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Ottawa, 23 March 2012

File No.:  8740-N51-201202738


Mr. Michel Gilbert
Director, Regulatory Affairs
NorthernTel, Limited Partnership
87 Ontario West
Montreal, Quebec
H2X 1Y8

RE:  Tariff Notice 332 – Implementation of wireless Phase II E9-1-1 Service

Dear Sir:

On 8 March 2012, the Commission received an application by NorthernTel, Limited Partnership (NorthernTel), under Tariff Notice 332 (TN 332), in which the company proposed to revise Section N390 of its General Tariff – Wireless Service Provider Enhanced 9-1-1 Service – to reflect Commission-mandated requirements specified in Implementation of wireless Phase II E9-1-1 service, Telecom Regulatory Policy CRTC 2009-40.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may request parties to file information or documents where needed.

NorthernTel is requested to provide comprehensive answers, including rationale and any supporting information, to the attached questions by 2 April 2012.

Yours sincerely,

‘Original signed by M. Murray for’

Suzanne Bédard
Senior Manager, Tariffs

cc:  Laurie Ventura, CRTC (819) 997-4589,


1.  NorthernTel has included the following paragraph as a proposed addition to its Wireless Service Provider Enhanced 9-1-1 Service tariff:

3.10     When facilities of other companies or telecommunications systems are used in establishing connections to or from customer-controlled facilities and equipment, NorthernTel is not liable for any act, omission or negligence of the other companies or telecommunications systems in relation to the provision of emergency services on a mandatory basis to the customer.

In Telecom Decision 2003-53, the Commission directed wireless carriers to include this limitation of liability provision in their end-user service contracts.  The Commission also noted that ILECs enjoy limitation of liability both for wireline E9-1-1 and wireless E9-1-1 network access services, pursuant to the ILEC-CLEC Interconnection Agreement and the WSP E9-1-1 Agreements, respectively.

NorthernTel is requested to explain why, as the ILEC providing this wholesale service to competitors, it has included this paragraph in its tariff when it is not required to do so.

2.  In its application, NorthernTel indicates that it is filing its additions and revisions pursuant to Commission-mandated requirements specified in Implementation of wireless Phase II E9-1-1 service, Telecom Regulatory Policy CRTC 2009-40, 2 February 2009. In that decision the Commission directed all wireless service providers to complete their respective implementation of wireless Phase II Stage 1 E9-1-1 service by 1 February 2010, wherever wireline E9-1-1 service is available across Canada.

Why is NorthenTel filing these proposed additions and revisions three years after the above-noted decision was issued?

3.  In paragraph 1.07, NorthernTel states “...The WSP Enhanced 9-1-1 Phase II Service is available to all wireless subscribers served by the Company’s 9-1-1 Network in Ontario and Québec. ...”

NorthernTel is requested to confirm that it provides this service in both Ontario and Québec.  If so, where in Québec does it provide the service?

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