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Ottawa, 20 December 2010
Our Reference: 8663-C12-201015470
Mr. Allen Stubbs
Stubbs Communications Inc.
397 Main Street
Dear Mr. Stubbs:
Re: Obligations of local VoIP service providers with respect to 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 are required to provide 9-1-1 service.
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 (Telecom Decision 2005-61), paragraphs 9 and 15, local VoIP service providers are required to submit to the Commission their proposed customer notification texts, prior to 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 November 2010, Stubbs Communications Inc. (Stubbs Communications) submitted its proposed customer notification texts with respect to its local VoIP 9-1-1 emergency service. Commission staff has reviewed the submission and considers that, in order for staff to evaluate compliance with the directives of Telecom Decision 2005-21 and Telecom Decision 2005-61, Stubbs Communications is required to:
a) confirm to the Commission that, as a VoIP provider, Stubbs Communications is currently providing 9-1-1 service;
b) provide the name, address and contact information of your third party VoIP 9-1-1 emergency call answering bureau;
c) provide copies of customer notification texts Stubbs Communications proposes to use for its instruction guide or starter kit, not only externally, but also inside the kit to reflect important 9-1-1 information/user tips;
d) provide copies of customer notification texts Stubbs Communications proposes to use for its marketing communications including television, radio and printed materials, and point of sale communications such as sales scripts;
e) reflect in the terms of service section under Liability, and also make reference to same in the user tips inside the starter kit, a full description of the company’s limitations of liability with respect to VoIP 9-1-1 emergency service;
f) provide a copy of the telephone set warning sticker, or the text that would appear on the sticker, which indicates to the customer that, when dialing 9-1-1 the customer must be prepared to provide their present address/location, and in addition to also note on the sticker that for more details, visit Stubbs Communications website (insert the company’s website name);
g) provide an online link to its terms of service and other important notification texts, related to VoIP 9-1-1, on each page of its website associated with local VoIP service; and
h) confirm to the Commission whether Stubbs Communications has requested to be registered with the Commission as a reseller, or if already registered to confirm the company name under which it has registered and the date of registration.
Accordingly, Stubbs Communications is to submit the above-noted information for Commission review, no later than 30 calendar days from the date of this letter.
The company’s letter is to indicate the reference number noted above with the subject title “Obligations of local VoIP service providers with respect to 9-1-1 emergency service”. The letter can be submitted using the online service at the Commission’s website (www.crtc.gc.ca) under the Telecommunications Sector link, by selecting the option «Submit a telecom-related document online» and further selecting the application type «other». Address your submission to:
Robert A. Morin
Canadian Radio-television and Telecommunications Commission
Should you have any questions regarding the information requested in this letter, please do not hesitate to contact us.
‘Original signed by S. Bédard’
Senior Manager, Tariffs
cc: C. Abbott, CRTC (819) 997-4509
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