ARCHIVED - Letter
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Ottawa, 21 May 2009
File No: 8638-C12-200907131
BY E- MAIL
Mr. David Palmer
Director - Regulatory Affairs
Bell Canada
160 Elgin Street, 19th Floor
Ottawa ON K2P 2C4
bell.regulatory@bell.ca
Mr. Robert Hersche
Director of Regulatory Affairs
2121 Saskatchewan Drive
Regina SK S4P 3Y2
document.control@sasktel.sk.ca
Dear Sirs,
Re: Follow-up to Implementation of wireless Phase II E9-1-1 service, Telecom Regulatory Policy CRTC 2009-40 - Request for an Extension
In letters to the Commission dated 1 May and 8 May 2009, Bell Aliant Regional Communications, Limited Partnership and Bell Canada (collectively, Bell) requested a revised filing date for their Wireless Phase II Enhanced 9-1-1 (E9-1-1) Service tariff, cost study and modified Agreement for the Provision of Wireless Service Provider Enhanced 9-1-1 Service. Bell requested a one month extension for the filing of these items and proposed that they be filed on 4 June, 2009 . By letter dated 4 May 2009, Saskatchewan Telecommunications (SaskTel) also requested the same extension to filing its revised tariff, cost study and revised agreement as proposed by Bell .
Bell noted that the reason for its request for an extension was because it was experiencing difficulties in concluding negotiations regarding the appropriate interconnection arrangements with the Wireless Service Providers (WSPs).
Bell submitted that the requested extension would have no bearing on Bell 's implementation activities for its Wireless Phase II E9-1-1 service by the 2 August 2009 deadline. Bell noted that WSPs will be able to order the required interconnection service beginning 4 May 2009. Bell also submitted that the aggregation of the E9-1-1 network to the point of interconnection ( POI ) will be completed in early July and WSPs will be able to complete interconnection (both physical and logical) to the E9-1-1 POI by 20 July 2009. Bell submitted that MLP testing is to begin on the same date, if not sooner. Bell noted that the ESWG expected to finalize an MLP testing schedule and it submitted that it will continue to work in close cooperation with WSPs and the ESWG in order to ensure that these timelines are met as well as to coordinate an expedient MLP testing process.
Rogers Wireless Partnership Inc. (Rogers) filed a letter with the Commission dated 14 May 2009 in response to Bell's request for an extension. Rogers disagreed with Bell's claims that it was experiencing difficulties in concluding negotiations regarding the appropriate interconnection arrangements with the WSPs. Rogers submitted that those discussions were concluded promptly and do not serve as a basis for justifying the requested revised filing date.
As well, Rogers submitted that any delay in the initial preparations such as interconnection or rollout testing by any parties, and in particular the ILECs, raises the risk of a delay to the introduction of Wireless Phase II E9-1-1 service in the affected areas.
Rogers also noted that TELUS Communications Company and MTS Allstream were able to meet the deadline imposed by the Commission and have submitted their respective revised Wireless E9-1-1 tariffs.
Commission staff notes that in order for WSPs to implement the Wireless Phase II E9-1-1 service, it is necessary for ILECs to modify their existing network to support the transmission of new location information to PSAPs.
Commission staff notes Rogers ' concern that the delay in filing the tariffs might have an impact on the implementation of the service. Commission staff notes, however, Bell 's and SaskTel's assurances that the requested extension would not impact Bell 's and SaskTel's implementation of the service by the 2 August 2009 deadline.
Commission staff therefore considers that it would be appropriate to grant Bell 's and SaskTel's request for an extension to file its tariffs, cost studies and modified agreements by 4 June 2009 .
However, in order to ensure that there is no delay in the implementation of the wireless Phase II E9-1-1 service, Bell is to:
- Immediately enable WSPs to order the required interconnection facilities and to ensure that WSPs will be able to complete interconnection (both physical and logical) to the E9-1-1 POI by 20 July 2009;
- Immediately provide WSPs with all of the technical information that they require to order the necessary facilities;
- Ensure that WSPs can begin to conduct ALI system integration testing and Mobile Location Protocol ( MLP ) testing on or before 20 July 2009 to ensure that the WSPs have sufficient time to conduct the testing prior to rollout;
- Work in close cooperation with WSPs and the ESWG in order to finalize an ALI and MLP testing schedule to coordinate an expedient ALI and MLP testing process.
Subsequently, SaskTel is to take the above actions, and in addition to file with the Commission and the ESWG the dates by which it will have completed the implementation milestones identified in 1 and 3 above, within 14 days of this letter.
Commission staff notes that the provision of Wireless Phase II E9-1-1 is important for public safety reasons and considers that it is incumbent on all companies to ensure that they take proactive actions to avoid any delays in order to expedite the implementation of the service.
Sincerely,
Original signed by
Paul Godin
Director General
Competition Costing and Tariffs
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