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Ottawa, October 23, 2012

Our reference:  8340-C172-201209560

BY EMAIL

Mr. Yuval Barzakay
President
Comwave Networks Inc.
61 Wildcat Road
Toronto, Ontario  M3J 2P5
ybarzakay@comwave.net

RE:  Interconnection Agreement for the Provision of 9-1-1 Service to a Competitive Local Exchange Carrier between Comwave Networks Inc. and Bell Canada

Dear Mr. Barzakay:

On 7 August 2012, the Commission received a letter from Comwave Networks Inc. (Comwave), with an attached agreement between Comwave and Bell Canada titled Interconnection Agreement for the Provision of 9-1-1 Service to a Competitive Local Exchange Carrier. The CLEC 9-1-1 Agreement is dated 12 June 2012.

Commission staff notes that pursuant to section 29 of the Telecommunication Act (the Act) such agreements require the Commission’s approval before coming into effect.

In Bell Aliant Regional Communications, Limited Partnership and Bell Canada – Revised Interconnection Agreement for the Provision of 9-1-1 Service to a Competitive Local Exchange Carrier, Telecom Decision CRTC 2011-213, 25 March 2011 (Telecom Decision 2011-213), the Commission approved a revised CLEC 9-1-1 Agreement for Bell Aliant Regional Communications, Limited Partnership and Bell Canada (collectively, the Bell companies).

The revised CLEC 9-1-1 Agreement for the Bell companies reflects a previous Commission decision that directed the Bell companies to amend their CLEC 9-1-1 Agreement to (a) provide that the costs of any third-party audit are to be shared equally between the Bell companies and the CLEC, and (b) clarify that CLECs shall report either the number of network access services (NAS) or the number of working telephone numbers (WTNs) for their end-customers for billing purposes in accordance with the way that the Bell companies’ own retail customers are billed for 9-1-1 service.

Commission staff notes that the agreement filed by Comwave is based on an agreement that was in effect prior to the issuance of Telecom Decision 2011-213 and does not reflect the latest CLEC 9-1-1 agreement approved for the Bell companies.

Because the attached CLEC 9-1-1 agreement does not conform to the approved revised CLEC 9‑1-1 agreement for the Bell companies, this file is closed.

Comwave may submit a new application for the Commission’s approval addressing the above-mentioned concerns. The application must be presented in the form of a new agreement.

Yours sincerely,

Original signed by

Michel Murray
Director, Regulatory Implementation
Telecommunications

c.c.:  Joseph Cabrera, CRTC, (819) 934-6352, joseph.cabrera@crtc.gc.ca

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