Telecom - Commission Letter adressed to the Distribution List

Ottawa, 19 November 2021

Our reference:  8663-J92-202101369

BY EMAIL

Distribution List

RE: Part 1 Application by the Independent Telecommunications Providers Association regarding the development of retail and wholesale NG9-1-1 rates in the geographic areas covered by SILEC exchanges

On 2 March 2021, the Commission received a Part 1 Application from the Independent Telecommunications Providers Association (ITPA) requesting from the Commission:

1. A determination confirming that small Incumbent Local Exchange Carriers (“SILECs”) are responsible for providing next-generation 9-1-1 services (“NG9-1-1”) to all end-users resident in their traditional operating territories regardless of which Telecommunications Service Provider (“TSP”) serves a particular end-user;
2. A determination confirming that for the purposes of the application of wholesale rates for NG9-1-1 that all end-users that have a registered 9-1-1 service address, and for those that are mobile a billing address, in SILEC operating territories should be charged a SILEC’s NG9-1-1 monthly rate either directly from the SILEC or indirectly from their TSP via a wholesale tariff;
3. An order directing Bell Mobility, Bragg Communications, Freedom Mobile, Rogers Communications, TELUS Communications and Vidéotron ltée (collectively “the WSPs” [wireless service providers]) to provide the number of mobile wireless subscribers (i.e. working telephone numbers equipped for outward local calling) associated with billing addresses in SILEC exchanges as of 28 February 2021;
4. An order directing these companies to report number of mobile wireless subscribers to the SILEC on a monthly basis thereafter; and
5. An order suspending the requirement for SILECs to file proposed retail and wholesale NG9-1-1 tariffs until a reasonable period of time after the 28 February 2021 submission of the number of mobile wireless subscribers are provided by the WSPs in order to give SILECs the opportunity to incorporate this information into their NG9-1-1 cost studies.

Pursuant to section 37 of the Telecommunications Act and paragraph 28(1)(a) of the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, the Commission may require that persons provide it with information necessary for it to dispose of matters before it.

Comprehensive responses to the requests for information (RFI) are to be filed via My CRTC Account^Footnote1, including all rationale and supporting information needed to properly validate the responses provided, by 10 December 2021, serving copies on all other parties.

As set out in Procedures for filing confidential information and requesting its disclosure in Commission proceedings Broadcasting and Telecom Information Bulletin 2010-961, 23 December 2010, parties may designate certain information as confidential. Parties must provide an abridged version of the document involved, accompanied by a note explaining how the information removed is confidential and why the public interest in disclosure would not outweigh the likely direct harm that would result from its disclosure.

Replies to the RFI responses must be filed via My CRTC Account, serving copies on all other parties, by 17 January 2022.

Responses will be published on the Commission’s website under the file number identified above.

Sincerely,

Original signed by Étienne Robelin for

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.: Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca 
Joel McGrath, CRTC, joel.mcgrath@crtc.gc.ca

Attach. (1)

Request for information

Request for Wireless Service Providers (including ITPA SILEC WSPs)

1. Provide the number of mobile wireless subscribers in the Table 1 below, separately, for the months of May, June and July 2021 ascertained on the basis of the following:
   1. The number of mobile wireless subscribers that have a billing address located within the incumbent local exchange operating territories of Lansdowne Telephone, Nexicom Inc. & Tuckersmith Communications; and,
   2. The number of mobile wireless subscribers that have a telephone number associated with a rate center/exchange within the incumbent operating territories of Lansdowne Telephone, Nexicom Inc. & Tuckersmith Communications.

   Responses to questions 1(a) and 1(b) are to be broken down by each of the incumbent local exchange operating territories identified above.  For clarity, and by way of example, responses are to separately identify how many of your mobile wireless service subscribers have billing addresses located within the incumbent local exchange operating territory of Landsdowne Telephone, how many have billing addresses located within Nexicom Inc.’s incumbent operating territory and how many have billing addressed located within Tuckersmith Communications’ incumbent operating territory.

   3. Provide, separately for each incumbent operating territory identified above in 1(a) and (b) on a monthly basis, the percentage of the total number of your mobile wireless subscribers that have telephone numbers associated with the relevant SILEC relative to the total number of customers that have billing addresses located within that incumbent local exchange operator’s incumbent service territory.
   4. Provide comments on the commonalities or differences between the two sets of figures identified above in 1(a) and (b) and explain how these sets of figures capture potential mobile wireless 9-1-1 users in these SILEC territories.

2. How many prepaid mobile wireless subscribers does your company have, nationally, and what percentage of your company’s overall wireless subscriber base does this represent?
3. What percentage of total billing addresses for mobile wireless subscribers does the company believe no longer reflects the location at which the billed party resides and how has the company estimated such percentage?
4. What percentage of total billing addresses associated with mobile wireless subscribers are located in a foreign jurisdiction (outside Canada) and how has the company estimated such percentage?
5. Provide an estimate of the development costs (identifying main cost elements) and timing to implement the billing address-based solution for the monthly counting of mobile wireless subscribers. If the costs and timelines vary depending on whether the solution must only be used to support operations in SILEC territories versus those costs that would be incurred to support your operations in all territories in which you operate, provide both cost estimates and timelines.

For clarity, and as indicated in the above cover letter, you are to provide all rationale and supporting information needed to validate your estimates.

6. With reference to the Lansdowne Telephone, Nexicom Inc. & Tuckersmith Communications SILEC territories, identify both:
   1. the number of mobile wireless subscribers with an NPA-NXX number that corresponds with a rate centre/exchange within the SILEC’s incumbent serving territory but who’s account is held by someone with a billing address located outside that same territory; and,
   2. the number of working phone numbers that do not correspond with a rate centre/exchange within the SILEC’s incumbent serving territory associated with accounts for which the billing address is located within the incumbent serving territory of that SILEC?

Request for ITPA

Following on the statement in paragraph 20 of the ITPA Part 1 Application, this application is focussed on the fourth source of interaction with 9-1-1 in SILEC exchanges; that being WSP that do not have interconnection arrangements but whose customers live in the geographic areas that make up SILEC exchange and use local numbers from non-SILEC exchanges, please provide the following information;

7. For each ITPA-member SILEC, indicate whether WNP agreements are in place and if yes, with whom and in which exchanges.
8. Identify  those WSPs (and the relevant rate centre) that you are aware of as providing mobile wireless services within a rate centre/exchange associated with your incumbent serving territory and with whom you do not have a WNP agreement in place covering the relevant rate centre

Distribution List:

ITPA
Jonathan L. Holmes, Executive Director regulatory@itpa.ca

Intervenors

Bell Canada and Bell Mobility Inc., Philippe Gauvin, Assistant General Counsel bell.regulatory@bell.ca
Quebecor Média inc., Dennis Béland, Vice-president, Regulatory Affairs, Telecommunications regaffairs@quebecor.com
Rogers Communications Canada Inc., Howard Slawner, Vice President – Regulatory, Telecom regulatory@rci.rogers.com
Shaw Communications Inc., Dean Shaikh, Vice President, Regulatory Affairs dean.shaikh@sjrb.ca
TELUS Communications Inc., Stephen Schmidt, Vice-President – Telecom Policy & Chief Regulatory Legal Counsel regulatory.affairs@telus.com

Date modified:

2021-11-17