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Ottawa, 22 November 2011
File No.: 8663-C12-201015470
BY E-MAIL
Mr. Dennis Peng
Vice President of Product Management
Ooma Inc.
1840 Embarcadero Road
Palo Alto, California
U.S.A.
94303
dennis.peng@ooma.com
Re: Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration as a reseller
Dear Mr. Peng:
Commission staff understands that Ooma Inc. (Ooma) has recently expanded its home phone service to Canada and may be providing local voice over Internet Protocol (VoIP) services.
Pursuant to Telecom Decision 2005-21[1], local VoIP service providers are required to provide 9-1-1 service. In addition, pursuant to Telecom Decision 2005-61[2], local VoIP service providers are required to submit to the Commission their proposed customer notification texts, prior to use, for Commission review.
Commission staff notes that it has reviewed the 9-1-1 customer notification texts the company has posted on its website. Commission staff considers that in order to comply with the directives of Telecom Decision 2005-21 and Telecom Decision 2005-61, Ooma is required to:
a) confirm, notwithstanding that Ooma has 9-1-1 customer notification texts posted on its website, that 9-1-1 is in fact being provided to its customers, pursuant to Telecom Decision 2002-21, and if not, to provide a detailed plan and time table for the provision of 9-1-1 service to customers;
b) provide the name of the 9-1-1 answering bureau that Ooma employs, as well as the local exchange carrier or reseller from which the company obtains its telephone numbers and other services that enable it to offer VoIP services. Contact names, telephone numbers, and email addresses are to be provided for each company identified;
c) provide a copy of the telephone set warning sticker, or the texts that would appear on the sticker, which indicate 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; and
d) confirm that the company intends to make available its customer notification texts through all of the remaining information sources, as per paragraphs 93 and 94 of Telecom Decision 2005-21[3].
Accordingly, Ooma is to submit responses to 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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