ARCHIVED - Telecom Commission Letter - 8638-C12-200512964

Letter

Ottawa, 5 June 2008

File # 8638-C12-200512964

By facsimile/e-mail

To: All ILECs, CLECs, and SILECs

Re: Obligations of local exchange carriers and local VoIP service providers with respect to 9-1-1 emergency service

The purpose of this letter is to remind all local exchange carriers (LECs) of their obligations to ensure that all local VoIP service providers to whom they are providing telecommunications services are complying with their local VoIP 9-1-1 emergency service obligations as directed by the Commission.

In a letter dated 28 March 2006, Commission staff had previously requested that the incumbent LECs (ILECs) and competitive LECs (CLECs) provide information as to the names of the local VoIP service providers to whom they were providing telecommunications services.  The Commission staff letter also requested additional information concerning service arrangements between the LECs and resellers, confirmation of registration of local VoIP service providers as resellers, and the provision of emergency 9-1-1 customer notification texts in accordance with the Commission’s directives.

9-1-1 Obligations of VoIP Service providers

In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Decision 2005-21), the Commission directed VoIP service providers supporting fixed/non-native or nomadic local VoIP services to implement, within 90 days of the date of Decision 2005-21, an interim solution for routing fixed/non-native or nomadic VoIP 9-1-1 calls to public safety answering points (PSAPs).  The Commission specified that the interim solution should provide a level of functionality comparable to basic 9-1-1 service and ensure that a 9-1-1 call originating from a local VoIP service would be routed to a PSAP that served the geographical location from which the call was placed.

The Commission described the nature of the interim solution in paragraphs 60 and 61of Decision 2005-21 as one where: an emergency call is first transferred to a VoIP service provider’s call centre; an agent answers the call; and the call centre operator verbally determines the caller’s location.

In Follow-up to Emergency services obligations for local VoIP service providers, Decision 2005-21 – Customer notification requirements, Telecom Decision CRTC 2005-61, 20 October 2005 (Decision 2005-61), the Commission approved the CRTC Interconnection Steering Committee (CISC) final consensus report, which set out the minimum requirements for VoIP 9-1-1 customer notification regarding the availability, characteristics, and limitations of a local VoIP service provider’s 9-1-1 service.

Local VoIP service providers were also directed to submit their proposed VoIP 9-1-1 customer notification texts to the Commission, prior to their use, for Commission review.  The proposed texts were to adhere to the requirements set out in the report attached to Decision 2005-61 and in paragraphs 11 to 13 of that Decision.

In Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points, Telecom Decision CRTC 2007-44, 15 June 2007 (Decision 2007-44), the Commission mandated the use of an emergency call routing solution that ensures that VoIP service providers or third-party operators can obtain direct access to the appropriate PSAP anywhere in the country.  It also prohibited local VoIP service providers from delivering the 9-1-1 calls to PSAPs using low-priority or administrative lines.

In all the above decisions, the Commission directed all LECs, as a condition of providing telecommunications services to local VoIP service providers, to include in their service contracts or other arrangements with these service providers, the requirement that the latter abide by the directions set out in Decision 2005-21, Decision 2005-61 and Decision 2007-44.  Canadian carriers were directed to amend their contracts and other arrangements between Canadian carriers and local VoIP service providers to add these conditions.

In addition, in Regulatory framework for voice communication services using Internet Protocol, Telecom Decision CRTC 2005-28, 12 May 2005, the Commission directed that, as a condition of obtaining services from a LEC or other telecommunications service provider, local VoIP service providers that were not operating as LECs were to register with the Commission as resellers.  Local VoIP service providers operating over their own facilities were required to register as CLECs.

Follow-up action by LECs

In light of the high degree of importance that the Canadian public and the Commission place on 9-1-1 services, Commission staff considers it necessary to undertake specific follow-up action to ensure that all LECs, where applicable, are meeting their obligations to ensure that local VoIP service providers are compliant with Commission directives.

Consequently, all LECs are to provide the following information by no later than 27 June 2008:

• Where a LEC is not providing telecommunications services, such as telephone numbers, to any local VoIP service provider, please respond to that effect;
  
  
• Where a LEC is providing telecommunications services, such as telephone numbers, to any local VoIP service provider:
  
  
• Give the name(s) of all the local VoIP service providers to which it is providing telecommunications services, including company brand name and registered name if different from the company's brand name;
  
  
• Where such information is available, for each local VoIP service provider listed in b) i) above, indicate whether it offers only fixed/native local VoIP service, only fixed/non-native local VoIP, only nomadic local VoIP service, and if it offers more than one type of service, indicate which types;
  
  
• For each local VoIP service provider listed in b) i) above, indicate whether the applicable contracts/agreements or other arrangements include the requirement that, as a condition of providing telecommunications services to local VoIP service providers, the local VoIP service provider must abide by the VoIP 9-1-1 obligations set out in Decision 2005-21, Decision 2005-61 and Decision 2007-44.  Where such contracts/agreements or other arrangements do not include the required VoIP 9-1-1 obligations, in each case, indicate why this was not done, as well as the date when the contracts/agreements or other arrangements will be updated and executed;
  
  
• Confirmation by each LEC, where applicable, that it offers fixed/native, fixed/non-native or nomadic local VoIP service to its own retail customers and indicate which type(s) of local VoIP service is/are offered; and
  
  
• Confirmation by each LEC offering fixed/native, fixed/non-native or nomadic local VoIP service to its own retail customers as indicated in c) above, that the LEC is in compliance with all of its obligations with respect to its retail customers as set out in Decision 2005-21, Decision 2005-61, and Decision 2007-44.

In addition to the items noted above, each LEC, as applicable, is to provide a written reminder of the 9-1-1 obligations of local VoIP service providers, including as a minimum those obligations identified in this letter, to each of the local VoIP service providers it has identified in b) i) above.  Each LEC is to confirm in writing by no later than 27 June 2008 that it has provided this reminder.

Submissions with respect to this letter are to reference the file number noted above and should be addressed to:

Robert A. Morin
Secretary General
Canadian Radio-Television and Telecommunications Commission
Ottawa, Ontario
K1A 0N2 

Sincerely, 

(Original signed by)

John Traversy
Executive Director,
Telecommunications 

c.c: Al Symons CRTC (819) 997-4604
      James Ndirangu CRTC (819) 997-36704 

ILEC List

bell.regulatory@bell.ca;  regulatoryaffairs@nwtel.ca;  regulatory.affairs@telus.com;  reglementa@telebec.com;  jane.gagnon@mtsallstream.com;  document.control@sasktel.sk.ca;  regulatory@bell.aliant.ca; 

CLEC List

michel.messier@cogeco.com ;  andrew@isptelecom.net;  bell.regulatory@bell.ca;  JohnP@mountaincable.on.ca;  regaffairs@quebecor.com;  jesse@vianet.ca;  regulatory.affairs@telus.com;  regulr@bmts.com;  gcordeau@maskatel.qc.ca;  gcordeau@maskatel.qc.ca;  documents@accesscomm.ca;  ataylor@personainc.ca;  alain.duhaime@sogetel.com;  pdowns@nexicom.net;  rfigliuzzi@wightman.ca;  natalie.macdonald@corp.eastlink.ca;  jboutros@globility.ca ;  regulatory@distributel.ca;  steve@wtccommunications.ca;  Regulatory@sjrb.ca;  grubb@hurontel.on.ca;  rbanks@mornington.ca;  iworkstation@mtsallstream.com;  Tiffany.schell@rci.rogers.com;  mlaurent@cooptel.qc.ca;  rroy@telwarwick.qc.ca;  brenda.stevens@rci.rogers.com ;  sachuter@tcc.on.ca;  regulatory@telnetcommunications.com;  sbishay@iristel.com;  regulatory@execulink.com;  paul@axion.ca; 

SILEC List

tim.deweerd@quadro.net ;  lisa@brooketel.ca;  gosfield@gosfieldtel.com;  grubb@hurontel.on.ca;  wagrier@1000island.net;  rbanks@mornington.ca;  steve@wtccommunications.ca;  roxboro@ontarioeast.net;  sachuter@tcc.on.ca;  jpatry@telcourcelles.qc.ca;  nantel@tellambton.net;  telstep@telstep.net;  paul.frappier@telmilot.com;  nantel@tellambton.net;  pdowns@nexicom.net;  pdowns@nexicom.net;  pwightman@wightman.ca;  a.schneider@hay.net;  alain.duhaime@sogetel.com;  regulatoryaffairs@nwtel.ca;  regulr@bmts.com;  j-fmathieu@telupton.qc.ca;  gcordeau@maskatel.qc.ca;  nicolet@puc.net;  lisa.marogna@citywest.ca;  rambacher@amtelecom.ca;  nfrontenac@kw.igs.net;  rob.olenick@tbaytel.com ;  mandrews@amtelecom.ca;  tracy.cant@ontera.ca;  rroy@telwarwick.qc.ca;  regulatory@execulink.com;  telvic@telvic.net;  dreynard@kmts.biz;  regmat@ntl.nt.net;  scoffey@dryden.ca;