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Telecom - Commission Letter addressed to Tim J W Beach (Roxborough Telephone Company Limited)

Ottawa, 4 August 2021

Our reference:  1011-NOC2020-0326

BY EMAIL

Tim J W Beach
Vice-President – Operations
Roxborough Telephone Company Limited
tjwbeach@ontarioeast.net

RE:  Compliance with Next Generation 9-1-1 (NG9-1-1) obligations

Dear Tim Beach:

This letter is to advise Roxborough Telephone Company Limited (Roxborough) of its breach of a certain NG9-1-1 regulatory obligation, as well as to remind Roxborough of upcoming NG9-1-1 obligations.

In Telecom Regulatory Policy 2019-66, the Commission directed the small Incumbent Local Exchange Carriers (ILECs) to advise the Commission and the Telecommunication Service Providers (TSPs) operating in their incumbent territories of the location of their NG9-1-1 Points of Interconnection (NG9-1-1 POIs) by 7 May 2019. In a letter dated 7 May 2019, the Independent Telecommunications Providers Association (ITPA), on behalf of its members including Roxborough, filed the location of their NG9-1-1 POIs. In subsequent correspondence, dated 8 November 2019, the ITPA, on behalf of its members in Ontario and Quebec including Roxborough, indicated their intention to outsource NG9-1-1 to Bell Canada and amended the location of the NG9-1-1 POIs previously filed by designating them as Bell Canada’s POIs in Toronto and Montreal.

In Telecom Decision 2019-348, the Commission directed Eastlink, the ITPA, and TBaytel to provide monthly status updates on their respective negotiations (to outsource NG9-1-1), starting 8 November 2019, until agreements are reached and the Commission has been notified. The ITPA, on behalf of its members including Roxborough, has filed numerous updates in response to this obligation.

Commission staff was informed by the ITPA that as of December 2020 it no longer represents Roxborough with respect to NG9-1-1.  Accordingly, as of 8 January 2021, Roxborough is in breach of the above-mentioned regulatory obligation.

As such, Commission staff requests that by 8 August 2021, Roxborough confirm its intention to outsource NG9-1-1 to Bell, and if so, also confirm that the location of its NG9-1-1 POIs remains as previously designated, that is, as Bell’s NG9-1-1 POIs in Toronto and Montreal. In the event that Roxborough no longer intends to outsource to Bell Canada, it is to describe in detail its alternative approach.

As stated above, Roxborough is in breach of its regulatory obligation to file monthly status updates on its respective negotiations to outsource NG9-1-1.  Failure to file this update by 8 August 2021, and monthly thereafter until an agreement is reached and the Commission has been notified, would constitute a further breach of its regulatory obligation and could expose Roxborough to remedial action including the imposition of an Administrative Monetary Penalty.

Commission staff would also like to remind Roxborough that, on 14 June 2021, in Telecom Decision 2021-199, the Commission established new deadlines for Canada’s transition to NG9-1-1, many of which apply to Roxborough as a TSP and as an NG9-1-1 network provider, Footnote1 whether Roxborough opts to outsource or self-provision NG9-1-1. In particular, the Commission:

  1. directed NG9-1-1 network providers, by 1 March 2022, to establish their NG9-1-1 networks, complete all NG9-1-1 production onboarding activities, and be ready to provide NG9-1-1 Voice by transiting live NG9-1-1 traffic, wherever Public Safety Answering Points (PSAPs) have been established in a particular region;
  2. directed Telecommunication Service Provider (TSPs), throughout their operating territories, to:
    1. make the necessary changes to support NG9-1-1 Voice in their originating networks that are technically capable of supporting NG9-1-1 Voice, including completing all NG9-1-1 production onboarding activities, by 1 March 2022; and
    2. begin providing, by 1 March 2022, NG9-1-1 Voice to their customers served by networks that are technically capable of supporting NG9-1-1 Voice, wherever PSAPs have been established in a particular region by directing their NG9-1-1 Voice traffic to the appropriate NG9-1-1 Points of Interconnections (NG9-1-1 POIs.) 
  3. directed all NG9-1-1 network providers to file proposed NG9-1-1 wholesale and retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, or functionalities;
  4. determined that NG9-1-1 network providers can include in their proposed tariffed rates incurred costs associated with the ability to handle, through default call routing, up to 5% of the average volume of 9-1-1 communications;
  5. directed ILECs to decommission their 9-1-1 network components that will not form part of their NG9-1-1 networks by 4 March 2025, or earlier if all the TSPs and PSAPs in an ILEC’s operating territory have completed their transition to NG9-1-1;
  6. directed all NG9-1-1 network providers to file proposed NG9-1-1 wholesale and retail tariffs, including proposed rates based on cost studies that include:
    1. costs associated with network components that were formerly included in 9-1-1 cost studies but continue to be required for the provision of NG9-1-1 services; and
    2. all other NG9-1-1-related cost components.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca
Mylène Germain, CRTC, mylene.germain@crtc.gc.ca

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