ARCHIVED - Telecom Commission Letter Addressed to Patrick Crotty (CBTS Canada Inc.)
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Ottawa, 20 July 2017
Our reference: 8663-C12-201015470
Mr. Patrick Crotty
CBTS Canada Inc.
55 King Street West, 7th floor
Kitchener, Ontario N2G 4W1
Re: Request for information - Obligations of local VoIP service providers with respect to 9-1-1 emergency service
Dear Mr. Crotty;
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).
A letter was recently sent to CBTS Canada Inc. regarding registration with the Commission as a telecommunications service provider.
As a follow-up to the above mentioned letter, and 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 application of 9-1-1 and other regulatory obligations directly to non-carriers (resellers) offering and providing telecommunications services is described in Telecom Regulatory Policy 2016-12Footnote 1 and Telecom Regulatory Policy 2017-11.Footnote 2 In TRP 2016-12, the Commission directed resellers, as a condition of offering and providing voice telecommunications services, to abide by all applicable existing and future obligations with respect to 9-1-1 service.In TRP 2017-11, the Commission directed resellers, as a condition of offering and providing any telecommunications services, to abide by all applicable existing consumer safeguard obligations, including the obligation to register with the Commission.
The emergency service obligations for local VoIP service providers in Canada are set out in Telecom Decision 2005-21Footnote 3 and Telecom Decision CRTC 2005-61Footnote 4.
If CBTS Canada Inc. provides VoIP service in Canada, it must provide information to the Commission demonstrating that it is in compliance with 9-1-1 obligations of local VoIP service. The details of the obligations, and what is required to be submitted to the Commission, are available from the following link: http://www.crtc.gc.ca/eng/telephone8.htm.
- If your company is not a facilities-based carrier, click on Service Provider Obligations, and then on VoIP Service Provider (Resellers). The information to be submitted is set out in the section titled: Attachment 1 to your letter to the Commission.
- In addition, a checklist that summarizes the information filing requirement from the above link is also set out in the Attachment to this letter.
As this file may be placed on the public record on the Commission’s website, it may be helpful for you to look at how companies file public versions of their letters and in some cases take measures to protect confidential and personal information. In effect, you could elect to file two versions of your reply. The confidential version that you would submit would include all of the information required by the Commission, with the confidential information designated as such; while the abridged version that you would also submit, to be published on our website, would be a copy of the confidential version, but with the sensitive information removed and replaced with the number sign ‘######’, and a footnote indicating that ‘####### refers to information filed in confidence with the CommissionFootnote 5.
If you would like to see a sample of abridged documents that other companies have submitted, please see: http://www.crtc.gc.ca/PartVII/eng/2010/8663/c12_201015470.htm.
You are requested to provide a complete response to this Commission Request for Information by 3 August, 2017. The letter should be addressed to the Commission’s Secretary General with the subject and file number indicated at the top of this letter, to ensure proper routing of your document.
As indicated above, for ease of reference, the attachment to this letter outlines the required information to be submitted to the Commission. If you have already provided all or some of the required information to the Commission, please provide the date and original company name for which this information was submitted.
If CBTS Canada Inc. is not a VoIP service provider and does not intend to offer such a service in the near future, please confirm this by email to firstname.lastname@example.org by the above-noted date so that the Commission’s registration records can be updated to reflect that there is no requirement for CBTS Canada Inc. to meet the VoIP 9-1-1 obligations.
Original signed by
Director, Dispute Resolution & Regulatory Implementation
c.c.: Wendy McClintock, CRTC, 819-639-6211, email@example.com
Information to be submitted to the Commission by local VoIP service providers in Canada
See the following links for more details.
Legal name –
Business name –
Business registration number
Jurisdiction in which the company is registered
Number of existing customer lines served –
Name of 9-1-1 answering bureau
Direct contact at 9-1-1 answering bureau - - include proof of contract or executive attestation
Intermediate contact company ies) If no direct contact with 9-1-1 answering and routing company - include proof of contract or executive attestation
Provider of telephone numbers
Ensures customers understand the service limitations for VoIP 9-1-1 service and obtains customer consent prior to beginning VoIP service that they understand and agree to the 9-1-1 service limitations.
Specify method by which consent to 9-1-1 service limitations is obtained from the customer.
Online updating of customer’s physical address for 9-1-1 purpose available Yes/No – If no, how do clients update their address.
Owns and operates its own transmission facilities in Canada - Yes/No
Registered with the Commission as a – Registered Reseller/Registered CLEC.
Obtained a Basic International Telecommunications Services (BITS) licence - Yes/No/Pending
Up to date with all ongoing regulatory filings to maintain its BITS licence and registration - Yes/No
Mandatory 9-1-1 emergency service customer notification texts - Stickers for telephone sets – Sample required
Company’s limitations of liability with respect to VoIP 9-1-1 service
Wording on company’s website, showing customer notification texts and limitations of liability with respect to VoIP 9-1-1 service
Confirm that VoIP 9-1-1 obligations are met in full - (see https://crtc.gc.ca/eng/phone/911/voip.htm) - Yes/No
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