ARCHIVED - Telecom Commission Letter Addressed to the Distribution List

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Ottawa, 30 October 2018

Our reference: 1011-NOC2018-0105


To: Distribution List

Re: Supplemental Reply Comments from the Independent Telecommunications  Providers Association (the ITPA)

Dear Madam/Sir:

In Telecom Notice of Consultation CRTC 2018-105, Next-generation 9-1-1 network design efficiencies, dated 26 March 2018 (TNC 2018-105), the Commission initiated a proceeding to examine matters related to next-generation 9-1-1 (NG9-1-1) network design efficiencies, including roles and responsibilities related to the provisioning of location information servers and customer information databases, NG9-1-1 network components that could be shared, and efficient interconnection arrangements.
On 17 August 2018, Commission staff requested information from all large and small incumbent local exchange carriers (ILECs), as well as from other telecommunication service providers who provide 9-1-1 services (TSPs) and have intervened in this proceeding, either directly or through an association (collectively, the TSP intervenors). Responses to these questions were filed by 17 September 2018.  Parties were to file reply comments by 1 October 2018. Footnote1 
On 25 September 2018, Commission staff revised the timelines as follows:

On 23 October 2018, the ITPA filed Supplemental Reply Comments.   The ITPA acknowledged that the process associated with the proceeding initiated by TNC 2018-105 did not contemplate supplementary replies but argued that its comments should nonetheless be accepted so as to ensure that the Commission does not reach erroneous conclusions based on incorrect information.  Commission staff is of the view that the submissions set out in paragraphs 5 through 8 of the ITPA’s Supplementary Reply Comments are of no relevance to determinations that the Commission will need to make in this proceeding and, accordingly, these comments will not be considered by the Commission.  Commission staff considers, however, that the comments set out in paragraphs 3 and 4 of these same reply comments and the matter to which they are addressed may be of relevance to the determinations that will be reached and therefore considers that these comments should form part of the record for this proceeding.  Commission staff further considers that TELUS Communications Inc. (TELUS) should be provided with an opportunity to respond to these comments, which were directed to it.  Accordingly, TELUS may provide a response to the statements made in paragraphs 3 and 4 of the ITPA’s Supplementary Reply by no later than 6 November 2018.
Should any questions related to these requests arise, please contact Mylène Germain by email at


Original signed by

Philippe Kent
Director, Competition and Emergency Services Policy
Telecommunications Sector
c.c.:  Mylène Germain, CRTC, 819-635-4538,;
James Ndirangu, CRTC 819-997-3670,

Distribution List;;;;;;;;;

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