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Ottawa, 20 December 2010
Our Reference: 8663-C12-201015470
BY E-MAIL
Mr. Rishi Patel
Director – FlexTEL Practice
FlexITy Solutions Inc.
45 Vogell Rd, 8th Floor
Richmond Hill, Ontario
L4B 3P6
rishi.patel@flexity.ca
Dear Mr. Patel:
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 19 November 2010, FlexITy Solutions Inc. (FlexITy) filed 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, FlexITy is required to:
a) provide the name, address and contact information of your third party VoIP 9-1-1 emergency call answering bureau;
b) reflect in all related texts that the 9-1-1 caller must ensure that their contact information on file with FlexITy is always accurate and kept current;
c) with respect to alternate telephone service, reflect in the texts in the starter kits and also in the terms of service that if the customer is not comfortable with the limitations of VoIP 9-1-1 emergency calling, the company recommends that the customer keep an alternative telephone service, such as a cellular telephone phone, to ensure the reliability of 9-1-1 calling or consider terminating their VoIP service;
d) modify the text, where it says “you must also orally provide the operator with your address and telephone number”, to insert the word “current” before the word “address” and note in the text that this is necessary as the operator may not have this information;
e) provide a copy of FlexITy’s terms of service information related to its local VoIP 9-1-1 service;
f) provide copies of all customer notification texts FlexITy proposes to use for its marketing communications including television, radio and printed materials, and point of sale communications such as sales scripts; and
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.
Accordingly, FlexITy 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
Secretary General
Canadian Radio-television and Telecommunications Commission
Ottawa, Ontario
K1A 0N2
Should you have any questions regarding the information requested in this letter, please do not hesitate to contact us.
Yours sincerely,
‘Original signed by S. Bédard’
Suzanne Bédard
Senior Manager, Tariffs
Telecommunications
cc: C. Abbott, CRTC (819) 997-4509
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