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Ottawa, 18 October 2010
Our Reference: 8663-C12-201015470
Ms. Traci Romedy
Cable & Wireless Americas Operations, Inc.
170 - 20110 Ashbrook Place
Dear Ms. Romedy:
Re: Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller
It has come to the attention of Commission staff that your company may be providing local voice over Internet Protocol (VoIP) services and therefore is required to adhere to the obligations set out in this letter.
A. Provision of 9-1-1 emergency service
In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Decision 2005-21), the Commission mandated that all local VoIP service providers provide 9-1-1 service. Your company is therefore required to provide 9-1-1 service that meets the requirements of Decision 2005-21.
B. VoIP 9-1-1 emergency service customer notifications
In Decision 2005-21, the Commission also mandated that all service providers offering local VoIP services must notify their customers, and potential customers, of any service limitations with respect to their 9-1-1 or Enhanced 9-1-1 (E9-1-1) service before service commencement and to provide on-going customer notification during service provision. This information is to be made available through all of the following: marketing material used for television, radio and printed media, the terms and conditions of service, on-line material, customer service representatives, starter kits, warning stickers affixed to telephone sets, and billing inserts.
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), local VoIP service providers were directed to submit to the Commission their proposed customer notification texts, prior to their use, for Commission review. The proposed texts must adhere to the minimum requirements set out in Decision 2005-61, based on the Emergency Services Working Group Consensus Report ESRE039D – Customer Notification Issues re: 9-1-1 Calls on VoIP, 21 July 2005.
In Viability of proposals for the provision of 9-1-1 service for nomadic and fixed/non-native VoIP subscribers, Telecom Decision CRTC 2010-387, 17 June 2010 (Decision 2010-387), the Commission directed all providers that offer nomadic and fixed/non-native VoIP services to implement the following measures, within 90 days of the date of this decision: (1) contact customers each time they change their billing address to confirm their most likely physical address for emergency purposes; and (2) ensure that customers are able to update their most likely physical address online.
Commission staff has included, as an attachment to this letter, suggested wording for the required VoIP 9-1-1 emergency service customer notification text. The suggested wording is provided as an example only and it must be amended where appropriate to match the specific service offerings of each local VoIP service provider.
C. Registration as a reseller
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 local exchange carrier (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 competitive local exchange carriers (CLECs).
D. Filing requirements
If your company is not providing local VoIP services, it is to confirm so in writing to the Commission within 30 calendar days.
If your company is a provider of local VoIP services, it is to provide all of the following within 30 calendar days from the date of this letter:
(a) confirmation that your company is providing 9-1-1 service in accordance with Decision 2005-21.
(b) the mandatory 9-1-1 emergency service customer notification text for review by the Commission; and
(c) confirmation that your company has requested to be registered with the Commission as a reseller. If your company is already registered, it is to confirm the company name under which it has registered as a reseller and the date of registration.
Requests to register as a reseller must be in writing and must indicate the name and address of the company, the services that are to be offered and in what locations, the name and title of a contact person, and as applicable, their telephone number, facsimile number and e-mail address.
The information requested above can be submitted electronically by accessing the Commission’s website at (www.crtc.gc.ca) under online services and selecting the option of «other» and submissions should be addressed to:
Robert A. Morin
Canadian Radio-television and Telecommunications Commission
The subject of the letter should be “Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller” and should reference the above noted file number.
‘Original signed by S. Bédard’
Senior Manager, Tariffs
cc: C. Abbott, CRTC (819) 997-4509
SUGGESTED STARTER KIT NOTIFICATIONS
External Starter Kit Notification:
On the outside of the starter kit, (company name) will place the following customer notification in English/French (as appropriate):
VoIP 9-1-1 emergency service is different than traditional telephone 9-1-1 services. See enclosed documents for further important details.
Inside Starter Kit:
Inside the starter kit, (company name) will include documentation/user tips with the following text in English/French (as appropriate):
IMPORTANT 9-1-1 INFORMATION
We want to make sure that you are aware of important differences in the way 9-1-1 service operates with a VoIP phone when compared with traditional telephone service. Here’s what you need to keep in mind:
Differences between traditional 9-1-1 service and VoIP phone 9-1-1.
With traditional phone services, your 9-1-1 call is sent directly to the nearest emergency response centre. With VoIP phone service, your 9-1-1 call is forwarded to a third-party service provider that will automatically or manually route your call to the emergency response centre.
Remember to verify your location.
Because you can move your VoIP phone between locations and because, for technical reasons, the emergency operator may not have your name, location or contact information available, you must immediately inform the emergency operator of your location and contact particulars any time you call 9-1-1. Do not risk sending police or ambulance services to the wrong location.
Be prepared during any service interruption.
VoIP phone service depends not only on your continued subscription (and payment) for the service, but also on Internet connectivity and power to function. In the event of power, network, or Internet outages (including congestion), or if your service is disconnected or suspended due to non-payment, you may experience a failure, disruption or delay in your 9-1-1 service. We recommend that you keep an alternative phone service (such as a cellular telephone) handy to increase the reliability of your access to emergency services during any service interruption.
Do not disconnect.
Until you are told to do so by an emergency dispatcher, do not disconnect your 9-1-1 call. If you are inadvertently disconnected, call back immediately.
Keep your service address up to date.
(Company name) will attempt to provide the emergency operator with your service address, so please ensure that your information on file with us is always accurate and updated. If you do not do this (for example, if you are unable to speak during a 9-1-1 call), the emergency operator may assume that you are calling from the last registered address.
Inform other users.
You must notify members of your household and other potential users of your VoIP phone service of the nature and limitations of 9-1-1 emergency calls. To make this easier, attach the included stickers in a visible location on your telephone sets.
Limitations of Liability.
(Company name)’s terms of service limit and disclaim liability related to VoIP 9-1-1 service, so please read these carefully.
For a complete description of our VoIP 9-1-1 service, please see (company name)’s terms of service at www.company.name.website.ca
Telephone Set Stickers Inside Starter Kit:
Inside the starter kit, (company name) will include telephone set warning stickers with the following text:
When dialling 9-1-1, be prepared to provide your address/location.
For more details visit www.company.name.website.ca
The URL indicated on the warning sticker goes to (company name)’s website, on which each page will contain a link to (company name)’s Terms of Service and other important notification items.
SUGGESTED MARKETING / POINT OF SALE NOTIFICATIONS
Printed Marketing Materials:
For its printed marketing materials, (company name) intends to use the following customer notification texts (examples) depending on the nature of the advertisement or promotion:
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 services. See sales representative for further details.
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 services. Visit www.company.name.website.ca for more information.
Note: Notifications similar to those above are also required in the event a local VoIP service provider is making use of other forms of advertising and or promotion such as with television, radio, or other forms of media.
When customers call (company name) to request activation of their VoIP service, (company name)’s representative will notify them of the documents in the starter kit and how the VoIP emergency 9-1-1 services differ from traditional 9-1-1 services. Once their VoIP service is ready to be activated, customers will, through the Internet, log onto their account management site to activate their 9-1-1 service. As part of the activation process, text similar to the printed 9-1-1 documents will be presented to the customers and the customers will be presented with the following in English/French (as appropriate) and their selections will be captured:
I agree that I have read and understand the 9-1-1 service limitations described above.
[link: "I Agree" (to proceed with activation)]
[link: "I Do Not Agree" (to cancel activation)]
Customer Service/Point of Sales:
(Company name)’s customer service and sales representatives will be fully versed in the contents of the VoIP 9-1-1 documents for discussion with potential customers.
On-line marketing on (company name)’s website will contain a link to its Terms of Service prefaced with the following text:
VoIP phone emergency 9-1-1 features differ from traditional 9-1-1 emergency services. Visit [link] [www.company.name.website.ca] for more information
SUGGESTED TERMS OF SERVICE NOTIFICATIONS
THIS SECTION CONTAINS IMPORTANT PROVISIONS, INCLUDING THOSE
REGARDING 9-1-1 SERVICE
Description: VoIP services allow you to make or receive telephone calls over the Internet to or from the public switched telephone network. The nature of VoIP telephone calls, while appearing similar to traditional telephone calling services, create unique limitations and circumstances, and you acknowledge and agree that differences exist between traditional telephone service and VoIP telephone services, including the lack of traditional 9-1-1 emergency services.
9-1-1 service: Because of the unique nature of VoIP telephone calls, emergency calls to 9-1-1 through your VoIP service will be handled differently than traditional phone service. The following provisions describe the differences and limitations of 9-1-1 emergency calls, and you hereby acknowledge and understand the differences between traditional 9-1-1 service and VoIP calls with respect to 9-1-1 calls placed to emergency services from your account as described below.
Placing 9-1-1 calls: When you make a 9-1-1 emergency call, the VoIP service will attempt to automatically route your 9-1-1 call through a third-party service provider to the Public Safety Answering Point (“PSAP”) corresponding to your address of record on your account. However, due to the limitations of the VoIP telephone services, your 9-1-1 call may be routed to a different location than that which would be used for traditional 9-1-1 dialling. For example, your call may be forwarded to a third-party specialized call centre that handles emergency calls. This call centre is different from the PSAP that would answer a traditional 9-1-1 call which has automatically generated your address information, and consequently, you may be required to provide your name, address, and telephone number to the call centre.
How your information is provided: The VoIP service will attempt to automatically provide the PSAP dispatcher or emergency service operator with the name, address and telephone number associated with your account. However, for technical reasons, the dispatcher receiving the call may not be able to capture or retain your name, phone number or physical location. Therefore, when making a 9-1-1 emergency call, you must immediately inform the dispatcher of your location (or the location of the emergency, if different). If you are unable to speak, the dispatcher may not be able to locate you if your location information is not up to date.
Correctness of information: You are responsible for providing, maintaining, and updating correct contact information (including name, residential address and telephone number) with your account. If you do not correctly identify the actual location where you are located, or if your account information has recently changed or has otherwise not been updated, 9-1-1 calls may be misdirected to an incorrect emergency response site.
Disconnections: You must not disconnect the 9-1-1 emergency call until told to do so by the dispatcher, as the dispatcher may not have your number or contact information. If you are inadvertently disconnected, you must call back immediately.
Connection time: For technical reasons, including network congestion, it is possible that a 9-1-1 emergency call will produce a busy signal or will take longer to connect when compared with traditional 9-1-1 calls.
9-1-1 calls may not function: For technical reasons, the functionality of 9-1-1 VoIP emergency calls may cease or be curtailed in various circumstances, including but not limited to:
Failure of service or your service access device—if your system access equipment fails or is not configured correctly, or if your VoIP service is not functioning correctly for any reason, including power outages, VoIP service outage, suspension or disconnection of your service due to billing issues, network or Internet congestion, or network or Internet outage in the event of a power, network or Internet outage; you may need to reset or reconfigure the system access equipment before being able to use the VoIP service, including for 9-1-1 emergency calls; and changing locations—if you move your system access equipment to a location other than that described in your account information or otherwise on record with (company name).
Alternate services: If you are not comfortable with the limitations of 9-1-1 emergency calls, (company name) recommends that you terminate the VoIP services or consider an alternate means for accessing traditional 9-1-1 emergency services.
Inform other users: You are responsible for notifying, and you agree to notify, any user or potential users of your VoIP services of the nature and limitations of 9-1-1 emergency calls on the VoIP services as described herein.
Liability: Customers are advised to review this section with respect to (company name)’s limitations of liability (as appropriate to each company).
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