ARCHIVED - Letter

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Ottawa, 5 March 2010

Our Reference: 8622-R28-200913344

BY E-MAIL

Distribution

RE: Rogers Cable Communications Inc. – Part VII Application requesting that the Commission review the appropriateness of the ILECs controlling the E9-1-1 system in a competitive environment

Dear Madam/Sir:

On 28 September 2009, the Commission received the above-noted application from
Rogers Cable Communications Inc. (RCCI).  In its application, RCCI identified several concerns regarding the way the E9-1-1 system is managed by Bell Canada.

In its 2 March 2010 letter addressing RCCI’s application, Commission staff indicated that it would request the CRTC Interconnection Steering Committee (CISC) to examine and provide its recommendations on three issues: 1) the change notification process;
2) interconnection with competitors’ E9-1-1 test beds; and 3) competitor access to the automatic location identification (ALI) database.

1. Change notification process

Commission staff is of the view that there may be ways to improve the process by which municipal changes such as street name changes, address changes, boundary changes, amalgamations, and changes to public service answering point systems (PSAPs) are conveyed to all carriers operating within a municipality’s boundaries in a timely manner.

Accordingly, Commission staff requests that CISC examine ways to improve the timeliness of change notification, including the feasibility of ILECs acting as central coordinators, and to provide recommendations to the Commission within eight months of the date of this letter.

Commission staff would expect that municipal representatives and representatives of other public entities with an interest in the municipal change notification process would be included and involved in any such discussions that take place within CISC.

2. Interconnection with competitors’ E9-1-1 test beds

Commission staff notes that both RCCI and Globalive Wireless Management Corp. indicated that allowing competitors to establish their own E9-1-1 test beds would facilitate troubleshooting and improve the efficiency of the E9-1-1 system. Commission staff further notes that Bell Canada and RCCI had been working together to develop a solution to RCCI’s request and that Bell Canada has indicated that any further work on this initiative should be done through CISC.

Commission staff recognizes that there may be benefits to test bed interconnection. However, Commission staff considers that it is a complex initiative which requires additional examination in order to determine whether a cost effective solution can be reached.

Accordingly, Commission staff requests that CISC examine the technical feasibility of test bed interconnection between ILECs and competitors with the objective of providing competitors with the same or similar testing capabilities as the ILECs.  The CISC examination of this issue should also include an assessment of competitor demand for such a service, the benefits to carriers and public safety, and any other considerations as necessary. CISC is requested to provide its recommendations to the Commission within ten months of the date of this letter.

3. Competitor access to the ALI database

Commission staff considers that enabling competitors and wireless carriers to access the ALI database in real-time could improve the accuracy of the information contained in the ALI database and improve the efficiency of the verification process for some carriers.  However, Commission staff recognizes that competitor access to the ALI database is a complex initiative that has not been examined in detail by the industry.

Accordingly, Commission staff requests that CISC examine the technical feasibility of real-time access to the ALI database with the objective of providing competitors with the same or similar access and verification capabilities as the ILECs.  The CISC examination of this issue should also include an assessment of competitor demand for such a service, the benefits to carriers and public safety, and any other considerations as necessary.  CISC is requested to provide its recommendations to the Commission within ten months of the date of this letter.

Sincerely,

Original signed by

Paul Godin

Director General

Competition, Costing and Tariffs

Telecommunications

Distribution : CISC distribution list

c.c.: ILECs

CLECs

WSPs

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