ARCHIVED - Telecom Commission letter adressed to distribution list

Ottawa, 1 April 2016

Our reference: 8638-C12-201600669

BY EMAIL

Distribution List

Re: Notice of 9-1-1 obligations, pursuant to Telecom Regulatory Policy 2016-12

The purpose of this letter is to remind non-carriers that provide telecommunications services (otherwise known as resellers) of their obligations with regard to providing 9-1-1 services.

Effective access to emergency services is critical to the health and safety of citizens, and is an important part of ensuring that Canadians have access to a world-class communication system.  Over the years, the Canadian Radio-television and Telecommunications Commission (Commission) has established policies to contribute to the availability of reliable and effective access to 9-1-1 services in Canada.

Recently, in Application of the 9-1-1 regulatory obligations directly to non-carriers offering and providing telecommunications services, Telecom Regulatory Policy CRTC 2016-12, 14 January 2016 (TRP 2016-12), the Commission listed the main 9-1-1 obligations applicable to resellers (See the Appendix to this letter) and implemented some policy changes to enhance the regulatory obligations that require that Canadians have access to reliable and effective 9-1-1 service.

The Commission directed all resellers, as a condition of providing local exchange telephone service, wireless voice telephone service, local voice over Internet Protocol (VoIP) telephone service, or payphone services, to abide by all existing and future obligations with respect to 9-1-1 service.

Further, the Commission required both underlying carriers and resellers that provide any telecommunications service to another reseller to include in their service contracts or other arrangements with those resellers the requirement that the latter must abide by all existing and future obligations with respect to 9-1-1 service.  Underlying carriers and all resellers are required to report to the Commission in a timely manner whenever a reseller that it provides service to does not comply or is suspected to not be complying with the 9-1-1 obligations.  

Non-compliance is to be reported by letter to the Secretary General using the file number provided above. Such letters are to include the name and contact information of the reseller, as well as any details regarding the alleged non-compliant behaviour. A reseller found to be in non-compliance with its obligations will be expected to implement any remedial directions from the Commission.

You are reminded that the Commission has the power to impose direct orders and penalties on all telecommunications service providers, including resellers, that fail to comply with the 9-1-1 obligations.^{Footnote 1} This includes failing to provide 9-1-1 service and comply with any related obligations (such as informing customers about limitations associated with 9-1-1 service) or to inform the Commission of a reseller that is failing or suspected to be failing to comply with the
9-1-1 obligations.

A reliable and effective 9-1-1 service is essential to protecting the safety of Canadians, and your organization is an important piece of that service.  The Commission is committed to working with your organization to ensure that Canadians that subscribe to your telecommunications services have access to reliable and effective 9-1-1 service.  If you have any questions with regard to your 9-1-1 obligations and how your organization can comply with them, please do not hesitate to contact me for assistance at michel.murray@crtc.gc.ca or at 819-997-9300.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  All non-carriers registered with the Commission

Appendix (1)

The text below is reproduced from Telecom Regulatory Policy 2016-12

Main 9-1-1 obligations applicable to non-carriers

Any person offering or providing the following telecommunications services who is not a Canadian carrier must provide 9-1-1services to its end-customers where a local Public Safety Answering Point (PSAP) has been established, and must abide by the obligations listed below. The 9-1-1services must be the same as those provided by the PSAP (e.g. Enhanced 9-1-1 (E9-1-1) or, where that is not available, Basic 9-1-1), except as noted below. The source of each obligation is also provided.

Local exchange telephone services

• Provide 9-1-1 service to end-customers (see paragraph 286 of Telecom Decision 97-8).
• Ensure, to the extent technically feasible, that the appropriate end-user information is provided to the Automatic Location Identification (ALI) database to the same extent as that provided by the incumbent local exchange carrier (ILEC) [see paragraph 286 of Telecom Decision 97-8].
• Provide customers with information about 9-1-1 service, including customer charges, if any, before contracting for service (see paragraph 293 of Telecom Decision 97-8).

Wireless voice telephone services

• Provide wireless E9-1-1 service to subscribers in communities where wireless E9-1-1 network access service is available from an ILEC (see paragraph 94 of Telecom Decision 2003-53).
• Establish and maintain toll-free telephone access to and continuous staffing of at least one operation centre, in order to promptly assist authorized PSAP personnel seeking subscriber information in emergency situations (see paragraph 94 of Telecom Decision 2003-53).
• Provide subscribers with initial and periodic notification of the availability, characteristics, and limitations of the 9-1-1 service offered (see paragraph 94 of Telecom Decision 2003-53).
• Adhere to the standard format of non-dialable callback numbers for particular call types that could be delivered to PSAPs (see paragraph 1 of Telecom Decision 2011-177).
• Make changes in networks, systems, and processes required to support the provision of Text Messaging with 9-1-1 (T9-1-1) service for hearing- or speech-impaired persons, with the expectation that the service will immediately be made available to hearing- or speech-impaired persons in a particular area when all T9-1-1 stakeholders (wireless carriers, ILECs, and PSAPs) are ready to support the T9-1-1 service in that area (see the summary and paragraph 16 of Telecom Decision 2013-22).

Local VoIP telephone services

• Provide 9-1-1/E9-1-1 service, where it is available from the ILEC (see paragraph 52 of Telecom Decision 2005-21).

Fixed/native^{Footnote 2} local VoIP telephone services

• Provide 9-1-1/E9-1-1 service, where it is available from the ILEC, which is to include provisioning end-user information in the ALI database associated with the end-user’s serving PSAP, and routing 9-1-1 calls, along with automatic number identification (ANI) and ALI data, to the correct PSAP in a manner that is compatible with the PSAP’s systems. Call control features are to be supported to the extent technically feasible (see paragraph 52 of Telecom Decision 2005-21).

Fixed/non-native^{Footnote 3} and nomadic^{Footnote 4} local VoIP telephone services

• Implement an interim solution that provides a level of 9-1-1 service, in areas where 9-1-1/E9-1-1 service is available from the ILEC, that is functionally comparable to Basic 9-1-1 service (see paragraph 68 of Telecom Decision 2005-21).
• The interim solution must connect an emergency call to an intermediary, which in turn transfers the call to the proper PSAP or emergency services agency (see paragraph 61 of Telecom Decision 2005-21). As well, this solution must ensure that a 9-1-1call originating from a local VoIP service is not routed to a PSAP that does not serve the geographic location from which the call is placed (see paragraph 68 of Telecom Decision 2005-21).
• Regarding the determination of the caller’s location using nomadic local VoIP service,
  • the primary means of identifying the location of a 9-1-1 caller is by verbally determining the caller’s location;
  • if a 9-1-1 call is disconnected before the operator can verbally determine a caller’s location, the operator must attempt to call back in order to determine the caller’s location; and
  • the registered service address should be used only when the 9-1-1 caller cannot communicate his or her location or when a 9-1-1 call is disconnected before the 9-1-1 caller’s location can be determined, and the operator cannot re-establish contact with the caller (see paragraph 10 of Telecom Circular 2008-2).
• Implement the capability to provide VoIP service provider (VSP) operators with a 9-1-1 caller’s telephone number, and require VSP operators to use the provided telephone number as a last resort to re-establish contact with a 9-1-1 caller, when a 9-1-1call is disconnected before the caller’s location has been determined (see paragraph 17 of Telecom Regulatory Policy 2011-426).
• Use zero-dialed emergency call routing service 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 E9-1-1 solution (see paragraph 60 of Telecom Decision 2007-44).
• Contact customers each time billing address changes are made to confirm the most likely physical address for emergency purposes, and ensure that customers are able to update their most likely physical address online (see paragraph 45 of Telecom Decision 2010-387).
• 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 addition, 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 (see paragraphs 93 and 94 of Telecom Decision 2005-21).
• Submit to the Commission proposed texts for customer notifications, which must adhere to the requirements set out in Telecom Decision 2005-61 (see paragraph 15 of Telecom Decision 2005-61).
• In cases where there are limitations on VoIP 9-1-1/E9-1-1 service, obtain, prior to commencement of service, the customer’s express consent, by which the customer acknowledges his/her understanding of the 9-1-1/E9-1-1 service limitations, using one of the methods approved in Telecom Decision 2005-15 (see paragraph 98 of Telecom Decision 2005-21).
• Provide all customer notification and any printed information used to secure express customer consent in alternative formats (e.g. Braille and large print) upon request. Furthermore, explain all customer notification and printed information to customers upon request (see paragraph 98 of Telecom Decision 2005-21).

Payphone services

• Provide coinless and cardless access to 9-1-1, or access to emergency call routing by an operator accessed by dialing 0 at a pay telephone (see heading xi(a) of Telecom Decision 98-8).
• Where required by civic authorities, provide a list of detailed pay telephone locations to the enhanced 9-1-1 administrator (see heading xi(a) of Telecom Decision 98-8).

Date modified:

2016-04-01