Telecom - Commission Letter addressed to Chris Armstrong (City West Cable & Telephone Corp.)
Ottawa, 31 August 2021
Our reference: 1011-NOC2020-0326
Director of Sales & Marketing
City West Cable & Telephone Corp.
RE: Incumbent Local Exchange Carriers (ILECs) obligations regarding the transition to Next Generation 9-1-1 (NG9-1-1)
Dear Chris Armstrong:
This is in response to a letter from City West Cable & Telephone Corp. (City West), dated 27 July 2021. In the letter, City West informed the Commission that its incumbent territory Prince Rupert, BC and the surrounding area is currently served by Basic 9-1-1 (B9-1-1) and therefore will be unable to meet the new NG9-1-1 implementation deadlines as set out in Telecom Decision 2021-199. City West further added that, at this point, it is unable to provide a date by which it will be able to do so.
The letter states that the primary obstacle for the transition to NG9-1-1 is the lack of local address and mapping information, for which the source would be the local municipal government. It also states that City West had negotiated an agreement to outsource the provision of NG9-1-1 to TELUS, prior to its understanding that the provision of B9-1-1 would be an obstacle. It further states that City West participates in Task Identification Form 94 (TIF-94) in the Emergency Services Working Group (ESWG), where it looks to this task to produce a roadmap and other guidance for the transition to NG9-1-1.
As noted in In Telecom Decision 2019-66, the Commission did not make an exception for the transition of B9-1-1 networks to NG9-1-1 networks when it set out its NG9-1-1 framework. Footnote1 Further, the Commission reiterated that all Incumbent Local Exchange Carriers (ILECs) are to establish their NG9-1-1 networks and be ready to provide NG9-1-1 Voice service by the Commission mandated date for such service, which is currently 1 March 2022, wherever PSAPs have been established in a particular region. Footnote2
Staff notes that in Telecom Decision 2019-348, the Commission directed Northwestel to file, for the Commission’s consideration, a transition plan for the establishment of NG9-1-1 networks (including NG9-1-1 Points of Interconnection) in its incumbent territory, wherever Public Safety Answering Points have been established, by the date set by the Commission, which is currently 1 October 2021. Footnote3
Commission staff acknowledges that the situation described by City West appears to have similarities to that experienced by Northwestel, who also provides B9-1-1. However, City West is subject to an obligation, imposed pursuant to the Commission’s powers under the Telecommunications Act, to provide NG9-1-1 service to end users by 1 March 2022 wherever a PSAP has been established. While staff acknowledges the challenges City West faces in meeting this requirement and others outlined in Telecom Decision 2021-199, City West cannot delay its obligations by way of its 27 July 2021 letter, which was limited to informing the Commission that the company will not be in compliance with Commission-established deadlines.
Should City West wish the Commission to provide it with relief from or an extension to established obligations, it is incumbent on the company to make such request through appropriate channels.
While Commission staff cannot provide advice as to how a formal request for relief should be structured, nor the grounds to be argued in support, it may be appropriate for City West to have regard for Northwestel's situation and the resulting requirements imposed upon this company by the Commission, should it chose to formally approach the Commission with a request for relief. Footnote4
Original signed by
Director, Dispute Resolution and Regulatory Implementation
c.c.: Étienne Robelin, CRTC, firstname.lastname@example.org
Mylène Germain, CRTC, email@example.com
Richard Polishak, TELUS, Richard.Polishak@TELUS.COM
Jonathan Holmes, ITPA, firstname.lastname@example.org
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