ARCHIVED - Letter

VIA EMAIL

Mr. Ted Woodhead
Vice- President
Telecom Policy & Regulatory Affaires
Floor 8, 215 Slater Street
Ottawa, ON   K1P 0A6
Regulatory.affairs@telus.com

Dear Mr Woodhead,

Re:  Request by TELUS Communications Company for Clarification of Telecom Decision CRTC 2010-387 and Telecom Decision CRTC 2001-72

This letter is in response  to TELUS Communications Company’s (TELUS) letter dated
2 March  2011 regarding several matters in Telecom Decision CRTC 2010-387 (Decision 2010-387) and Telecom Decision CRTC 2011-72 (Decision 2011-72), which dealt with determining the call location of Nomadic and Fixed non-native VoIP customers when they place 9-1-1 emergency calls.  TELUS raised concerns about the applicability of the Commission’s determinations to business VoIP customers, and suggested that the CRTC Interconnection Steering Committee Emergency Services Working Group (CISC ESWG) should examine the ability of these customers to update their current location for use by public service answering points.  TELUS also raised concerns about the subscriber location information database implementation timeframes as set out in the decisions.

Commission staff notes that Decisions 2010-387 and 2011-72 were the result of public proceedings in which TELUS and other interested parties provided comments, which were considered by the Commission in making its determinations.  Commission staff notes that TELUS, in its letter, has provided the same arguments it and/or other parties submitted in support of Bell Canada’s position in the review and vary proceeding of Decision 2010-387. In the resulting decision (Decision 2011-72) from the review and vary proceeding, the Commission confirmed that the directives in Telecom Decision 2010-387 do apply to both residential and business customer of VoIP service providers.

In regards to TELUS’ submission that the Commission request the CISC ESWG to review the requirements set out in its Decisions, Commission staff notes that CISC ESWG is not the appropriate forum to review or discuss policy issues.  Further the policy matters have already been dealt with by the Commission in the two decisions noted above.  Therefore, Commission staff considers that this is not a matter that should be referred to CISC ESWG.

TELUS also requested that the Commission clarify whether business customers are to input, into the database, the physical location of the business or of the individual end-users (their employees).  Commission staff clarifies that the requirement is to update the end-user’s physical locations.  Whether the update is done by the business customer or the end-user is at the discretion of the business customer

In regards to TELUS’ request for an extension to the database implementation timeframe, Commission staff notes that in Decisions 2010-387, the Commission directed all service providers to implement the requirements by 15 September 2010.  In addition, Commission staff considers that TELUS, in its letter, has not provide substantive arguments as to why it has not and cannot meet the implementation timeframes.  Commission staff further considers that the matters being examined in Telecom Notice of Consultation CRTC 2011-73 do not prevent TELUS from implementing the requirements directed by the Commission in the above decisions.  Commission staff therefore considers that TELUS should implement the requirements set out in Decision 2010-387 forthwith.

Sincerely,

Original signed by

Mario Bertrand
Acting Director General, Competition, Costing and Tariffs
Telecom

CC: Bell Canada
MTS Allstream

Ontario 9-1-1 Advisory Board (OAB),
Alberta E9-1-1 Advisory Association
Association of 911 Service Providers of BC

Date modified:

2011-03-22