Telecom - Staff Letter addressed to Various Parties

Gatineau, 19 June 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

Stephen Schmidt
Vice-President – Telecom Policy & Chief Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
Telus Communications Inc.
Floor 5, 215 Slater St.
Ottawa, ON K1P 0A6
regulatory.affairs@telus.com

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 responses and replies to Commission staff’s request for information (RFI) issued on 9 May 2025, staff requires additional information.

Questions for Iristel

In its application, Iristel outlined a process for reachability testing whereby Iristel places a call from a device subscribed to another carrier’s service to an Iristel test number that is part of the block of numbers from the new CO code. In Appendix 1 NPANXXs – Failed with Bell Canada_2024_2025 of its application, Iristel provided a list of CO codes for which reachability tests from a device subscribed to the Bell Mobility network failed.

• Q1. Iristel is to confirm whether it conducted reachability tests for these CO codes using devices subscribed to networks other than Bell’s. If not, Iristel is to explain why. If such tests were conducted, Iristel is to identify the networks used and report the results.

In its application, Iristel stated that “[a]s part of the process of putting a CO Code in service, an applicant is required to…send a [Global Title Translation (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”.

In Appendix 1 to its application, Iristel listed in column H “GTT Sent On” the dates it issued the GTT notifications (the GTT Notification Date) to Canadian carriers and in column I “CNAC Effective Date 66 Days,” the date by which its new CO codes were expected to be active (the Effective Date).

Staff noted that for 29 out of the 42 CO codes listed in Appendix 1, the interval between the GTT Notification Date and the Effective Date was less than 30 days. Accordingly, in its 9 May 2025 RFI, staff requested Iristel explain (i) why, for the majority of the CO codes listed in Appendix 1 to its application, Iristel sent GTT notifications less than 30 days prior to the Effective Date; and (ii) Iristel’s expectations with regards to CO codes being reachable by the Effective Date, despite the GTT notification being issued less than 30 days prior.

In its response dated 23 May 2025, Iristel answered that “In some cases, Iristel’s numbering team may have inadvertently sent the GTT a few days early. In the course of examining its CO code activation process, Iristel identified this issue and corrected its process to ensure that all CNAC and CISC process timelines are fully respected.”

By referring solely to instances in which it issued GTT notifications before the deadline, staff considers that Iristel’s response did not address staff’s questions, which focused on cases where Iristel did not meet the GTT notification deadline. As such, staff reiterates its questions and, in doing so, provides Iristel with an opportunity to submit amended responses.

• Q2. In Appendix 1 to its application, Iristel listed 29 CO codes for which the GTT Notification Date is less than 30 days prior to the Effective Date. For these codes, which staff has captured in the attachment to this RFI, Iristel is to explain

  1. Why it sent GTT notifications less than 30 days prior to the Effective Date; and
  2. 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 TELUS Communications Inc. (TELUS)

In its answer to the application, filed 2 April 2025, and further clarified in its 23 May 2025 response to staff RFIs, Bell submitted 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 by way of interconnection with TELUS’ network.

• Q3. TELUS is to provide comments in reply to Bell’s submissions. In doing so, TELUS is to include

  1. An explanation of its roles and responsibilities with regards to activating Iristel’s Western Canada-based CO codes;
  2. An explanation as to why Iristel’s reachability tests would fail when attempting to complete calls to Western Canada-based CO codes using a mobile device subscribed to the Bell Mobility network; and
  3. An explanation of its roles and responsibilities in addressing and resolving CO code activation delays for the CO codes listed in Appendix 1 to Iristel’s application.

Procedure

Iristel is to file its responses to the questions address to it by 27 June 2025.

TELUS is to file its response to the question addressed to it by 11 July 2025.

Bell may file a reply to Iristel and TELUS’ responses by 23 July 2025. In doing so, Bell is to limit its comments to only the new information provided by Iristel and TELUS.

Iristel may file a reply to both TELUS’ and Bell’s response by 5 August 2025. In doing so, Iristel is to limit its comments to only the new information provided by Bell and TELUS.

Further, staff expects all parties to disclose as much information as possible on the public record to ensure a definitive understanding of the matter.

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, parties 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 parties 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

Attachments (1) - List of CO codes for which GTT notifications were sent less than 30 prior to the effective date

Attachment 1 to Request for Information

Date modified:

2025-06-19