Telecom Commission Letter Addressed to OnSwitch Inc.

Ottawa, 13 April 2017

Our references: 8663-C12-201015470 & 766372

BY EMAIL

OnSwitch Inc.
PO Box 25058
Keswick, ON  L4P 4C2
info@onswitchit.ca

Re: Request for information - Obligations of local VoIP service providers with respect to 9-1-1 emergency service and registration with the Commission

To whom it may concern:

The Canadian Radio-television and Telecommunications Commission (the Commission) regulates, among other things, the provision of 9-1-1 service by local Voice over Internet Protocol (VoIP) service providers pursuant to the Telecommunications Act (the Act).

The Commission received a complaint on 17 March 2017Footnote1 claiming that OnSwitch Inc. (OnSwitch) was offering VoIP service without proper approval and without offering a 9-1-1 emergency service. In addition, Commission staff noted in early April that on its website, OnSwitch stated that "OnSwitch Cloud Phone does not provide emergency/911 services, and should not be used as a replacement landline or mobile access to emergency assistance services. Calls to emergency services from an OnSwitch Cloud Phone device will not be connected." The OnSwitch website has since then been revised to indicate that E9-1-1 services are provided as part of the company’s Cloud Phone service.

In light of the importance of 9-1-1 emergency service to the Canadian public, the Commission is working to ensure that local VoIP service providers in Canada adhere to their obligations related to the provision of 9-1-1 service.

The emergency service obligations for local VoIP service providers in Canada are set out in Telecom Decision CRTC 2005-21, Emergency service obligations for local VoIP service providers and Telecom Decision CRTC 2005-61, Follow-up to Emergency service obligations for local VoIP service providers, Decision 2005-21- Customer notification requirements.

There are three obligations major which local VoIP service providers in Canada must meet:

  1. Provide 9-1-1 service to the company’s customers.
  2. Provide information to customers explaining the limitations of and/or differences between VoIP 9-1-1 and traditional 9-1-1, and obtain from customers express consent to such limitations.
    1. Register with the Commission as a reseller (or as a Competitive Local Exchange Carrier (CLEC) if the company owns or operates facilities in Canada), and
    2. Obtain a BITS licence (Basic International Telecommunications Services licence) from the Commission.
    For queries on these registration matters please call 866-845-6036 or write cd-dc@crtc.gc.ca

If OnSwitch is providing VoIP service, you must provide information to the Commission demonstrating that your company is in compliance with these obligations. The details of the obligations, and what is required to be submitted to the Commission, are on the following link: http://www.crtc.gc.ca/eng/telephone8.htm. Follow the Service Provider Obligations link, and click on Reseller if your company is not a facilities-based carrier: The information to be submitted is set out in the section titled: Attachment 1 to your letter to the Commission.

If your company is a telecommunications common carrier (owns or operates its own facilities), such as a CLEC, there are additional non-9-1-1 related obligations that also have to be met. The link above has a section on Carriers.

If you would like to see a sample of abridgedFootnote2 documents that other companies have submitted, please check here: http://www.crtc.gc.ca/PartVII/eng/2010/8663/c12_201015470.htm.

You are requested to provide a response to the Commission by 04 May 2017, showing that your company meets the three obligations listed above. The letter should be addressed to the Commission’s Secretary General with the subject and file numbers indicated at the top of this letter, to ensure proper routing of your document. If you have already provided the required information to the Commission, please provide the date and original company name for which the registration was submitted.

If OnSwitch is not a VoIP service provider and does not intend to offer this service in the near future, please confirm this by email to wendy.mcclintock@crtc.gc.ca by the above-noted date so that the Commission’s registration records can be updated to reflect that there is no requirement for OnSwitch to meet the VoIP 9-1-1 obligations.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications sector

c.c.: Wendy McClintock, CRTC, 819-639-6211, wendy.mcclintock@crtc.gc.ca

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