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Ottawa, 4 October 2013

Our reference: 8740-T69-201313106

BY EMAIL

Michelle Duguay
Senior Regulatory Advisor – Tariffs
Telecommunications Policy and Regulatory
TELUS Communications Company
9 Jules-A-Brillant Street, R 0901
Rimouski, Quebec G5L 7E4
michelle.duguay@telus.com

Re: Tariff Notice 599 – Zero dialed emergency call routing service (0-ECRS)

Dear Madam:

On 27 September 2013, the Commission received an application submitted by TELUS Communications Company (TCC or the Company) as part of Tariff Notice No. 599 (TN 599). It is a competitive tariff-type application, and the Company proposes an effective date of
29 October 2013.

The company proposed to add an amendment to the emergency services tariff provided to CLECs to specify that in accordance with Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points, Telecom Decisions CRTC 2007-44, 15 June 2007, the CLEC is directed to use 0-ECRS as the solution to fixed/non-native and nomadic VoIP
9-1-1 solution to call public safety answering points (PSAPs) calls.

Paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure provides that the Commission may require the parties to provide the information or documents that it considers necessary.

Staff notes that in TD 2007-44, the Commission determined that zero-dialed emergency call routing service (0-ECRS) is the only available 9-1-1 call routing method on the record that is functionally comparable to basic 9-1-1 service.

Further, the Commission directed all Canadian carriers offering local VoIP service to use 0-ECRS as the interim solution to route fixed/non-native and nomadic VoIP 9-1-1 calls to the
PSAPs, pending the development and implementation of a long-term fixed/non-native and nomadic VoIP 9-1-1 solution. The carriers are to implement this interim solution within
30 days of the date of this Decision.

Thus, TCC was required to implement this interim solution within 30 days of the date of TD 2007-44. Consequently, the Company is requested to:
1- provide clarifications on the implementation of the zero-dialed emergency call routing service (0-ECRS) since the date of issue of TD 2007-44; and
2- explain the delay of over six years to add the amendment to its emergency services tariff.

The Company is required to submit its responses to the above questions by 15 October 2013 at the latest.

Yours sincerely,

Original signed by

Michel Murray
Director, Regulatory implementation
Telecommunications

c.c.: Imen Arfaoui, CRTC, 819-997-4663, imen.arfaoui@crtc.gc.ca

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