ARCHIVED - Telecom Commission Letter - 8621-C12-01/00

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Letter

Ottawa, 30 April 2007

File No.:    8621-C12-01/00

BY E-MAIL

To: Distribution List (Attached)

Re:   Request to put a halt to current discussions in the CISC Emergency Services Working Group (ESWG) regarding the implementation of Enhanced 9-1-1 (E9-1-1) for nomadic Voice over Internet Protocol (VoIP) service providers

This will refer to the letter dated 4 April 2007 submitted to the Commission by Cogeco Cable Inc., Quebecor Media Inc., Rogers Communication Inc. and Shaw Communications (the Cable Carriers).

Commission staff notes the issues raised by the Cable Carriers are in regard to the ongoing task to develop a functional architecture for the implementation of VoIP E9-1-1 service in Canada at the CRTC Interconnection Steering Committee (CISC) Emergency Services Working Group (ESWG).   The Commission requested t he CISC ESWG to undertake this task in CRTC Interconnection Steering Committee - Consensus report on E9-1-1 services provided to nomadic and fixed/non-native VoIP subscribers, Telecom Decision CRTC 2006-60, 21 September 2006 (Decision 2006-60).

Staff notes that the Cable Carriers in their letter are requesting the Commission to halt the current CISC ESWG process due to lack of consensus and to initiate a formal public process to asses what form of nomadic VoIP E9-1-1 routing model might meet the public interest.   The Cable Carriers are also requesting that this public process take into consideration the evolution of technical standards in the United States and elsewhere, as well as perform an assessment of the ongoing effectiveness of the interim solution of the routing of nomadic VoIP 9-1-1 calls.

Commission staff notes that the ESWG is currently in process of drafting a non-consensus report to be presented to the Commission highlighting the proposed functional architecture as well as identifying the specific non-consensus issues raised by some members in regards to that proposal.   Commission staff notes in the 28 March 2007 EWSG meeting, all members were requested to provide to the ESWG any non-consensus issues they have on the proposed functional architecture , with supporting rationale, for inclusion in the non-consensus report.

It is through this EWSG report that the industry as members of the ESWG, can present the consensus and non-consensus views on the technical issues in order for the Commission to make a determination.

As a result, Commission staff considers that it would not be in the public interest at this time to halt the current discussions in CISC of the drafting of the ESWG report.   As well, Commission staff considers that it would be premature to carry out any other public process without first reviewing the ESWG report and analysing the non-consensus issues raised in it.

Therefore, Commission staff considers that the Cable Carriers should present any proposed alternatives to or concerns on the technical solutions, equipment and standards used in the proposed functional architecture , as non-consensus items for inclusion in the ESWG report.   Commission staff considers that the Cable Carriers should also provide supporting rationale for their position(s) as well as indicate the impact those position(s) have on the overall functionality of the proposed architecture.

With respect to the Cable Carriers' concerns regarding the overall cost of the proposed architecture and on how underlying broadband service providers will be able to recover their share of the cost , staff considers that the Commission gave direction on this issue in Decision 2006-60.

The Commission in that Decision determined that in order to examine any cost recovery issues, the industry and the Commission must first understand the specific roles and responsibilities of all emergency service industry participants in implementing the proposed VoIP E9-1-1 architecture .   This is particularly the case for those supplying the new operating elements.

Commission staff notes as a consequence that the Commission considered that the development of a cost recovery mechanism would only be appropriate after the Commission has received and reviewed the ESWG report on the functional architecture as directed in Decision 2006-60.

Further, the Commission noted that it would provide guidance to the industry on how and when the issue of cost recovery will be dealt with as part of any implementation directives upon the disposition of the ESWG's architecture report.

As indicated above Commission staff has noted the Cable Carriers' concerns and welcomes their continued participation at CISC.

Yours truly,

'Original signed by P. Godin'

Paul Godin
A/Director General
Competition, Costing and Tariffs
Telecommunications

Attach.

cc:    James Ndirangu, CRTC (819) 997-3670

Distribution List

Cogeco Cable Inc., Yves Mayrand, yves.mayrand@cogeco.com
Quebecor Media Inc., E douard Trepanier, trepanier.edouard @ quebecor.com
Rogers Communication Inc., Ken Engelhart, ken.engelhart@rci.rogers.com
Shaw Communications , jean-brazeau@sjrb.ca  
ESWG Members

Date Modified: 2007-04-30
Date modified: