CRTC INTERCONNECTION STEERING COMMITTEE TIF REPORT Date Submitted: 23 June 2015 WORKING GROUP: CSCN REPORT #: 114 REPORT TITLE: MVNOs File ID: CNRE114B.docx Revised Canadian IMSI Assignment Guideline to include Full OUTCOME: NON-CONSENSUS RELATED TASK(s) #: BACKGROUND: On 05 May 2015 the CRTC issued Telecom Regulatory Policy CRTC 2015-177, Regulatory framework for wholesale mobile wireless services. In Paragraph 159 of Telecom Regulatory Policy CRTC 2015-177, the CRTC noted that Mobile Virtual Network Operators (MVNOs) are not currently eligible to acquire a Mobile Network Code (MNC). 159. Mobile network codes (MNCs) in Canada are assigned by the Canadian Numbering Administrator pursuant to the Canadian International Mobile Subscriber Identity (IMSI) Guideline (the Guideline). The Guideline was developed by the Canadian Steering Committee on Numbering (CSCN) and approved by the Commission. The Guideline requires that an applicant for an MNC hold a spectrum licence from Industry Canada. Thus, MVNOs cannot acquire MNCs. MVNOs are not eligible for MNCs based on Section 7 of the current Canadian International Mobile Subscriber (IMSI) Guideline. Accordingly, in Paragraph 162 of Telecom Regulatory Policy CRTC 2015-177, the CRTC has directed the CSCN to amend the IMSI Guideline to permit assignment of MNCs to full MVNOs by 6 July 2015. 162. The Commission hereby directs the CSCN to (i) amend the Guideline to allow full MVNOs to acquire MNCs, and (ii) submit the amended Guideline for Commission approval by 6 July 2015. [Emphasis added] In the process of updating the IMSI Guideline, the CSCN faced some challenges with the Commission’s term “full MVNO”. The definition that was provided in TRP 2015-177 was not specific enough for the purposes of the IMSI Guideline. Further, the term “full MVNO” is not a defined term in the wireless industry. Due to international and national wireless industry 2-digit limitation, the CSCN has been carefully monitoring the assignment and usage of MNCs for a period of time. To date in Canada, 45 MNCs are assigned and 56 remain for assignment based on the current Guideline. Appendix 1 of the Guideline also outlines further limitations (2-digit MNCs) to availability. If the MNC inventory is exhausted, a new Mobile Country Code is required and the implementation could be costly on the industry. The CSCN has drafted a revised Guideline that permits assignment of MNCs to full MVNOs but was unable to come a consensus on what the definition of a full MVNO should be in the Guideline. 1 ISSUES: Revised guideline excluding the “Full MVNO” definition (consensus): Under direction from Telecom Regulatory Policy CRTC 2015-177, the CSCN has modified the Canadian International Mobile Subscriber (IMSI) Guideline to permit the assignment of MNCs to Full MVNOs. The CSCN was able to come to a consensus on the whole document except the definition of a Full MVNO. CRTC qualify Full MVNOs and create and maintain registration list (consensus): The CSCN does not believe it should be the responsibility of either the CSCN or the CNA to determine whether an MVNO meets the requirements to be considered a Full MVNO. Accordingly, the CSCN recommends that the CRTC qualify all eligible registrants and create and administer a registration list of organizations that meet the requirements of a Full MVNO. This will allow the CNA, when assigning MNCs, to quickly identify whether an organization is eligible for assignment of MNCs. This is a similar reference process that the CNA uses for identifying if a CO code applicant qualifies as a Competitive Local Exchange Carrier or Wireless Service Provider. Definition of a “Full MVNO” (non-consensus): The four positions represented are below. 2 POSITION 1 (Cogeco): 1. At the last meeting of the CSCN on TIF 94, dated 5 June 2015, the participants came to a non-consensus with respect to the definition of “Full MVNO” to be included in the Glossary, section 15.0 of the Canadian International Mobile Subscription Identity (IMSI) Guideline. A streamlined definition (Definition 1) and an explicit definition (Definition 2) of full MVNO have been proposed stating the following: Full MVNO DEFINITION 1: An MVNO that is registered with the CRTC as a Full MVNO. DEFINITION 2: An MVNO that is registered with the CRTC as a Full MVNO. To register with the CRTC as a Full MVNO, an MVNO must be able to provide mobile wireless services to consumers using core network hardware (e.g. switches, routers) separate from all WSPs, and its own service profile management system (eg. Home Location Register [HLR], Home Authentication, Authorization, and Accounting [AAA], Home Subscriber System [HSS]), all of which must be located in Canada. 2. Cogeco is in favor of Definition 1 for the following reasons. For the purpose of this Guideline, Cogeco submits that this proposed streamlined definition is not only consistent with the proposed modification to Section 2.11 of the Guideline which reflects the description of a full MVNO used in TRP 2015-1772, but enunciates without ambiguity that the registration requirement with the CRTC is the determining element to identify a full MVNO eligible to obtain a Mobile Network Code (MNC). 3. Furthermore, Cogeco submits that it is neither the role of the CSCN to define which requirements would permit to identify a full MVNO, nor the role of the Canadian Numbering Administrator (CNA), i.e., the Canadian IMSI Administrator, based on such a definition, to determine which entity is eligible to obtain or not an MNC. 4. As noted in paragraph 160 of TRP 2015-177, the possibility of acquiring its own MNC is critical to ensuring that a full MVNO can commercially operate in the retail market independently of its host wireless carrier. Since this component is not a requirement for an MVNO operating as a branded reseller, the Commission directly The proposed modification to Section 2.1 of the Guideline states that “A Full MVNO is an MVNO who supplies most of the components of the network it uses to provide services apart from the Radio Access Network (RAN) and is registered with the CRTC as a Full MVNO” 2 Paragraph 43 states: “An MVNO that supplies most of the components of a network apart from the RAN is referred to in this decision as a “full MVNO.” Branded resellers provide marketing services, distribution channels, and billing services, but rely on wireless carriers for the rest of their business, including the operation of the network. While MVNO models vary, they all require access to the RAN of a wireless carrier.” (Emphasis added) 1 3 referred to the full MVNO category in the policy decision where it explained the relevance of amending the Guideline for the assignment of MNCs.3 In fact, for the understanding of the decision, it was not necessary to have a technical definition of full MVNO. Further, although the Commission directed the CSCN to amend the Guideline to allow full MVNOs to acquire MNCs, it is very significant to note that the Commission did not order the CSCN to propose such a definition. 5. In any event, Cogeco submits that it is the role of the CRTC to determine the requirements that should be met by a wireless service provider to be considered a full MVNO and be allowed to acquire an MNC. To this end, Cogeco reiterates that the registration process enunciated in proposed Definition 1 is appropriate and sufficient. 6. Furthermore, in TRP 2015-177, Cogeco notes that the Commission declined to establish a regulatory framework mandating the provision of MVNO access services, and continued relying on commercial negotiations to support the emergence of MVNOs, including full MVNOs. Further, the Commission used “its existing powers to take action to reduce certain barriers faced by MVNOs to facilitate, and allow more flexibility in, their commercial negotiations with wireless carriers” (Emphasis added), expecting that the removal of MVNO restrictions in wholesale roaming arrangements and the possibility for full MVNO to acquire an MNC “should also encourage the emergence of a competitive market for wholesale MVNO access.”4 7. Since the Commission is relying mainly on market forces to foster the emergence of full MVNOs, for consistency purposes, Cogeco submits that the registration process for full MVNO should be as streamlined as possible. 8. Therefore, in order to be registered as a full MVNO with the Commission, Cogeco proposes a two-step process. In the first step, a wireless service provider would simply have to notify the Commission, in writing, that it is negotiating a wholesale full MVNO access arrangement with a wireless carrier. Based on this notification, the wireless service provider would be recognized and registered as a “proposed full MVNO” by the CRTC and would thus be allowed to submit an MNC application to be reviewed and processed by the CNA. 9. In the second step, the proposed full MVNO would inform the Commission, in writing, that it has concluded a wholesale full MVNO access agreement and therefore is qualified to be registered as a full MVNO with the CRTC. Consequently, based on this registration, the CNA would immediately assign the requested MNC to the full MVNO. 3 4 Paragraphs 159 to 162 of TRP 2015-177. Paragraph 124 of TRP 2015-177. 4 POSITION 2 (Rogers): Background In CSCN TIF 94, a non-consensus has arisen over whether or not to include a detailed definition of the CRTC term, “Full MVNO,” which appears in Telecom Regulatory Policy 2015-177, paragraph 43. It states: “MVNOs also rely on some or all components of a wireless carrier’s network, including the RAN, to provide retail services. An MVNO that supplies most of the components of a network apart from the RAN is referred to in this decision as a “full MVNO.” Branded resellers provide marketing services, distribution channels, and billing services, but rely on wireless carriers for the rest of their business, including the operation of the network. While MVNO models vary, they all require access to the RAN of a wireless carrier.” To facilitate preparation of the non-consensus report, Rogers proposes the following text be used in the preparation of the non-consensus report: Full MVNO Definition Rogers proposes the following definition of “Full MVNO” be used in the Glossary of the IMSI Guidelines: A Full MVNO is a MVNO that must register with the CRTC and demonstrate that it has core network hardware platforms separate from all WSPs (eg. switches, routers) and a service profile management system (eg. Home Location Register [HLR], Home Authentication, Authorization, and Accounting [AAA], or Home Subscriber System [HSS]); own, operate or have access to transmission facilities to provide mobile wireless services to consumers; and handle its own network routing. All platforms are within Canada. 5 Rationale In Telecom Regulatory Policy 2015-177, the Commission ratifies the use of the term “Full MVNO” however the definition of “Full MVNO” in TRP 2015-177 is somewhat shy of what is required by the Canadian Numbering Administrator (CNA) and others to easily determine whether or not the applicant of a Mobile Network Code (MNC) is a Full MVNO or not. Rogers believes that a complete definition is required to reduce ambiguity. Ambiguity is the enemy of any guideline. Further, the Telecom Act5 lists among its objectives: “7 (a) to facilitate the orderly development throughout Canada of a telecommunications system that serves to safeguard, enrich and strengthen the social and economic fabric of Canada and its regions;” If a clear and detailed definition of “Full MVNO” is not implemented in the IMSI Assignment Guideline, MVNO organizations may use this ambiguity to argue that they qualify as a Full MVNO. Providing a clear and unambiguous definition of “Full MVNO” will facilitate the orderly development of telecommunications systems throughout Canada. A clear and detailed definition of “Full MVNO” will ensure that MNCs are assigned to only those parties that truly match the Commission’s definition and intention of a “Full MVNO.” This in turn will create a mechanism of efficient distribution of the Canadian MNCs. Distributing MNCs on an inefficient basis will lead to premature exhaust of the Canadian MNC resource which will force the entire industry into a costly MNC relief planning process. Rogers also supports the suggestion that a MVNO must register with the CRTC in order to become a Full MVNO. A Full MVNO is basically a facilities-based WSP without a Radio Access Network (RAN). A Full MVNO should therefore be subject to the same regulations and qualification requirements as a complete WSP. This is consistent with the Telecom Act’s Canadian Telecom Policy6 Objective 7 (d), “to promote the ownership 5 http://laws-lois.justice.gc.ca/PDF/T-3.4.pdf 6 http://laws-lois.justice.gc.ca/PDF/T-3.4.pdf 6 and control of Canadian carriers by Canadians” and PART II of the Telecom Act, “ELIGIBILITY TO OPERATE; Canadian Ownership and Control.” Allowing a MVNO to become a Full MVNO without Canadian Ownership and Control requirements would facilitate organizations with nefarious intentions of skirting Canadian laws and regulations by claiming that since they are outside of the country, they are not required to comply with Canadian laws and regulations. Also, if the HLR or HSS are located in foreign countries, it may subject the identity of Canadian subscribers to the laws of investigation of foreign countries which may not be compatible with Canadian laws. For these reasons, a MVNO seeking qualification to become a Full MVNO must register with the CRTC, meet Canadian Ownership and Control requirements, and locate its network platforms within Canada. 7 POSITION 3 (Bell): Background In Telecom Regulatory Policy 2015-177, at paragraph 162, the Commission required the CSCN to amend the IMSI guideline to allow “full MVNOs” to acquire Mobile Number Codes (MNCs). The Commission provides a short description of the term “full MVNO” at paragraph 43: MVNOs also rely on some or all components of a wireless carrier’s network, including the RAN, to provide retail services. An MVNO that supplies most of the components of a network apart from the RAN is referred to in this decision as a “full MVNO.” Branded resellers provide marketing services, distribution channels, and billing services, but rely on wireless carriers for the rest of their business, including the operation of the network. While MVNO models vary, they all require access to the RAN of a wireless carrier. (emphasis added) In the process of updating the IMSI guideline, as directed by the Commission, the CSCN faces a significant challenge. It is important for the IMSI guideline to clearly and unambiguously define the specific criteria that applicants for MNCs must meet in order to be eligible to obtain these scarce numbering resources. This is so that the Canadian Numbering Administrator (CNA) can appropriately and efficiently assign MNCs only to those eligible entities and refuse those that are not. Unfortunately, the Commission’s definition of a “full MVNO” is inexact. The words “most of the components” do not provide sufficient certainty for the CSCN to determine whether or not an MVNO qualifies as a “full MVNO” to obtain MNCs. Cogeco has advocated that the CSCN should not attempt to clarify the current ambiguity regarding “full MVNO” status is that the applicant need only register as a “full MVNO” with the Commission.7 We disagree with this approach because of the risks it poses as explained below. 7 See Cogeco contribution for TIF 94submitted to CSCN 29 May 2015 and Minutes of meeting 5 June 2015. 8 Instead, we recommend three things: i) that a clear and complete definition of a “full MVNO” be approved by the Commission and included for reference in the IMSI guideline, ii) that the Commission manage a process where entities are required to register as “full MVNOs” and iii) that the Commission assesses whether the entities that claim to register as “full MVNOs” actually meet the required criteria before they are listed on its website. Rationale The need for a clear, unambiguous definition of “full MVNO” A clear definition is necessary for prospective code applicants to understand the criteria to be met in order to be eligible to apply for and obtain MNCs. The CNA is not in a position to determine who should get the codes without sufficiently clear criteria. There is no consensus within the CSCN on what “full MVNO” means or implies. A complete and easy to administer definition is required to eliminate the current ambiguity. Without a clearly defined, Commission-approved definition, the ambiguity will continue and will leave the CNA to interpret and assign MNCs without direction. A clear and detailed definition of “full MVNO” ensures that MNCs are assigned to only those entities that align with the Commission’s intention with respect to “full MVNOs.” In TRP 2015-177, the Commission puts emphasis on the importance of encouraging investment in wireless networks and the need to break down barriers so that MVNOs can participate in this market. The Commission made a conscious decision to distinguish “full MVNOs” when it allowed only these entities to obtain MNCs to encourage more wireless investment and provide these MVNOs more flexibility to participate in the delivery of wireless services. Cogeco itself acknowledged this point at paragraph 114 of the TRP. Cogeco submitted that the entry of MVNOs in the market would increase the amount of investment in the telecommunications industry, since it would be necessary for these service providers to make substantial investments in facilities and operational systems to operate as full MVNOs. MNCs are limited numbering resources and must be managed efficiently 9 All numbering resources must be managed efficiently so that a sufficient quantity remains available for use, particularly in the case of MNCs, where this resource is much more constrained compared with other numbering resources. The MNCs have a very limited inventory pool which is due to a known International routing limitation related to GSM and CDMA systems. This limitation is recognized by the International Telecommunications Union and built into the US IMSI guideline as well as the Canadian IMSI guideline at Appendix 1. In the industry, certain GSM and CDMA systems are only able to handle two digits, which in practice means that not all the MNCs in the inventory within a country code can be assigned. For example, if the MNC 220 is assigned to Bell Mobility, then the MNC 221 cannot be assigned to another entity as certain systems will only see “22” and would confuse which service provider is associated with calls. In Canada, there is only one country code and therefore the maximum number of MNCs that can be assigned is under 100 (some numbers cannot be assigned) of which approximately 50 are already assigned. For years now, the CSCN has been actively monitoring this resource and discussing this topic multiple times each year to ensure the inventory continues to be adequate for all the stakeholders. If MNCs were to be assigned without any restrictions on which entities qualify as a “full MVNO”, including resellers, the number of MNCs could very quickly be exhausted. Once the inventory is depleted (and even well before that time) a new country code would need to be implemented for Canada. This will impose very significant investments for all of the wireless industry so that respective IS/IT systems are updated concurrently in order to be able to address a new country code. Therefore, MNCs should not be assigned to all MVNOs, including those that are only reselling services, as this would lead to a premature exhaust of the MNC inventory. It makes no sense to impose these costs on all the entities that need these codes particularly for entities who fall short of being “full MVNOs” that do not invest in the wireless networks. Requiring “full MVNOs” to register with the Commission We consider that the administrative simplicity associated with assigning other numbering resources, such as Central Office (CO) codes, provides a useful guide in this case for “full MVNOs”. In the case of CO codes, the CNA is able to either rely on simple validation elements, such as a Commission letter authorizing a CLEC to operate in an area, or the Commission’s website that lists those CLEC authorized to operate as CLECs. This information provides the CNA with the certainty to determine if a CO code applicant meets the eligibility requirement for a CO code. For MNCs, the same logic should apply and “full MVNOs” registered with the Commission on a distinct “full MVNO” list would enable the CNA to determine whether an MNC can be assigned to a specific entity claiming to be an MVNO. This approach is transparent for the industry and should 10 be relatively easy to implement. It would also enable the CNA to perform its duties and assign MNCs in an efficient and orderly manner. The need for Commission validation For the same reason that the Commission qualifies other types of entities, like LECs with specific rules and criteria, “full MVNOs” should similarly have a clearly articulated and easy to administer set of criteria and be qualified by the Commission. A neutral party like the Commission has the ability to examine confidential information and has the technical expertise to confirm whether an entity meets the criteria of a “full MVNO.” “Full MVNO” Definition Some CSCN parties have proposed a definition for inclusion in the IMSI guideline. Although we fully support having the definition of a “full MVNO” included in the IMSI guideline for reference purposes (since not all parties would necessarily know where to look for this information on the Commission’s website) we nevertheless believe that simply having a definition in the IMSI guideline is not sufficient. The status of a “full MVNOs” must be validated using a specific, easy to administer set of criteria. The definition in the IMSI guideline could be a simple summary but the criteria to be used to validate whether an entity is a “full MVNO” is ultimately what is most important. To assist the Commission in validating “full MVNO” status, we propose below the following criteria. For greater certainty, under our proposed approach, an entity would not qualify as a “full MVNO” unless it satisfies all three of the following criteria: 1) Owns and operates core network hardware separate from all WSPs (e.g. switches, routers, etc.) Rationale: the “full MVNO” must be able to demonstrate that it owns a core network and is not relying on the core network of another carrier. 11 2) Owns and operates a service profile management system (a Home Location Register (HLR), or a Home Authentication, Authorization, and Accounting (AAA), or a Home Subscriber System (HSS)) Rationale: the “full MVNO” must be able to demonstrate that it has its own service profile management system. 3) Handles its own network routing Rationale: the “full MVNO” must be able to demonstrate that it is handling its own network routing and is not relying on routing by another carrier. Conclusion In conclusion, Bell’s resolution of the “full MVNO” issue embodies the following three principles: i) the Commission adopts a clear and complete definition of a “full MVNO” that is included for reference in the IMSI guideline, ii) that the Commission manage a process where entities are required to register as “full MVNOs” and, iii) that the Commission assesses whether the entities that claim to register as “full MVNOs” actually meet the required criteria before they are listed on its website. Our recommended definition of “full MVNO” is an entity that meets each of the following three criteria: A “full MVNO”: 1) Owns and operates core network hardware separate from all WSPs (e.g. switches, routers, etc.); and, 2) Owns and operates a service profile management system (a Home Location Register (HLR), or a Home Authentication, Authorization, and Accounting (AAA), or a Home Subscriber System (HSS)); and, 3) Handles its own network routing. 12 POSITION 4 (SaskTel): Full MVNO Definition: A "Full" MVNO utilizes a Carrier Wireless Service providers network through a negotiated arrangement to provide its own managed telecommunication services to the general public. It is differentiated from Resellers and Rebillers by its requirement to own certain network elements to manage the service received by its end customers. SaskTel notes that the definitions proposed by the other parties do not incorporate the ITU requirement from E.212 Appendix B, Paragraph 2, that Mobile Network Codes (MNC)'s are only to be assigned to, and used by public networks offering public telecommunication services. SaskTel has focused its proposed definition on the outcome of the requirement of being a Full MVNO. The Full MVNO must use network elements to provide and manage its own service independent of the Carrier Wireless Service Provider's agreement. This interpretation is informed by the Commission's Notice of Consultation (NC) 2014 - 76 paragraph 5 (requirement "to enable MVNO's to offer services") and Telecom Regulatory Policy (TRP) 2015 -177, Paragraph 43, ("supplies most of the components apart from the RAN"). SaskTel considers that the specific network elements are less relevant, (as they change over time), than the requirement which is to use MVNO owned network resources to deliver and manage the MVNO services. SaskTel notes the International and National industry are and have been concerned about the potential exhaust of the MNC two digits codes. The impact of such an exhaust, driven by industry factors such as additional technologies (which would require a significant number of codes for existing providers), and/or a large number of new participants such as MVNO's could quickly exhaust the remaining MNC unassigned codes. The consequence of the exhaust would be the implementation of an additional country code. The addition of a Wireless Country Code would be the first for the Canadian Wireless Service Providers. Although the real scope could not realistically be determined, SaskTel expects the implementation expense to exceed the cost a carrier would experience in a "standard" NPA exhaust. Despite best industry efforts of managing the exhaust, the country code implementation time line has the potential to restrict competition by MVNO's and WSP's due to the carrier requirement to modify their existing operational and billing systems to accept the new country code. 13 FACTORS: ALTERNATIVES: ANALYSIS: CONCLUSIONS: The CSCN created a draft version of the Canadian International Mobile Subscriber (IMSI) Guideline that was acceptable to all parties except for the definition of a Full MVNO included in the Guideline. RECOMMENDATIONS: The CSCN recommends that the CRTC review the Canadian International Mobile Subscriber (IMSI) Guideline as included and consider the four positions for the included definition of a Full MVNO. The CSCN recommends that the CRTC decide on the definition of a Full MVNO to be included in the Guideline. The CSCN recommends that the CRTC qualify all eligible registrants and create and administer a registration list for Full MVNOs. The CSCN recommends that the CRTC, after determining a final definition for Full MVNO, approve the revised Canadian International Mobile Subscriber (IMSI) Guideline with the final Full MVNO definition. ATTACHMENTS: Revised draft of the Canadian International Mobile Subscriber (IMSI) Guideline 14 Canadian International Mobile Subscription Identity (IMSI) Assignment Guideline Version X.X Approved by Telecom Decision CRTC ?? Dated: dd-mmmm-2015 Developed by: The Canadian Steering Committee on Numbering (CSCN) Date approved by CSCN: 25 June 2015 TABLE OF CONTENTS Page 1.0 Introduction .................................................................................................... 1 2.0 Purpose and Scope ....................................................................................... 1 3.0 References ..................................................................................................... 2 4.0 IMSI Format and Function ............................................................................. 2 5.0 Assumptions and Constraints ...................................................................... 4 6.0 Assignment Principles .................................................................................. 5 7.0 Criteria for MNC Assignment ........................................................................ 7 8.0 Responsibilities of MNC Applicants and Assignees ................................... 8 9.0 Responsibilities of the IMSI Administrator .................................................. 9 10.0 MNC Return and Reclamation Procedures ................................................ 11 11.0 IMSI Resource Conservation and Assignment Audits .............................. 12 12.0 MCC Relief Planning .................................................................................... 12 13.0 Maintenance of Guidelines .......................................................................... 12 14.0 Appeals Process .......................................................................................... 13 15.0 Glossary ....................................................................................................... 13 Appendix 1 Temporary Accommodation for GSM-Based and CDMA-Based Wireless Networks .................................................................................................................. 16 Appendix 2 IMSI Resource Assignment for Public Safety ........................................................ 17 International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 1.0 Introduction The Canadian Steering Committee on Numbering (CSCN) developed this Guideline for use in Canada. It becomes effective upon review by the CRTC Interconnection Steering Committee (CISC) and approval by the Canadian Radio-television and Telecommunications Commission (CRTC). In Canada, the Canadian Numbering Administrator (CNA) (hereafter referred to as the “IMSI Administrator”) undertakes the primary administrative functions for all International Mobile Subscription Identity (IMSI) resources. The CNA administers IMSI resources in accordance with Guidelines developed by the CSCN and approved by the CRTC. The administration of IMSIs in Canada is conducted under the regulatory authority of the CRTC and Industry Canada. 2.0 Purpose and Scope This document contains procedures for the assignment and use of IMSIs for Canadian Wireless Service Providers (WSP), Wireless Competitive Local Exchange Carriers (WCLEC), satellite carriers, certain public safety related associations, and ‘Full’ Mobile Virtual Network Operators (MVNO). 2.1 For the purpose of this Guideline, a WSP or WCLEC is defined as a Canadian entity authorized by Industry Canada pursuant to the Radiocommunication Act to provide two-way common carrier wireless mobility communications service to the public. Examples of WSPs and WCLECs include Cellular, Personal Communications Services (PCS), Enhanced Specialized Mobile Radio (ESMR), and Mobile Satellite Services (MSS). A Full MVNO is an MVNO who supplies most of the components of the network it uses to provide services apart from the Radio Access Network (RAN) and is registered with the CRTC as a Full MVNO. 2.2 This Guideline pertains to the entire Canadian IMSI resource. The IMSI Administrator administers only the Mobile Network Code (MNC) segment of the IMSI. The combination of the Mobile Country Code (MCC) and MNC is referred to as the Home Network Identity (HNI) and identifies the home mobile network of a subscription. The remaining segment of the IMSI, the Mobile Subscription Identification Number (MSIN), is directly administered by the network operator to whom the MNC is assigned. -1- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 2.3 This Guideline applies throughout Canada and does not supersede the regulations, procedures or requirements of the CRTC or any other appropriate legal or regulatory authority. 2.4 This Guideline is based on the content of ITU-T Recommendation E.212, The international identification plan for public networks and subscriptions. 3.0 References 3.1 ITU-T Recommendation E.212, The international identification plan for public networks and subscriptions. A copy of ITU-T Recommendation E.212 can be viewed at: http://www.itu.int/rec/T-REC-E.212-200805-I . No part of the Recommendation can be copied without the express permission of the ITU. 4.0 IMSI Format and Function 4.1 The IMSI format and function are based on ITU-T Recommendation E.212. 4.2 Each IMSI uniquely identifies the mobile subscription, the home mobile network of the mobile subscription, and the home country of the home mobile network. The IMSI is not intended to be used for dialling purposes. 4.3 Wireless networks conforming to ITU-T Recommendation E.212 use IMSIs for: a) b) c) d) determination of a mobile subscription’s home mobile network, mobile subscription identification when information about a mobile subscription is to be exchanged between visited and home mobile networks, including subscription and billing information needed to enable charging of visiting mobile subscriptions, mobile subscription identification on the radio control path for registering a mobile subscription in a visited wireless network, mobile subscription identification for signaling on the radio control path, and -2- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 e) 4.4 subscription management, i.e. retrieving, providing, changing, and updating subscription data for a mobile subscription. The format of the IMSI in North America is: Mobile Country Mobile Network Code (MCC) Code (MNC) 3-digits 3-digits* Mobile Subscription Identification Number (MSIN) 9-digits* Home Network Identity (HNI) National Mobile Subscription Identity (NMSI) International Mobile Subscription Identity (IMSI) *Note: See Appendix 1 concerning 2- and 3-digit MNCs. 4.5 The IMSI format in Canada is a fixed 15-digit length -- the maximum allowable by Recommendation E.212. Each IMSI contains an MCC, an MNC, and an MSIN. The MCC and MNC combine to form the HNI. The MNC and MSIN together form the National Mobile Subscription Identity (NMSI). MSINs are administered directly by the wireless network operator to whom the MNC is assigned. 4.6 The function of the MCC is to identify the domiciliary country of a mobile subscription. Some MCCs are used to identify international operators, e.g. satellite systems providing service to aircraft, maritime or land-based mobile subscriptions across or between multiple countries. By analyzing the MCC, a foreign visited wireless network can determine the country or international -3- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 operator from which the mobile subscription originated and in which its home mobile network resides. According to ITU-T Recommendation E.212, an MCC is three digits in length. MCCs other than a test MCC are in the format NXX, where N equals any of the digits 2-9, and X equals any of the digits 0-9. MCCs are assigned by the ITU in response to formal requests from recognized national administrators of ITU-member countries, and more than one MCC may be assigned to a country. In Canada, the recognized national administrator for ITU resources is Industry Canada. The MCC currently assigned to Canada is 302. 4.7 The function of the MNC is to identify the home mobile network, within the country associated with the MCC, of the visiting mobile subscription. The visited mobile network uses the MCC-MNC combination to determine the home mobile network of the visiting mobile subscription that is requesting service. Per ITU-T Recommendation E.212, MNCs may be two or three digits in length, the choice being a national matter. In North America MNCs are three digits in the format XXX, where X equals any of the digits 0-9. The three digit maximum is necessary so that, when combined with the 3-digit MCC, the visited network need not analyze more than six digits to determine the home mobile network of the visiting mobile subscription. The XXX format provides one thousand MNCs (000-999) for each MCC. (See Appendix 1 for “temporary” GSM - based limitations on MNC assignments.) 4.8 The function of the MSIN is to uniquely identify a mobile subscription within its home mobile network. MSINs in Canada are nine digits in length and in the format XXXXXXXXX, where X equals any of the digits 0-9. ITU-T Recommendation E.212 limits IMSI length to a 15-digit maximum. Since the Canadian IMSI format includes a 6-digit MCCMNC, a 9-digit MSIN is the maximum allowable. The nine digit format provides one billion MSINs per MNC. 4.9 The NMSI contains the MNC followed by the MSIN and is a fixed twelve digit length in Canada. It is the national portion of the IMSI, i.e. excluding the MCC. Its length and format are determined nationally within the constraints of ITU-T Recommendation E.212. 5.0 Assumptions and Constraints This Guideline is based on the following assumptions and constraints: -4- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 5.1 This Guideline shall permit the effective and efficient management of IMSIs as a finite resource. 5.2 The function of the IMSI Administrator will be performed by the CNA. 5.3 This Guideline for IMSI assignments shall remain in effect until there is regulatory approval to change it. 5.4 This Guideline does not describe the method by which IMSIs are transmitted between and processed by networks. Network interworking arrangements are contained in other standards, documents, or business agreements. 6.0 Assignment Principles The following assignment principles will apply to the assignment of MNCs by the IMSI Administrator and the use of IMSIs by assignees: 6.1 MNCs are to be assigned and used in accordance with this Guideline. 6.2 On receipt of a valid application, the IMSI Administrator will assign an initial MNC to the applicant. In exceptional circumstances, in order to accommodate certain technological or operational constraints, e.g., where separate facility-based wireless networks are provided by a WSP or WCLEC, the IMSI Administrator can assign an additional MNC in the XX0 format. In the event that an applicant submits an application for a third MNC in the XX0 format, the IMSI Administrator shall consult with CRTC staff before making an assignment decision. If an MNC in the XX0 format is currently assigned to a wireless Carrier, then MNCs in the XXX format within that MNC can be assigned to that wireless Carrier without consultation with CRTC staff. 6.3 The 3-digit MNC is to be assigned so as to uniquely identify the home mobile network of the service user. 6.4 An MSIN is assigned by a wireless network operator to a mobile subscription. An individual IMSI may only be assigned to a single subscription; however, more than one IMSI may be assigned to a mobile user. 6.5 IMSIs and MNCs shall be assigned to permit the most effective and efficient use of a finite resource in order to defer, as long as practical, the need to request additional MCC resources. -5- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 6.6 IMSIs are a public resource. The assignment of any portion of an IMSI (i.e., MNC, MSIN) does not imply ownership of the resource by either the entity to which it is assigned or by the entity performing the administrative function. 6.7 Should an assignee transfer control of its network operation through acquisition or merger to another operator, then the use of the assigned MNC is transferable to that operator. 6.8 The IMSI Administrator will: a) Assign MNCs in a fair, timely and impartial manner to any applicant that meets the criteria for assignment contained in this Guideline. b) Assign MNCs on a first-come, first-served basis from the available pool of unassigned MNCs. c) Make all assignments based on the procedures in this Guideline. d) Treat sensitive information received from applicants as proprietary and confidential. e) Assign MNCs to applicants authorized by Industry Canada or the CRTC to provide service on an experimental basis. In the event the applicant is eligible, based on section 6.2 above, and is subsequently authorized to provide the service on a regular basis, the assignee may be permitted by the IMSI Administrator to retain the same MNC assigned for the experimental operation. f) MNCs 990 to 999 have been set aside for experimental purposes not initially requiring regulatory approval. Should the experimental period exceed one year, the temporary assignee is required to re-apply for the use of the MNC, three months in advance of the expiration of the one year timeframe. 6.9 Information that is requested of applicants in support of an MNC application shall be uniform and kept to a minimum. 6.10 Assigned MNCs should be deployed as soon as possible, but no later than twelve months after initial assignment. If the assignee can demonstrate that an assigned MNC has not been deployed solely due to delays beyond its control, the time period can be extended for up to 90 days. At the discretion of the IMSI Administrator, up to three additional 90-day extensions may be granted. 6.11 An entity that is denied an MNC assignment or extension under this Guideline has the right to appeal that decision in writing to the CRTC with a copy provided to the IMSI Administrator. 6.12 An MNC recovered or returned to the IMSI Administrator’s pool will be aged for a period of not less than one year, from the date of return to the MNC pool, before reassignment. -6- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 6.13 Applicants for MNCs must comply with all applicable Canadian regulatory requirements in regards to the provisioning of wireless network services. 7.0 Criteria for MNC Assignment The assignment criteria in the following paragraphs should be considered by a potential MNC applicant before submitting an MNC application and will be used by the IMSI Administrator in reviewing and processing an MNC application: 7.1 The MNC applicant must be one of the following; a) b) c) an entity who is licensed by Industry Canada for the spectrum utilized by a wireless network and be registered as a telecommunications carrier with the CRTC to operate in the area in which it intends to provide a mobility service, and who provides evidence of certification to the IMSI Administrator. A public safety related association that has a need to roam onto/from telecommunications carriers’ networks in Canada may also be an applicant for an MNC. See Appendix 2. an entity registered with the CRTC as a Full MVNO. 7.2 An MNC will only be assigned by the IMSI Administrator upon receipt and approval of a completed Form A – Mobile Network Code (MNC) Application, Reservation, Information Change or Return. 7.3 The applicant must certify that the MNC will be used for mobile applications. That is, the applicant must certify that the service provided will have the following characteristics: a) b) 7.4 Terminal Mobility – The ability of a terminal to access telecommunication services from different locations and while in motion, and the capability of the network to identify and locate that terminal. Personal Mobility – the ability of a user to access telecommunications services at a terminal on the basis of a personal identifier, and the capability of the network to provide those services according to the user’s profile. Personal mobility involves the network capability to locate the terminal associated with the user for the purpose of routing. At least one radio interface protocol used for the mobile service provided by the applicant must be from the following list of protocols known to require an IMSI for identification and signaling: a) GSM-based protocols including General Packet Radio Service (GPRS), Enhanced Data for GSM Evolution (EDGE), Wideband CDMA (W-CDMA), and High Speed Packet Access (HSPA); -7- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 b) c) CDMA2000 protocols including CDMA2000 1X (a 3GPP2 cellular technology providing voice and data services) and High Rate Packet Data (HRPD [EVDO]); or Long Term Evolution (LTE) protocols including LTE Advanced. 7.5 A second MNC may be assigned to an applicant in order to accommodate certain technological or operational constraints. (See section 6.2.) The applicant must provide a description of the technological or operational constraints and an explanation of how the assignment of an additional MNC resource will resolve the described technological or operational constraints. In the event that a network provider submits an application for a third or subsequent MNC, the IMSI Administrator shall consult with CRTC staff before making an assignment decision. 7.6 The CNA shall only provide numbering services and assign numbering resources to entities that have executed a “Service User Agreement” in the form determined by the Canadian Numbering Administration Consortium (CNAC). 8.0 Responsibilities of MNC Applicants and Assignees MNC applicants and Assignees shall comply with the following: 8.1 MNC applicants and Assignees must meet all conditions specified in this Guideline. Copies of this Guideline may be accessed from the CNA’s website at: www.cnac.ca. 8.2 MNC applicants shall submit their requests to the IMSI Administrator using Form A – Mobile Network Code (MNC) Application, Reservation, Information Change or Return. Copies of all required forms are included in Attachment 1 to this Guideline. 8.3 MNC Assignees shall: 8.3.1 Assign and efficiently manage the MSINs (last nine digits of the IMSI) associated with the assigned MNC, and maintain MSIN assignment records. Reports from these records may be required for audit purposes. 8.3.2 Inform the IMSI Administrator of changes to the information associated with an MNC assignment by using Form A – Mobile Network Code (MNC) Application, Reservation, Information Change or Return. Changes may occur when an MNC is transferred to a different network because of a merger or acquisition. The initial assignee of the MNC involved in a transfer occurring through merger, acquisition or other means must immediately inform the IMSI Administrator when such a change becomes effective. In addition, the company acquiring the IMSI must immediately inform the IMSI Administrator using Form A and supply proof of the merger or acquisition. Timely submission of change information is -8- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 required to enable the IMSI Administrator to maintain accurate MNC assignment records. 8.3.3 Participate in an IMSI audit process, when requested by the appropriate regulatory authority. 8.3.4 Deploy any MNC, either assigned directly by the IMSI Administrator or obtained through merger or acquisition, within the specified time period from the date of initial assignment (Section 6.10) and inform the IMSI Administrator of MNC deployment by submitting Form C – Mobile Network Code (MNC) Deployment. 8.3.5 Apply to the IMSI Administrator for an extension, in accordance with this Guideline if the MNC is not deployed within the specified time period from the date of initial assignment, and the MNC is still required. 8.3.6 Return to the IMSI Administrator, using Form A – Mobile Network Code (MNC) Application, Reservation, Information Change or Return: a) b) c) any MNC no longer needed for the provision of wireless services; any MNC not deployed within the time period specified, including extensions; and/or any MNC not used in conformance with this Guideline. 8.4 Forms must be signed and submitted by a resource applicant's or Assignee's Authorized Representative for making resource requests. The Authorized Representative must be either a corporate officer or other designated individual for submitting resource requests, and other documentation described in this Guideline. This serves as a control measure for the protection of both the resource applicant and the IMSI Administrator. The resource applicant or Assignee may designate its Authorized Representatives for multiple types of numbering resources in a single letter to the IMSI Administrator. 9.0 Responsibilities of the IMSI Administrator The IMSI Administrator shall: 9.1 Provide information to the industry on the structure and proper use and management of IMSIs. 9.2 Provide copies of this Guideline and forms to MNC applicants and Assignees, and respond to reasonable questioning pertaining to any aspect of the IMSI process, forms, instructions, etc. The IMSI Administrator is not responsible for completing forms for, or training the staff of, MNC applicants and Assignees. -9- International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 9.3 Review and process MNC applications as follows: 9.3.1 Review the application to determine if all requested information is provided and credible. If not, return the application to the applicant requesting that any deficiency be corrected. 9.3.2 Inform applicants of the status of their requests using Form B – IMSI Administrator’s Response-Confirmation. Notify the applicant in writing of the disposition (i.e., approved, denied or additional information required) within 14 calendar days from receipt of Form A. The response will include: a) b) c) 9.4 if assigned, the specific MNC(s) assigned; if denied, the reasons for denial and instructions on how and where to appeal the decision; or, if additional information is required, the specific information required. Use the following assignment procedures: 9.4.1 There may be technical considerations or limitations on the part of the assignee that require a specific assignment or preclude them being able to use the next consecutive MNC assignment. These exceptions are set forth below and in Appendix 1 to this document. Due to possible legacy issues such as dual technology carriers, the MNC range 302-000 to 302-009 should not be assigned until further investigation is undertaken. 9.4.2 MNC applicants eligible for multiple MNCs may request that such MNCs be assigned in the next available block of numerically sequential codes (excepting those MNCs reserved or unavailable for assignment, in accordance with this Guideline or any subsequent appendices to this Guideline). In such cases, a separate Form A should be submitted for each MNC requested, along with a cover letter requesting their assignment in a sequential block. 9.4.3 When assigning an MNC that has been reclaimed or returned, the IMSI Administrator will ensure that the MNC has remained dormant for not less than one year. 9.5 Maintain accurate and current MNC assignment records. Update the records as required to respond to requests for changes in assignment information reported by MNC Assignees. Respond to these requests within 14 calendar days using Form B – IMSI Administrator’s Response-Confirmation or a letter. 9.6 Publish and maintain on the CNA’s website (www.cnac.ca), a list of assigned MNCs. The list will include the MNC number and the assignee's organization name. The IMSI Administrator shall track the number of MNCs assigned and the - 10 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 assignment rate and advise the CSCN when action needs to be taken to expand the available resource. When the CSCN determines that additional resources are required, the IMSI Administrator should also inform CRTC staff, the ITU National Study Group 2 Chair and Industry Canada. 9.7 Investigate any MNC that has not been deployed within 12 months, and issue extensions if appropriate. 9.8 Reclaim assigned MNCs, in accordance with this Guideline. 9.9 Direct the IMSI conservation program and conduct periodic audits of MNC Assignee records, as required. 10.0 MNC Return and Reclamation Procedures 10.1 Assignee responsibilities Assignees will return MNCs that are no longer required, not deployed, or not used in conformance with this Guideline. Assignees will cooperate with the IMSI Administrator in carrying out its reclamation and auditing responsibilities. 10.2 Administrator responsibilities The IMSI Administrator will contact any MNC Assignee identified as not having returned to the administrator, for reassignment, any MNC no longer required, not deployed, or not used in conformance with this Guideline. The IMSI Administrator will first seek clarification from the Assignee regarding any alleged non-use or misuse. If the Assignee provides an explanation satisfactory to the IMSI Administrator, and in conformance with this Guideline, the MNC will remain assigned. If no satisfactory explanation is provided, the IMSI Administrator will request a Form A from the Assignee to return the assigned MNC for reassignment. If a direct contact cannot be made with the Assignee to affect the above process, a registered letter will be sent to the Assignee’s address of record requesting that they contact the administrator within thirty days regarding the alleged MNC non-use or misuse. If the letter is returned as non-delivered or is ignored, the IMSI Administrator will advise CRTC staff that the MNC will be made available for reassignment following the required dormant period, if any, unless CRTC staff advises otherwise. The IMSI Administrator will: a) b) Accept all referrals of alleged non-use or misuse of MNCs, and investigate and review such referrals in the context of this Guidelines Attempt to resolve the referral or, if appropriate, initiate the Guidelines revisions process and/or refer the case to CRTC staff. - 11 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 11.0 IMSI Resource Conservation and Assignment Audits 11.1 Assignment and management of Canadian IMSI resources are undertaken with the following conservation objectives: a) b) 11.2 to efficiently and effectively administer/manage a limited resource through code conservation, and to eliminate or delay the exhaust potential for the MCCs currently assigned to Canada. To promote the efficient and effective use of numbering resources, audits of MNC assignments may be performed to ensure consistent compliance with these Guidelines. 12.0 MCC Relief Planning 12.1 When 70% of the MNCs for a given MCC have been assigned, the IMSI Administrator will inform the CSCN, CRTC staff, Industry Canada and the ITU Study Group 2 Chair that MCC 302 assigned to Canada is approaching exhaust. 12.2 When the IMSI Administrator informs the CSCN, CRTC staff, Industry Canada and the ITU Study Group 2 Chair that the MCC 302 assigned to Canada is approaching exhaust, the IMSI Administrator will: a) b) c) Conduct an audit of current IMSI assignment reports to determine if IMSI utilization is efficient and, if necessary, Provide the requisite data to CRTC staff and the ITU Study Group 2 Chair so that Industry Canada may request additional MCC resources from the ITU-T. Currently, MCCs 303-307 are not allocated. Should additional MCCs be required by Canada, MCCs in this list of unallocated MCCs could be requested in order to continue with consecutive MCC allocations. 13.0 Maintenance of Guidelines It may be necessary to modify this Guideline periodically to meet changing and unforeseen circumstances. The need for Guideline modification may be identified by the administrator, the CRTC or any entity in the telecommunications sector. The CSCN will coordinate the modification process. Questions or concerns regarding the maintenance of the Guideline may be directed to the Canadian Numbering Administrator, 60 Queen Street, Suite 1516, Ottawa, Ontario K1P 5Y7 (Telephone: 613-563-7242). - 12 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 14.0 Appeals Process Disagreements may arise between the IMSI Administrator and MNC applicants or Assignees in the context of the administration and management of IMSIs and the application of this Guideline. In all cases, the IMSI Administrator and MNC applicants/Assignees will make reasonable, good faith efforts to resolve such disagreements among themselves, consistent with this Guideline, prior to pursuing any appeal. Appeals may include, but are not limited to, one or more of the following options: a) b) The MNC applicant/Assignee will have the opportunity to resubmit the matter to the administrator for reconsideration with or without additional input. The MNC applicant/Assignee submits an appeal to the CRTC (or Industry Canada for international issues) to change the IMSI Administrator’s action. Reports on any resolution resulting from the above options, the content of which will be mutually agreed upon by the involved parties, will be kept on file by the administrator. At minimum, the report will contain the final disposition of the appeal; e.g. whether or not an MNC was assigned. 15.0 Glossary Term Authorized Representative Canadian Numbering Administrator (CNA) Canadian Radio-television and Telecommunications Commission (CRTC) Canadian Steering Committee on Numbering (CSCN) Carrier Conservation CRTC Interconnection Steering Committee (CISC) Definition A person authorized in accordance with this Guideline to sign and/or submit resource requests and other documentation described in this Guideline. The entity responsible for the administration of numbering resources in Canada, including IMSIs. The Canadian regulatory body for broadcasting and telecommunications. Its responsibilities include the regulation and administration of domestic numbering. An open public forum established as a subtending working group of the CRTC Interconnection Steering Committee to consider and resolve numbering resource issues. For the purpose of this Guideline a Carrier is a Local Exchange Carrier or Wireless Carrier. Consideration given to the efficient and effective use of a finite resource in order to minimize the cost and need to expand its availability while at the same time allowing the maximum flexibility in the introduction of new services, capabilities and features. Undertakes tasks related to technological, administrative and operational issues on matters assigned by the Canadian Radiotelevision and Telecommunications Commission (CRTC) or originated by the public, that fall within the CRTC's jurisdiction. Full MVNO To be determined by the CRTC. Home Network Identity (HNI) The combination of the Mobile Country Code (MCC) and MNC is referred to as the HNI in North America and identifies the home mobile network of a subscription. - 13 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 Home mobile network International Mobile Subscription Identity (IMSI) International Roaming Capability International Telecommunication Union (ITU) ITU Telecommunication Standardization Sector (ITU-T) Local Exchange Carrier (LEC) MNC Assignee Mobile Country Code (MCC) Mobile Network Code (MNC) Mobile Subscriber Mobile Subscription Mobile Subscription Identification Number (MSIN) Mobile Virtual Network Operator (MVNO) National Mobile Subscription Identity (NMSI) Radio Access Network (RAN) Visited network The mobile network authorized by Industry Canada or certain fixed networks in the PSTN licensed by the CRTC to which the mobile station/user is subscribed. The string of digits, up to a maximum of 15 digits, that uniquely identifies a mobile terminal or mobile subscription internationally. The IMSI consists of three fields; the Mobile Country Code (MCC), the Mobile Network Code (MNC), and the Mobile Subscription Identification Number (MSIN). The MCC is uniformly 3-digits in length and identifies the home country of a roaming terminal/user. The MNC is 3-digits in length and identifies the home network of a roaming terminal/user (see HNI definition above). The MSIN is 9digits in length and uniquely identifies the roaming subscriber/terminal. The use of an IMSI enables international roaming capability. The ability of a mobile station/subscriber to use subscribed services while outside their home country. The United Nations specialized agency in the field of telecommunications. A permanent arm of the ITU responsible for studying technical, operating and tariff questions and issuing Recommendations on them with a view to standardizing telecommunications on a worldwide basis. An entity that has been authorized by the CRTC to provide local exchange service. The entity to which a Mobile Network Code (MNC) has been assigned. A 3-digit code that identifies the domiciliary country or international operator for a mobile subscription. By analyzing the MCC, a visited foreign network can determine the home country where the mobile subscription originated and its home network. A 2 or 3-digit code (3 in North America) that identifies the home network, within the country associated with the MCC, of a visiting mobile subscription. The visited network uses the MCC-MNC combination to identify the home network of the visiting mobile subscription that is requesting service. An entity or person that contracts to receive or pay for a public mobility service. An account registered with a wireless service provider and assigned to a subscriber. A mobile subscription is uniquely identified by an IMSI. The third part of the IMSI, a 9-digit number (a maximum of 10 digits if the MNC is 2-digits) which is administered by the relevant operator to identify individual subscriptions. An MVNO is a wireless service provider who uses the spectrum and RAN of a wireless carrier and, in some cases, other facilities and/or services, to provide mobile wireless services to consumers. A number consisting of the MNC followed by the MSIN, a fixed length 12-digit number in Canada. It is the national portion of the IMSI (i.e., excluding the MCC). A RAN is the part of a mobile wireless network that includes equipment such as towers, antennas and base stations. The network providing service to a subscriber when the subscriber roams outside the home network. - 14 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 Wireless Carrier Wireless Service Provider (WSP) or Wireless Competitive Local Exchange Carrier (WCLEC) A facilities-based provider that holds a licence for spectrum to provide mobile service in Canada. A Canadian entity authorized by Industry Canada pursuant to the Radiocommunication Act to provide two-way common carrier wireless mobility communications service to the public. - 15 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 Appendix 1 Temporary Accommodation for GSM-Based and CDMA-Based Wireless Networks Currently some GSM-based (Global System for Mobile) and CDMA-based (Code Division Multiple Access) wireless networks with which Canadian wireless networks have, or will have, roaming agreements can handle only 2-digit MNCs. To accommodate this 2-digit limitation, the following assignment principles are temporarily added to these Guidelines until such time as GSM and CDMA wireless networks have been modified to support 3-digit MNCs: 1. 2. 3. MNCs in the format XX0, where X equals any of the decimal digits 0 through 9, shall only be assigned to applicants using GSM or CDMA technology. When an applicant using a GSM or CDMA network requests an MNC assignment in the format XX0, the IMSI Administrator shall assign an available MNC in the format XX0, preferably in a MNC series where none of the XX1 through XX9 MNCs have been assigned. Where an MNC in the format XX0 has been assigned, the corresponding unassigned MNCs in the format XX1 through XX9 shall not be assigned to other applicants until such time as the limitation is removed. - 16 - International Mobile Station Identity (IMSI) Assignment Guideline Approved: d mmm 2015 Appendix 2 IMSI Resource Assignment for Public Safety 1. The IMSI Administrator will assign a single, common Mobile Network Code (MNC) for use by all Industry Canada authorized 700 MHz public safety broadband network operators. 2. In addition to the allocation of the single public safety MNC, the IMSI Administrator is authorized to set aside additional MNCs for use by public safety if justified to the IMSI Administrator, CRTC staff and Industry Canada staff. 3. Only the Industry Canada authorized 700 MHz public safety network operator may apply for the use of the single MNC, and will do so by using Form A of Attachment 1 where: a. b. c. d. e. 4. The public safety network operator will select “Public Network Operator” as the type of entity requesting use of the public safety MNC; The applicant will provide documented authorization for use of the MNC to the IMSI Administrator; Contact information on the form must be provided for the use of the MNC by the public safety network; The entity that submits the application is responsible for the MNC Assignee responsibilities per section 7.3 of the IMSI Guideline, including the assurance that IMSI station ID assignments are made in accordance with the guidelines for such assignments and ensuring that conflicting assignments are not made with another authorized user of the MNC assigned for public safety use; and, The entity that submits the application is responsible for maintaining the contact information associated with the use of the MNC. The entity that submits the application is responsible for its use of the MNC in accordance with this Guideline. - 17 - International Mobile Station Identity (IMSI) Approved: 6 November 2013 Attachment 1 INTERNATIONAL MOBILE SUBSCRIPTION IDENTITY (IMSI) CANADIAN APPLICATION FORMS The forms in this package are used for communication between the IMSI Administrator and applicants for and assignees of these resources. Forms included in this package are: Form A - Mobile Network Code (MNC) Application, Reservation, Information Change or Return Applicants complete, sign, and send this form to the IMSI Administrator when applying for or changing the status of an MNC. Form B - IMSI Administrator’s Response/Confirmation The administrator uses this form to notify the applicant of the outcome of his/her application. Form C - Mobile Network Code (MNC) Deployment The MNC Assignee uses this form to notify the IMSI Administrator that the assigned code has been deployed. Return completed forms to the administrator. Canadian Numbering Administrator 60 Queen St., Suite 1516 Ottawa, Ontario K1P 5Y7 Tel: 613-563-7242 Fax: 613-563-9293 E-mail: NonCOCodeApps@leidos.ca International Mobile Station Identity (IMSI) Form A Approved: dd mmmm 2015 Form A – Mobile Network Code (MNC) Application, Reservation, Information Change or Return This Form A is to be used by a MNC Code Applicant or MNC Holder to apply for a MNC assignment, reservation, information change, or return. Use one Form A for each MNC requested. One Form A may be used to make the same information change for more than one MNC or to return more than one MNC. Mail, fax, or e-mail the completed form to the IMSI Administrator. The preferred method of submission is by e-mail. As of the date of issue of this form, the IMSI Administrator contact information is: Telephone: (+1) 613 563 7242 Facsimile: (+1) 613 563 9293 E-mail: NonCOCodeApps@leidos.ca Postal address: 1516-60 Queen Street, Ottawa, ON K1P 5Y7 See http://www.cnac.ca/about/contact_us.htm for updates to CNA contact information. If this is the first time that you have submitted a Form A to the IMSI Administrator that must be signed by an Authorized Representative, please send a signed facsimile or a paper copy of this form to the IMSI Administrator in addition to or instead of a signed e-mail submission containing a scanned signature. I hereby certify that the following information is true and accurate to the best of my knowledge and that this application has been prepared in accordance with the currently applicable version of the Canadian International Mobile Subscription Identity (IMSI) Assignment Guidelines. Authorized Representative of MNC Applicant International Mobile Station Identity (IMSI) Form A Approved: dd mmmm 2015 Signature Title Application Date Type of Application (check one): MNC Assignment MNC Reservation MNC Information Change MNC Return International Mobile Station Identity (IMSI) Form A Approved: dd mmmm 2015 1.0 GENERAL INFORMATION 1.1 Contact Information: MNC Applicant or MNC Holder Entity Name: Address: Contact Name: City, Province, Postal Code: Facsimile: OCN: Telephone: E-mail: 1.2 Details relating to MNC Assignment or Reservation: a) Type of Entity (See section 7.1 of the Guideline): WSP or WCLEC (commercial or government (public safety related)), or its authorized agent offering mobility services with a need to roam onto/from public networks; or A telecommunications carrier licensed by the CRTC and Industry Canada that provides personal mobility services. A Full MVNO b) Indicate type and date of certification or registration (eg., letter of authorization, licence, CRTC registration list, etc.) or provide other explanation: c) Type of radio interface protocol used by the network equipment or end user devices (may choose more than one): GPRS EDGE W-CDMA International Mobile Station Identity (IMSI) Form A Approved: dd mmmm 2015 HSPA 1xRTT HRPD/EVDO LTE/LTE Advanced d) Type of service for which MNC is being requested: e) MNC preference(s) (optional): f) Undesirable MNC(s) (optional): 1.3 Type of Application: MNC Assignment Initial MNC Additional MNC for Growth (details): MNC(s) already assigned: Additional MNC for Unique Purpose (details): Experimental MNC (excluding 99X series): MNC(s) already assigned: MNC Reservation: Initial MNC Additional MNC for Growth (details): MNC(s) already assigned: Additional MNC for Unique Purpose (details): MNC(s) already assigned: Information Change: MNC(s) affected – Type of change: OCN Details (provide attachment if needed): International Mobile Station Identity (IMSI) Form A Approved: dd mmmm 2015 Company Name Contact Information Address Return of MNC MNC(s) being returned: International Mobile Station Identity (IMSI) Form B Approved: dd mmmm 2015 Form B – IMSI Administrator’s Response/Confirmation Code Applicant: Entity Name: Contact Name: Address: City, Province, Postal Code: E-mail: Telephone: Facsimile: OCN: Date of Application: Date of Receipt: Date of Response: Effective Date: IMSI Administrator Contact Information Name: IMSI Administrator Contact Name: Address: 60 Queen St. Suite 1516 City, Province, Postal Code: Ottawa, ON K1P 5Y7 Telephone: 613-563-7242 E-mail: Facsimile: 613-563-9293 Signature: MNC Assignment MNC Assigned: Date of Assignment: This MNC must be placed in-service within 12 months of the date of this notification. MNC Reservation International Mobile Station Identity (IMSI) Form B Approved: dd mmmm 2015 MNC Reserved: Date of Reservation: This MNC must be placed in-service within 12 months of the date of this notification. MNC Information Change MNC(s) Affected: Return: MNC(s) Returned: Form Incomplete (additional information required in the following section(s)): Form complete, application denied (explanation): Processing of application temporarily suspended (explanation and further action): International Mobile Station Identity (IMSI) Form B Approved: dd mmmm 2015 Form C – Mobile Network Code (MNC) Deployment IMSI Applicant: Entity Name: Contact Name: Address: City, Province, Postal Code: Telephone: Facsimile: E-mail: OCN: IMSI Administrator Name: Telephone: 613-563-7242 Facsimile: 613-563-9293 E-mail: By signing below, I certify that the MNC specified in Section 1 below is in service and that the MNC is being used for the purpose specified in the original application. Authorized Representative of MNC Applicant Signature Title International Mobile Station Identity (IMSI) Form B Approved: dd mmmm 2015 Date 1. MNC: 2. Dates: a. Date of Application: b. Effective Date: c. In-Service Date: