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ARCHIVED - Telecom Commission Letter addressed to Mr. Philippe Gauvin (Bell Canada)

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Ottawa, 17 March 2016

Our reference: 8740-B2-201512757

BY EMAIL

Mr. Philippe Gauvin
Senior Legal Counsel
Floor 19, 160 Elgin Street
Ottawa, Ontario, K2P 2C4
bell.regulatory@bell.ca

RE: Bell Canada Tariff Notice 7480 request for information

Dear Mr. Gauvin:

On 10 November 2015, the Commission received an application from Bell Canada proposing changes to its Special Facilities Tariff (SFT) Item G21 – Wireless Service Provider (WSP) Enhanced 9-1-1 (E9-1-1) Service in order to revise the rate for the In-Call Location Update (ICLU) feature for wireless 9-1-1 service.
Bell Canada is to provide responses to the attached interrogatories by 20 April 2016. Parties may file comments on Bell Canada’s responses to interrogatories by 29 April 2016 and Bell Canada may file reply comments by 11 May 2016.

Interrogatory responses and any reply are to be served on all parties to this application by the specified dates. Where a document is to be filed or served by a specific date the document must be received, not merely sent.  Copies of the document should also be sent to nat.natraj@crtc.gc.ca

Sincerely,

Original signed by Tom Vilmansen for

Lyne Renaud
Director, Competitors Service and Costing Implementation
Telecommunications Sector
c.c.: B. Natraj (Nat Natraj), CRTC, 819-953-5081 nat.natraj@crtc.gc.ca
dennis.beland@quebecor.com, regaffairs@quebecor.com
RCI.regulatory@rci.rogers.com Attention: Simon-Pierre Oliver

Attach.

  1. Refer to Paragraphs 6 and 20 to 32 of the company’s 10 November 2015 Economic Evaluation Report (the Report) and paragraph 3 of the company’s reply comments dated 21 January 2016 where the company identifies the work done for Public Service Answering Points (PSAPs).
    1. Provide a breakdown of the major activities and associated costs for the work done. Also provide a brief description of all major activities.
    2. Provide the present worth of annualized costs (PWAC) associated with the work done for PSAPs included in the cost study.
    3. With respect to the major activities and associated costs provided in response to a) above confirm whether these activities would benefit any of the services referred to in Bell Canada’s General Tariff item 1400 9-1-1 PUBLIC EMERGENCY REPORTING SERVICE (PERS).
    4. Refer to paragraph 12 of Order CRTC 2000-430 which states that “the Commission considers that the PSAP hardware and software and PSAP maintenance costs should not be recovered through the 9-1-1 rate”. 

    In view of this determination, explain why the company proposes that the cost associated with the work done for the PSAPs should be recovered from the ICLU rate and how this complies with the Commission’s determination.

  2. With respect to the data connections to a PSAP providing Enhanced 9-1-1 service which have been modified to Internet Protocol (IP) components such as IP Virtual Private Network (VPN) circuits and CE routers (referred to as “IP 9-1-1 data network”): 
    1. Provide the list of services (from those referred to in Bell Canada’s General Tariff item 1400, 9-1-1 PERS in the company’s General Tariff) that currently use the IP 9-1-1 data network.
    2. Provide the date (month and year) when IP 9-1-1 data networks was first implemented to transmit 9-1-1 data traffic to PSAPs.
    3. Will the IP 9-1-1 data networks be used to provide Text with 9-1-1 service, where the service is available?
    4. Could these IP 9-1-1 data networks be used to provide Next Generation 9-1-1 (NG 9-1-1) services?
      1. Will the IP 9-1-1 data networks be used to transmit NG9-1-1 caller information to PSAPs when this NG9-1-1 capability is implemented?
      2. Will the IP 9-1-1 data networks be used to transmit NG9-1-1 voice calls to PSAPs when this NG9-1-1 capability is implemented?
  3. Refer to paragraphs 20 to 32 of the company’s 10 November 2015 Report and paragraph 3 of reply comments dated 21 January 2016, where details of the activities associated with the IP 9-1-1 data networks are described.
      • Provide the breakdown of the major activities and the associated costs for the implementation of the PSAP IP 9-1-1 data network. Also provide a brief description of all major activities.
      • Provide the present worth of annualized costs (PWAC) associated with the implementation of IP 9-1-1 data networks (e.g. IP VPN circuits to PSAP and CE routers) included in the cost study.
    1. Refer to paragraph 5 of company’s reply comments dated 21 January 2016 where the company submitted that it would not have undertaken to implement any network modifications to the 9-1-1 network had the Commission not required the implementation of the ICLU feature.
        1. Indicate when (what date) the x.25 circuits used for 9-1-1 data connections with PSAPs were implemented, and indicate whether Bell Canada recovered these costs from Bell Canada’s General Tariff item 1400 9-1-1 PERS, or from any other tariff.  If the costs were recovered from another tariff, provide the tariff name and item number.
        2. List the services referred to in Bell Canada’s General Tariff item 1400 9-1-1 PERS tariff which  used the x.25 data connections to provide 9-1-1 access to subscribers of those services
        3. Did Bell Canada have a 9-1-1 modernization plan to:
          • Replace the 9-1-1 data connections (x.25 circuits) with PSAPs with 9-1-1 data networks?  If yes, indicate when (what date) this 9-1-1 modernization plan was first developed and the timeline and date (month and year) the company had initially planned to complete the modernization to IP 9-1-1 data connections with PSAPs. If not, explain how long the x.25 circuits are expected to continue to provide service.
          • Migrate its current ALI systems to an IP-enabled ERS platform to provide 9-1-1 services? If yes, indicate when (what date) this 9-1-1 modernization plan was first developed and the timeline and date (month and year) the company had initially planned to complete the ERS platform.  If not, explain how long the current ALI systems are expected to continue to provide service.
        4. In view of the company’s position that it would not have undertaken to implement any network modifications to the 9-1-1 network had the Commission not required the implementation of the ICLU feature:

        Confirm whether the company would have made these network modifications, in the future, to modernize the 9-1-1 network. If so provide the expected date (month and year) for making each of these network modifications. If not, explain why not with supporting rationale.

      1. Refer to paragraph 5 of the company’s reply comments dated 21 January 2016 where the company submitted that it had to migrate the existing ALI system to the IP-enabled ERS platform to support the provisioning of the ICLU feature:
        1. Provide a breakdown of the major activities and associated costs to migrate the existing ALI system to IP-enabled ERS platform. Also provide a brief description of all major activities.
        2. Provide the present worth of annualized costs (PWAC) associated with the implementation of the IP-enabled ERS platform included in the cost study.
        3. Provide a complete list of the services (referred to in Bell Canada’s General Tariff item 1400,     9-1-1 PERS that use the ERS platform in an area where the PSAP provides Enhanced 9-1-1.
        4. Provide the date (Month and Year) when the ERS platform was first implemented to provide live 9-1-1 calls.
        5. Indicate the date (Month and Year) when the ALI functionality managed by the ERS platform was put into production to handle live 9-1-1 calls, and indicate if Bell Canada recovers the costs to provide the ALI functionality from Bell Canada’s General Tariff item 1400 9-1-1 PERS or any other tariff.  If from another tariff, provide the tariff name and item number.
        6. Confirm whether the company submitted any application to the Commission (e.g. tariff notice or Part 1 application) seeking approval to change any of its tariffed 9-1-1 rates in Bell Canada’s General Tariff item 1400 9-1-1 PERS in relation to the implementation of the ERS platform prior to or within 6 months after the ERS platform was implemented to provide live 9-1-1 calls.
          • If so, provide the application number, date, and a list of services in Bell Canada’s 9-1-1 PERS tariff that the application pertained too.
          • If not, explain with supporting rationale why Bell Canada at the time did not submit an application to the Commission.
      2. Explain, with supporting rationale, the appropriateness of recovering 9-1-1 modernization costs (i.e. IP VPN circuits , CE routers, and IP enabled Emergency Report System (ERS) platform and costs associated with work done for PSAPs), which will benefit all subscribers of 9-1-1 services, from:
        1. The subscribers of ICLU service, as proposed by the company.
        2. All subscribers of 9-1-1 service (i.e. to whom the 9-1-1 rate identified in item 1400 9-1-1 PUBLIC EMERGENCY REPORTING SERVICE (PERS) in Bell Canada’s General Tariff is charged).
      3. Using the format of Tables 1 to 7 in Appendix 1 of the company’s Report dated 10 November 2015, provide revised proposed ICLU costs and rates for each of the following changes in assumptions:
        1. Exclude  the following costs:
          •  Costs associated with the work done for PSAPs provided in response to 1 b)
          • Costs associated with the implementation of IP 9-1-1 data networks provided in response to 3 b)
          • Costs associated with the implementation of the IP-enabled ERS platform provided in 5 b)
    1. Exclude all the costs identified in 7i) above but include only the costs of advancement associated with these costs.  To calculate the cost of advancement associated with these costs use the date these network modifications would have been made in the future as provided in response to 4 d).  Also, provide a step-by-step calculation of how the cost of advancement has been estimated. Comment on the appropriateness of this change in assumptions.

Provincial 9-1-1 service approved for Island Telecom Inc., Order CRTC 2000-430, 24 May 2000

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