Telecom - Commission Letter addressed to the Distribution List

Ottawa, 21 October 2021


To: Distribution List

RE: Internet Protocol (IP) voice network interconnection – Request for Information

In Telecom Regulatory Policy CRTC 2012-24, the Commission deemed that migration to IP voice interconnection between carriers was in the public interest and established a set of principles to facilitate IP voice network interconnection between network operators while allowing market players to develop their own arrangements. Since then, the Commission has monitored migration progress through requests for information (RFIs) on the status of the IP voice network interconnection market in 2013, and again in 2015.

Several technological and societal developments have taken place since the last iteration of RFIs on this topic, including the evolution to Next Generation 9-1-1 services, the implementation of the STIR/SHAKEN framework, as well as increases in network traffic due to the COVID-19 pandemic.

In order for the Commission and its staff to better understand the current state of IP voice network interconnection arrangements between network operators and associated issues, please provide responses to the information requested in the attachment by December 20, 2021. All responses are to be received, and not merely sent, by that date.

As set out in section 39 of the Telecommunications Act, persons may designate certain information as confidential.

A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential, or provide reasons why an abridged version cannot be filed.

Yours sincerely,         

Original signed by

Ian Baggley
A/Executive Director
Telecommunications Sector

c.c. Distribution List: Parties affected by the migration to IP voice interconnection

Appendix: RFI Questions

  1. Does your company interconnect with other entities’ networks for the purposes of exchanging voice traffic? If so,
    1. Provide the names of these entities.
    2. For each of these entities, in the table format provided below, for the period from 1 July 2020 to 30 July 2021, separated by voice traffic type (i.e. Local, toll, wireless) where possible, provide the following information:
      1. the total number of interconnections (e.g. TDM-TDM or IP-IP interconnections) your company has with each of these carriers
      2. the number of interconnections with the carrier that require conversion from IP to TDM
      3. the % of trunks carrying traffic that requires conversion from IP to TDM
      4. an estimate of the voice traffic that was exchanged with each carrier on a time-division multiplexing (TDM) basis, and on an internet protocol (IP) to IP (Session Initiation Protocol (SIP)) basis as a percentage of the total voice traffic exchanged with that carrier. The breakdown is to be provided by Voice – local, toll, & wireless
      5. an estimate of the percentage of voice traffic exchanged with the carrier that required conversion from IP to TDM in order to enable interconnection
        Interconnections and Conversions, by Carrier and Traffic Type
        Carrier Traffic Type Total number of interconnections (e.g. TDM-TMD or IP-IP interconnections) Interconnections that require IP to TDM conversion % of trunks requiring conversion TDM Traffic (%) IP-to-IP (SIP-based) (%) Traffic that required IP to TDM conversion (%)
        <Carrier #1> All voice traffic
        <Carrier #2> All voice traffic
  2. Is your company currently negotiating arrangements with other entities for the purposes of exchanging traffic on an IP-to-IP (SIP) interconnection basis?  If so,
    1. Provide the names of these entities.
    2. For each of these entities, provide the estimated target completion date by which IP-to-IP (SIP) interconnection for the purpose of exchanging traffic will be implemented. If the estimated target completion date has not been established or is later than you would prefer, provide your views on issues or challenges that are causing the delay in or inability to establish such interconnection arrangements with the relevant carrier.
  3. Outline your company’s forecasted plans to migrate your voice network over the next five years to IP-based (SIP) telephony equipment and by what date your company’s network is forecasted to be fully converted to IP-based (SIP) technologies? This outline should include any plans that merge voice services with other non-voice services over a common IP-based (SIP) network.
  4. Provide the following information using the table format below:
    Network Evolution Forecast, by Technology
    Year* TDM-Based Softswitch/IP-Based (SIP)
    Number of switches Number of customers served Number of switches Number of customers served
    By 2031

    *Please forecast fiscal year-end numbers (ending on December 31).

  5. Given that IP interconnection is not subject to the same physical demands as TDM interconnection:
    1. Could or should IP interconnection arrangements for voice between telecommunications carriers take the same form as the interconnection arrangements used for connecting to the Internet? For example at an Internet exchange point (IXP) or other points of interconnection (POIs). Provide the reasoning or rationale for your views on these type of arrangements.
    2. Are there any resiliency, security or other concerns that may result from the above method of interconnecting? Please provide your rationale and also identify any approaches or solutions that could mitigate these concerns.
  6. Are there any barriers or challenges that are preventing or delaying your company’s network migration to IP-based (SIP) networks or technologies? If there are, what are these barriers and/or problems and what is being done or can be done to remove them?
  7. In Telecom Regulatory Policy 2017-182 the Commission determined that incumbent local exchange carriers (ILECs) are responsible for the construction, operation, and maintenance of the next-generation 9-1-1 (NG9-1-1) networks, which will use IP technology. This will enable Canadians to access new, enhanced, and innovative 9-1-1 services with IP-based capabilities. Please comment on the availability of IP-to-IP interconnection between originating networks and the NG9-1-1 networks, and how this impacts your ability to support NG9-1-1.
  8. In Compliance and Enforcement and Telecom Decision 2021-123 the Commission directed all TSPs to implement STIR/SHAKEN to authenticate and verify caller identification (ID) information for IP-based voice calls as a condition of offering and providing telecommunications services, effective 30 November 2021.  On July 23rd 2021, you were asked to describe the status of your IP interconnection with other TSPs.  Please update your response, as appropriate, and comment on how your current IP interconnection status impacts your ability to support STIR/SHAKEN
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