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Telecom - Commission Letter addressed to Various Parties

Ottawa, 17 March 2022

Our reference: 1011 - NOC2020-0326

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
160, Elgin Street, Floor 19
Ottawa (Ontario) K2P 2C4
bell.regulatory@bell.ca

Stephen Schmidt
Vice-President – Telecom Policy & Chief
Regulatory Legal Counsel
510 West Georgia Street
Vancouver (British Columbia) V6B 0M3
stephen.schmidt@telus.com

Kevin Spelay
Regulatory Affairs Manager
Saskatchewan Telecommunications
2121 Saskatchewan Drive
Regina (Saskatchewan) S4P 3Y2
document.control@sasktel.com

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

Dear Philippe Gauvin, Stephen Schmidt, and Kevin Spelay:

The present is in response to a status update (the Letter) filed  with the Commission on 23 February 2022 on behalf of Allstream Business Inc., Bell Canada (on behalf of itself and its affiliates)(the Bell companies), Bragg Communications Inc. (carrying on business as Eastlink), Distributel Communications Limited and Primus Management ULC, Freedom Mobile Inc. and Shaw, Rogers, TBayTel, SaskTel, TELUS and Westman Media Cooperative Ltd (operating as Westman Communications Group), Beanfield Technologies Inc. (collectively, the Signatories), in relation to next generation 9-1-1 (NG9-1-1) implementation.

In Telecom Decision 2021-199Footnote1, the Commission directed

  1. Next generation 9-1-1 (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; and
  2. Telecommunications Service Providers (TSPs)Footnote2 , 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 interconnection (POIs).Footnote3

In the Letter, the signatories advised the Commission that while Bell, TELUS, and SaskTel have established their NG9-1-1 networks, NG9-1-1 production onboarding activities will have only been completed for a subset of TSPs by the 1 March 2022 deadline in Bell and SaskTel’s incumbent operating territories. The signatories cited the quantity of carriers needing to onboard and the sequential approach to onboarding as the cause for these delays. Further, the signatories indicate that once a TSP is onboarded onto a NG9-1-1 network, a “soaking period” of up to six weeks will be required as traffic is migrated from the E9-1-1 networks to the NG9-1-1 networks, and these activities may extend into fall of 2022.

Lastly, the NG9-1-1 network providers that are signatories to the Letter commit to reporting on the status of TSP onboarding and traffic migration on a monthly basis beginning on 1 March 2022.

Subsequent to the receipt of the Letter, the Independent Telecommunications Providers Association (ITPA) filed a response with the Commission. The ITPA reiterated that its members are NG9-1-1 network providers in their own right and that despite not being signatories to the Letter, having designated Bell Canada’s NG9-1-1 POIs as their own, all 9-1-1 traffic originated from ITPA members’ operating territories, regardless of which ONP originates the call, will be accepted and routed in accordance with the Commission’s mandated NG9-1-1 requirements. Further, the ITPA confirmed that the signatories’ statements with regard to onboarding and traffic migration in Quebec and Ontario apply equally to ITPA members’ networks and that ITPA members will continue to rely on their NG9-1-1 network provider to facilitate the onboarding and traffic migration processes.

Commission staff notes that, in establishing the regulatory deadlines at issue, the Commission took into consideration relevant submissions made by NG9-1-1 network operators and other TSPs with regards to the activities and time needed to fully establish NG9-1-1 networks, make necessary modifications to originating networks and complete onboarding activities.  Commission staff notes that, notwithstanding that Telecom Decision 2021-199 was published on 14 June 2021, no application to review and vary that decision or to otherwise modify or modulate the obligations therein set out has been filed with the Commission. Staff notes that the regulatory requirements set out in Telecom Decision 2021-199 have therefore not been displaced and remain in force. Staff considers that it was incumbent upon the concerned entities to properly seize the Commission with any concerns, whether by way of a review and vary or other application, in the event that it was felt that regulatory relief was warranted.

Staff acknowledges that signatories to the Letter intend to file a monthly status report beginning 1 March 2022. Staff considers, however, that given the importance of the services at issue to the health, safety and wellbeing of Canadians and the failure by those concerned to take appropriate and timely action on the regulatory front, such status reports need to be comprehensive and frequent.

As such, in lieu of the monthly report proposed by the Signatories, staff requests that the Bell companies, TELUS, and SaskTel file with the Commission, by 01 April 2022, an initial plan in which they are to

  1. Provide the anticipated final end date by which all NG9-1-1 production onboarding and traffic migration will be completed and by which all TSPsFootnote4 will be in a position to route all their relevant 9-1-1 traffic over the NG9-1-1 network operator’s NG9-1-1 network.
  2. Provide the complete list of TSPs that are or that will be interconnected to and served by their respective NG9-1-1 networksFootnote5 ; and
  3. for each of these TSPs,
    1. indicate if it is a wireline, wireless, or wireline and wireless service provider;
    2. indicate the detailed onboarding activities and E9-1-1 to NG9-1-1 traffic migration activities status as of 1 March 2022, including the detail of those activities that have been completed and those that remain;
    3. indicate the start and end date of NG9-1-1 production onboarding activities, including anticipated dates where relevant; and
    4. indicate the start and end date of each E9-1-1 to NG9-1-1 traffic migration step (including soaking periods), including anticipated dates where relevant.

Subsequent to the filing of this initial plan, staff requests that the Bell companies, TELUS, and SaskTel provide, by 08 April 2022 and on a weekly basis thereafter, a status report on the progression of each TSP. These weekly reports are to include:

  1. the status as of the report filing date and complete details of NG9-1-1 production onboarding activities and E9-1-1 to NG9-1-1 traffic migration as listed above; and
  2. a clear indication of and detailed justification for any deviation with respect to the companies’ initial plan.

Further, the Bell companies, TELUS, and SaskTel are to serve all reports (including the initial plan and weekly reports) upon all TSPs that are or that will be interconnected to and served by their respective NG9-1-1 networks. Bell Canada is also to serve all its reports upon the ITPA and individual small incumbent local exchange providers with whom it has NG9-1-1 related agreements.

As previously indicated, the obligations set out in Telecom Decision 2021-199 remain in place.  This letter should not be understood as absolving or otherwise providing tacit acquiescence to any failure to fulfill applicable Commission-mandated obligations by either NG9-1-1 network providers or originating network providers. Commission staff reminds the signatories that failure to meet regulatory obligations in relation to NG9-1-1 implementation could expose them to remedial action including the imposition of Administrative Monetary Penalties.Footnote6

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c.:  Étienne Robelin, etienne.robelin@crtc.gc.ca, 873-354-4325
CLECs, ILECs, SILECs, and Wireless Carriers
Independent Telecommunications Providers Association
Allstream Business Inc.
Beanfield Technologies Inc.
Bragg Communications Inc., carrying on business as Eastlink
Distributel Communications Ltd.
Freedom Mobile Inc.
Rogers Communications Canada
Shaw Telecom Inc.
TBayTel
Westman Media Cooperative Ltd.

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