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Ottawa, 4 November 2010

Our Ref.: 8663-C12-201015470


Mr. Dave Hogg
BCS Global Networks Inc.
5025 Orbitor Drive, Bldg. 5, Suite 300
Mississauga, Ontario
L4W 4Y5

Dear Mr. Hogg:

Re: Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller

Pursuant to paragraphs 9 and 15 of 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 (Telecom Decision 2005-61), local VoIP service providers are required to submit to the Commission their proposed customer notification texts, prior to their use, for Commission review.  The proposed texts must adhere to Emergency Services Working Group Consensus Report ESRE039D – Customer Notification Issues re: 9-1-1 Calls on VoIP, 21 July 2005 (the Report), and paragraphs 11 to 13 of Telecom Decision 2005-61.

On 22 June 2006, BCS Global Networks Inc. (BCS Global) filed its proposed customer notification texts regarding its 9-1-1 emergency service. In order to comply with the directives of Telecom Decision 2005-61, on 23 June 2006, Commission staff requested BCS Global to submit the following information and to make changes to its proposed customer notification texts:

a) provide a copy of its proposed telephone set warning sticker, or in the alternative, the text that will appear on the sticker;

b) provide copies of any text that would appear on the company’s web site and in promotional material, such as information in starter kits etc., and ensure all notification text clearly covers the first item of paragraphs 5 and 7 outlined in the Report to the CRTC which is attached to Telecom Decision 2005-61;

c) as the provisioning of 9-1-1 emergency service by local VoIP service providers is mandatory, pursuant to Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005, Commission staff considers that the second sentence of item #2 (Your 9-1-1 calls will be routed to a trained dispatcher), of the company’s submission, is inappropriate and thereby requires deletion;

d) reflect in item #3 (Emergency service responders will not automatically know your number or where you are located), of the company’s submission, that the customer must not disconnect the 9-1-1 call until told to do so by the emergency dispatcher, and should the call be inadvertently disconnected the customer must call back immediately; and

e) the company should also review the minimum requirements for customer notification of VoIP 9-1-1 service limitations, as set out in paragraph 8, Table 1, in the Report to the CRTC (TIF 39 Consensus Report) which is attached to Telecom Decision 2005-61, to ensure that it will be in compliance with respect to the specific form of customer communication being provided.

Commission staff notes that BCS Global has yet to submit the requested information or confirm that it has made the above-noted changes.

Accordingly, BCS Global is to submit the above-noted customer notification information with the requested changes for Commission review, no later than 14 calendar days from the date of this letter.  The company’s letter should indicate the file number noted above with the subject title “Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller”.

Commission staff further notes that upon a check of the reseller registration list, BCS Global does not appear to be registered with the Commission. Pursuant to 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).

BCS Global is therefore required to register with the Commission as a reseller no later than 14 calendar days for the date of this letter. Registration letters 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.

Your response can be submitted using the online service at the Commission’s website ( under the Telecommunications Sector link by selecting the option «Submit a telecom-related document online» and further selecting the appropriate application type. Submissions should be addressed to:

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

Should you have any questions regarding the above, please do not hesitate to contact us.

Yours sincerely,

‘Original signed by S. Bédard’

Suzanne Bédard
Senior Manager, Tariffs

cc: C. Abbott, CRTC (819) 997-4509

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