ARCHIVED - Telecom Commission Letter Addressed to Stephen Schmidt (Telus Communications Company)

Ottawa, 28 September 2016

Our reference:  8663-C12-201015470

BY EMAIL

Mr. Stephen Schmidt
Vice-President - Telecom Policy & Chief Regulatory Legal Counsel
Telecom Policy & Regulatory Affairs
TELUS Communications Company
215 Slater Street, Floor 8
Ottawa, Ontario  K1P 0A6
regulatory.affairs@telus.com

RE: 9-1-1 calling using TELUS EXTEND service

Dear Mr. Schmidt:

In order to assist the Commission to determine whether the provision of the TELUS Extend service by TELUS Communications Company (TELUS) complies with Commission obligations concerning the provision of 9-1-1 service, TELUS is requested to respond to the following questions:

1. Provide a complete and detailed description of the TELUS Extend service, including a complete description of the call activation and routing functions.
2. How are potential customers informed of the TELUS Extend service?
3. Under what circumstances is the TELUS Extend service offered to subscribers?
4. When was the TELUS Extend service first offered to customers?
5. How many customers are currently subscribed to TELUS Extend, broken down by province and by residential subscribers and business subscribers?
6. What is the expected lifespan of the TELUS Extend service?
7. Explain whether TELUS Extend constitutes a nomadic local Voice over Internet Protocol (VoIP) service as defined by the Commission in Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005 (Telecom Decision 2005-21)? If TELUS Extend constitutes a nomadic local VoIP service,
8. Confirm whether TELUS Extend customers can place 9-1-1 voice calls using this service in the manner mandated by the Commission for nomadic VoIP services in Telecom Decision 2005-21 and subsequent decisions as identified in the attachment to this letter? If 9-1-1 service is not provided in the manner mandated for nomadic VoIP service, explain how 9-1-1- service is provided differently. If 9-1-1 service is not provided at all, explain why this obligation has not been met.
   1. As required by Follow-up to Emergency service obligations for local VoIP service providers, Decision 2005-21 - Customer notification requirements, Telecom Decision CRTC 2005-61, 4 April 2005,
      1. indicate whether, when, and how customers are being informed of any limitation concerning the provision of 9-1-1 service, and
      2. specify the notification that a customer would receive concerning the availability, characteristics, and limitations of the service.
   2. Explain how TELUS through its TELUS Extend service is meeting all other VoIP service providers’ obligations with respect to 9-1-1, as identified in the attachment to this letter.
9. If TELUS Extend does not constitute a nomadic local VoIP service, indicate why not and specify which alternate service category would apply and how any 9-1-1 obligations related to the service category in question are met?

The obligations that apply to local VoIP service providers, including the provision of nomadic VoIP service, are summarized in the attachment to this letter.

TELUS is to file its response to the questions by 11 October 2016.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  Jesslyn Mullaney, CRTC,819-953-5255, jesslyn.mullaney@crtc.gc.ca

Attach. (1)

Local VoIP service providers’ obligations

• All Local VoIP service providers must provide either Basic or Enhanced 9-1-1 service. (Emergency service obligations for local VoIP service providers, Telecom Decision CRTC 2005-21, 4 April 2005)
• Nomadic VoIP service providers and those who provide fixed VoIP service in a city where the area code of the telephone number provided belongs to another area code region (another city) must notify subscribers about the availability, characteristics and limitations of their 9-1-1 service when the service starts and at least once a year thereafter. Local VoIP service providers are to submit to the Commission their proposed customer notification texts, prior to their use, for Commission review. (Follow-up to Emergency service obligations for local VoIP service providers, Decision 2005-21 - Customer notification requirements, Telecom Decision CRTC 2005-61, 4 April 2005)
• Nomadic VoIP service providers must obtain express customer consent that the customer understands the limitations of their 9-1-1 service. (Telecom Decision 2005-21)
• All local VoIP providers must register with the Commission as a reseller if they do not own or operate their own transmission facilities, or as a Competitive Local Exchange Carrier if they do own and control those transmission facilities. (Regulatory framework for voice communication services using Internet Protocol, Telecom Decision 2005-28, 12 May 2005, paragraph 204)
• It is inappropriate for voice over Internet Protocol (VoIP) service providers to deliver 9-1-1 calls from their fixed/non-native and nomadic VoIP customers to public safety answering points (PSAPs) using low-priority telephone lines or restricted numbers. 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. (Routing of fixed/non-native and nomadic VoIP 9-1-1 calls to public safety answering points, Telecom Decision CRTC 2007-44, 15 June 2007)
• A summary of the emergency service obligations of nomadic local voice over Internet Protocol (VoIP) service providers related to determining the location of a 9-1-1 caller (Emergency service obligations of nomadic local VoIP service providers related to determining the location of a 9-1-1 caller, Telecom Circular CRTC 2008-2, 28 July 2008)
• Until next-generation 9-1-1 service is implemented, Nomadic and fixed/non-native VoIP carriers are to (1) contact customers each time they change their billing address to confirm their most likely physical address for emergency purposes; and (2) ensure that customers are able to update their most likely physical address online. (Viability of proposals for the provision of E9-1-1 service for nomadic and fixed/non-native VoIP subscribers, Telecom Decision CRTC 2010-387)
• Canadian carriers that offer Nomadic and fixed/non-native voice over Internet Protocol services are to implement the directives set out in Telecom Decision 2010-387. (Bell Aliant Regional Communications, Limited Partnership and Bell Canada – Application to review and vary Telecom Decision 2010-387 regarding the application of directives for 9-1-1 VoIP service, Telecom Decision CRTC 2011-72)
• Nomadic and fixed/non-native voice over Internet Protocol service providers are to provide their customers’ telephone numbers to their 9-1-1 operators. The operators are to use the numbers provided as a last resort to re-establish contact with a 9-1-1 caller when the call is disconnected before the caller’s location has been determined. (Provision of a 9-1-1 caller’s telephone number to nomadic and fixed/non-native VoIP service providers’ 9-1-1 operators, Telecom Regulatory Policy 2011-426, 14 July 2011)
• A modification to the contractual condition requires that local VoIP service providers, and any or all of their wholesale customers and subordinate wholesale customers, must comply with the 9-1-1 obligations applicable to local VoIP service providers. (VoIP 9-1-1 service – Modified contractual condition, Telecom Decision 2012-137, 7 March 2012)

Date modified:

2016-09-28