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Ottawa, 24 October 2011
File No.: 8663-C12-201015470
BY E-MAIL
Mr. Regan Kerry
Chief Technology Officer
Epik Networks Inc. (IP Conex Inc.)
2 Bloor Street West
Suite 2004
Toronto, Ontario
M4W 3E2
regan@epiknetworks.com
Re: Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller
Dear Mr. Kerry:
On 27 September 2011, Epik Networks Inc. (Epik Networks) submitted its proposed customer notification texts with respect to its local VoIP 9-1-1 emergency service. Commission staff has reviewed the proposed texts and considers that, in order for staff to continue to evaluate compliance with the directives of Telecom Decision 2005-21[1] and Telecom Decision 2005-61[2], Epik Networks is required to:
1. make the following revisions:
a) clarify in the texts, the difference between traditional 9-1-1 and VoIP 9-1-1 emergency calling with respect to the 9-1-1 call routing. Note that with VoIP 9-1-1, calls are forwarded to a third party service provider before routing the call, either automatically or manually, to the Public Safety Answering Point (PSAP);
b) reflect in the texts that customers must ensure that they understand the difference between VoIP 9-1-1 and traditional 9-1-1 emergency calling;
c) reflect in the texts that customers are not to hang up during a 9-1-1 call until told to do so, and to call back if the call gets disconnected;
d) reflect in the texts 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; and
e) reflect in the texts that customers must inform users and potential users of the nature and limitations of VoIP 9-1-1 emergency calling.
2. provide:
a) copy of the telephone set warning sticker, or the texts that would appear on the sticker, which indicates that, in addition to where to find additional information regarding VoIP 9-1-1, when dialing 9-1-1 the customer must be prepared to provide their present address/location;
b) verification of an online link to the company’s 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
c) confirmation that Epik Networks intends to make available its proposed customer notification texts as per paragraphs 93 and 94 of Telecom Decision 2005-21[3].
Accordingly, Epik Networks is to submit the above-noted requirements for Commission review, no later than 15 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 and registration as a reseller”. The letter should 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:
John Traversy
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
Telecommunications
cc: C. Abbott, CRTC (819) 997-4509
[1] In Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Telecom Decision 2005-21), the Commission mandated that all local VoIP service providers are required to provide 9-1-1 service.
[2] 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.
[3] In Telecom Decision 2005-21, paragraph 93, the Commission directed all Canadian carriers offering local VoIP services to provide initial customer notification, regarding any limitations that may exist with respect to 9-1-1/E9-1-1 service, before service commencement. This information is to be made available through all of the following: marketing material used for television, radio and printed media, the terms and conditions of service, on-line material, customer service representatives, service contracts and starter kits.
In paragraph 94, the Commission further directed all Canadian carriers offering local VoIP service to provide on-going customer notification during service provision through all of the following: marketing material used for television, radio and printed media, the terms and conditions of service, on-line material, customer service representatives, warning stickers affixed to telephone sets and billing inserts.
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