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

Ottawa, 09 March 2022

Our reference:  1011-NOC2020-0326

BY EMAIL AND REGISTERED MAIL

Tim J W Beach
Vice-President – Operations
Roxborough Telephone Company Limited
P.O. Box 190
Moose Creek ON K0C 1W0
tjwbeach@ontarioeast.net

Tim J W Beach
Vice-President – Operations
Roxborough Telephone Company Limited
431 Pitt Street
Cornwall ON K6J 3R3
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 Decision 2021-199, the Commission directed NG9-1-1 network providersFootnote1 to file proposed NG9-1-1 wholesale and retail tariffs no later than 1 November 2021. These tariffs were to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, or functionalities and can include incurred costs associated with the ability to handle, through default call routing, up to 5% of the average volume of 9-1-1 communications.

As of 9 March 2022, the Commission has yet to receive such a filing from Roxborough. As such, Roxborough is currently in non-compliance with this obligation.

The Commission would also like to remind Roxborough of its upcoming obligations with regard to NG9-1-1 implementation as a telecommunications service provider (TSP) and as an NG9-1-1 network provider. Per Telecom Decision 2021-199, Roxborough, by 1 March 2022, is to

  1. establish its 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. make the necessary changes to support NG9-1-1 Voice in its originating networks that are technically capable of supporting NG9-1-1 Voice, including completing all NG9-1-1 production onboarding activities; and
  3. begin providing NG9-1-1 Voice to its 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.

Moreover, Roxborough is to

  1. decommission its 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; and
  2. file proposed NG9-1-1 wholesale and retail tariffs, including proposed rates based on cost studies that include (i) 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 (ii) all other NG9-1-1-related cost components, with sufficient time for them to take effect on the date by which their existing 9-1-1 networks are to be decommissioned.

In the event that Roxborough assesses that it will be unable to meet its obligations set out in Telecom Decision 2021-199, the Commission reminds Roxborough that it can avail itself of procedural options to seek the relief appropriate for its situation.

Notwithstanding, the Commission directs Roxborough to arrange and conduct a meeting with Commission staff no later than 18 March 2022 to discuss, among other items, Roxborough’s plans to rectify its current non-compliance situation and its plans to meet upcoming and future NG9-1-1 obligations. This meeting can be set up by contacting Étienne Robelin, Manager of Emergency Services (etienne.robelin@crtc.gc.ca).

Further, the Commission reminds Roxborough that by failing to meet its regulatory obligations in relation to NG9-1-1 implementation, Roxborough could be exposed to remedial action including the imposition of an Administrative Monetary Penalty.Footnote2 The Commission therefore directs Roxborough to provide, by 25 March 2022, a copy of its audited financial statements for the current (2021-2022) and last two fiscal years (2019-2020 and 2020-2021) or failing the
availability of audited statements, unaudited financial statements for the same years, the veracity of which is to be formally attested to by an officer of the corporation.

Sincerely,

Original signed by

Claude Doucet
Secretary General

c.c.:  Michel Murray, CRTC, michel.murray@crtc.gc.ca, 819-639-9790
Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca, 873-354-4325

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