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Our Reference: 8663-C12-201015470
Mr. Peter Sliwka
2 - 3415 Dixie Road, Suite 348
Dear Mr. Sliwka:
Re: Provision of 9-1-1 service to customers in Canada
Commission staff notes that on two occasions it has issued letters to Voipgo Corporation (Voipgo), the most recent being 18 October 2010, requiring the company to comply with the 9-1-1 obligations of local VoIP service providers and the obligation to register as a reseller. To date, a response has not been received from Voipgo.
In addition, it has come to the Commission’s attention through a customer complaint that Voipgo, which provides local VoIP services in Canada, is not providing 9-1-1 service to its Canadian customers. The complainant indicated that Voipgo had told him that it does not offer emergency calling at this time. The complainant also indicated that Voipgo had not provided any information about its lack of 9-1-1 services when the complainant initially received service from Voipgo, nor subsequently during service, and that Voipgo had not obtained express consent from the complainant that he understood the limitations of Voipgo’s 9-1-1 service.
Commission staff notes that Voipgo’s local VoIP services must provide access to 9-1-1 in Canada in case of an emergency. Commission staff considers that the absence of access to 9-1-1 by Voipgo’s Canadian local VoIP service customers is a very serious matter.
This matter is further aggravated by the lack of response by Voipgo to two letters from Commission staff, referenced above, that required Voipgo to comply with the Commission’s directives regarding 9-1-1 obligations of local VoIP service providers, as outlined in the letters and further summarized in the Attachment to this letter, or to confirm in writing should it not be a provider of local VoIP services.
Commission staff has checked Voipgo’s website for 9-1-1 emergency service customer notification texts. It appears the information provided in its Terms of Service, and its 9-1-1 Emergency page under Frequently Asked Questions, may be related only to customers in the United States. Voipgo has not provided any such information relative to its Canadian customers to the Commission for review in order to meet minimum requirements as mandated by the Commission.
Commission staff further notes that Voipgo has not registered as a reseller of telecommunications services as mandated by the Commission.
Accordingly, this letter requires Voipgo to:
1. Implement 9-1-1 service in Canada within 30 calendar days of the date of this letter, in accordance with the Commission’s requirements, and provide confirmation that it has done so. Otherwise the company is to provide justification, within 14 calendar days, as to why it cannot meet this date and is to provide an alternate date.
2. Provide to the Commission, within 14 calendar days:
a. A detailed 9-1-1 implementation plan, including information on network infrastructure, routing, and which 9-1-1 answering bureaus/third-party call centres it intends to use to provide 9-1-1 service, as well as implementation milestones;
b. The number of Voipgo Canadian customers to which the company does not provide 9-1-1 service;
c. Confirmation that, as a local VoIP service provider, Voipgo has requested to register with the Commission as a reseller of telecommunications services or, if already registered, identification of the name under which it has registered and the date of registration; and
d. Identification of local exchange carriers and/or local service providers currently providing Voipgo with network resources and Canadian telephone numbers to allow it to offer local VoIP service in Canada.
3. Provide to the Commission for review, within 30 calendar days, VoIP 9-1-1 emergency service customer notification texts adhering to minimum requirements as mandated by the Commission.
Should the company fail to abide by the directions set out in this letter, please be advised that the Commission may take further measures to enforce its regulations.
‘Original signed by L. Fancy’ (for)
Executive Director, Telecommunications
cc: C. Abbott, CRTC (819) 997-4509
The Commission has mandated that all local VoIP service providers must:
- Provide 9-1-1 service;
- 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 to the customer and to provide on-going customer notification during service provision;
- Obtain express consent from the customer by which the customer acknowledges his/her understanding of the 9-1-1/E9-1-1 limitations;
- Provide customer notification through all of the following:
- marketing material used for television, radio and printed media, on-line material, and starter kits;
- the terms and conditions of service;
- customer service representatives;
- warning stickers to be affixed to telephone sets; and
- billing inserts; and
- Submit to the Commission, for review, proposed customer notification texts.
 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. 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.
 Regulatory framework for voice communication services using Internet Protocol, Telecom Decision 2005-28, 12 May 2005.
 Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005.
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