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Telecom - Commission Letter addressed to Edward Scott Hardy (Black Rider Technologies Corporation)

Ottawa, 25 May 2020

BY EMAIL

Mr. Edward Scott Hardy
Director
Black Rider Technologies Corporation
18 Basswood Crescent
Smiths Falls ON K7A 5B8

Mr. Edward Scott Hardy
104 rue de l'Écorce
Gatineau QC J8M 1R6
service@blackrider.net

Subject: Obligations of local VoIP service providers with respect to 9-1-1 emergency service

Commission staff recently became aware of an incident that occurred on 7 August 2019 in which an individual was purportedly unable to contact 9-1-1 using their local phone service provider. It is Commission staff’s understanding that this individual’s local phone service provider was Black Rider Technologies Corporation (Black Rider Technologies), and that Black Rider Technologies may be providing local voice over Internet Protocol (VoIP) service to Canadians that may not always include access to 9-1-1 emergency service.

9-1-1 Obligations of Local VoIP Service providers

The three major obligations are as follows:

  1. In accordance with Telecom Decision CRTC 2005-28Footnote1 and Telecom Regulatory Policy CRTC 2017-11Footnote2 , register with the Commission as a reseller, as a condition of obtaining services from a Local Exchange Carrier (LEC) or other telecommunications service provider. If the provider owns telecommunications facilities, they must register with the Commission as a Competitive Local Exchange Carrier (CLEC).
  2. In accordance with Telecom Decision CRTC 2005-21Footnote3, provide either Basic 9-1-1 (B9-1-1) or Enhanced 9-1-1 (E9-1-1) service to their customers;
    • In addition, in 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, the Commission mandated the use of an emergency call routing solution that ensures that VoIP service providers or third-party operators can obtain direct access to the appropriate Public Safety Answering Point (PSAP) anywhere in the country. It also prohibited local VoIP service providers from delivering the 9-1-1 calls to PSAPs using low-priority or administrative lines;
  3. In accordance with Telecom Decisions CRTC 2005-21 and 2005-61Footnote4 , provide customer notification text to their customers regarding the availability, characteristics, and limitations of a local VoIP service provider’s 9-1-1 service; the texts must be submitted for Commission review, prior to their use.

Furthermore, in Telecom Regulatory Policy CRTC 2016-12Footnote5, 14 January 2016, the Commission directed non-carriers, as a condition of offering and providing any telecommunications service, including local exchange, wireless voice, local voice over Internet Protocol, and payphone services, to abide by all applicable existing and future obligations with respect to 9-1-1 service. The appendix to Telecom Regulatory Policy CRTC 2016-12 provides a detailed list of main 9-1-1 obligations applicable to non-carriers.

Request for information from Black Rider Technologies

Black Rider Technologies Corporation and/or Mr. Edward Scott Hardy, by 09 June 2020Footnote6are requested to:

  1. Confirm whether Black Rider Technologies provides local VoIP services in Canada, detailing which municipalities or areas are served and as of which date(s);
  2. Provide a detailed breakdown of the VoIP plans Black Rider Technologies offers its customers (residential and commercial if applicable), including complete information pertaining to:
    1. Upfront, one-time, or service charges;
    2. Rates and charges for the local phone service plans available, including what is included in those rates;
    3. Which plans include access to 9-1-1 and whether there are additional charges for 9-1-1 service; and
    4. Should certain or all plans not include access to 9-1-1 or should customers of certain or all plans be required to pay additional charges or take additional steps to obtain access to 9-1-1 service that is functionally comparable to B9-1-1, Black Rider Technologies is requested to explain how this is consistent with Telecom Decision CRTC 2005-21.
  3. Provide a list of customers that Black Riders provided services to in L’Ange-Gardien, Quebec, as of 7 August 2019;
  4. Confirm whether Black Rider Technologies is registered with the Canadian Radio-Television and Telecommunications Commission (CRTC) as a telecommunications service provider in accordance with Telecom Decision CRTC 2005-28 and Telecom Regulatory Policy CRTC 2017-11Footnote7. If it is not registered with the Commission, explain why it should not do so immediately;
  5. Describe how Black Rider Technologies routes emergency calls and explain how the employed solution is consistent with Telecom Decisions CRTC 2005-21  and  2007-44; 
  6. Identify the third-party operator Black Rider Technologies employs to interface with VoIP customers and route 9-1-1 calls to Public Safety Answering Points (include name and complete contact information); describe how Black Rider Technologies provides this third-party service provider with a 9-1-1 caller’s telephone number and explain how the employed solution is consistent with Telecom Regulatory Policy CRTC 2011-426Footnote8;
  7. Describe how Black Rider Technologies determines a VoIP caller’s location and explain how the employed solution is consistent with Telecom Circular CRTC 2008-2Footnote9;
  8. Provide a copy of the template contract used by Black Rider Technologies with its customers, including a copy of the customer notification texts Black Rider Technologies provides its customers indicating any service limitations with respect to their B9-1-1 or E9-1-1 service in accordance with Telecom Decisions CRTC 2005-21 and 2005-61; and
  9. Provide business name and contact information of the underlying service provider from whom Black Rider Technologies was purchasing phone numbers or other wholesale telecommunications services on 7 August 2019 and presently, if different;
  10. Provide a copy of the contract(s) (including business name(s) and address(es)) that exist(s) between Black Rider Technologies and the local exchange carrier(s) (LECs) or other telecommunications service provider(s) from which it purchases the underlying wholesale service it relies on to provide service to its own customers. If Black Rider Technologies has purchased underlying wholesale services from different LECs or telecommunications service providers in the past, it is requested to provide these contracts as well.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications

c.c.: Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca

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