of CO codes by Bell, including a diagram if possible; and
  3. Explain the contractual relationship between Bell and this third party. Given that it is Bell’s regulatory responsibility, as the carrier, to route calls, explain why Bell is unable to exert any control over the third-party carrier to ensure timely and effective routing of new CO codes in Western Canada.

This letter and any subsequent correspondence will be placed on the Commission’s website. 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, Iristel may designate certain information as confidential, though it 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, should Iristel designate information as confidential, it 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 Philippe Nadeau for

Suneil Kanjeekal
Director, Dispute Resolution & Regulatory Implementations
Telecommunications

c.c.:  Etienne Robelin, CRTC, etienne.robelin@crtc.gc.ca

Date modified:

2025-05-09