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Telecom - Commission Letter addressed to Mr. Philippe Gauvin (Bell Canada), Mr. Stephen Schmidt (Regulatory Legal Counsel) and Mr. Kevin Spelay
(Saskatchewan Telecommunications)

Ottawa, 12 April 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 letter filed with the Commission on 25 March 2022 (the 25 March 2022 Letter) on behalf of Bell Canada and its affiliates (the Bell companies), SaskTel, and TELUS (collectively, the NG9-1-1 service providers), in relation to initial NG9-1-1 onboarding and traffic migration plans and follow-up progress reports requested by Commission staff.

On 23 February 2022, Allstream Business Inc., 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, Westman Media Cooperative Ltd (operating as Westman Communications Group), and Beanfield Technologies Inc. (collectively, the Signatories), filed a letter with the Commission indicating that 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 , and that as a result, only a subset of ONPs in the various NG9-1-1 territories are in a position to migrate their traffic to the NG9-1-1 network due to delays in onboarding with the NG9-1-1service provider.. The signatories committed to reporting on the status of ONP onboarding and traffic migration on a monthly basis beginning on 1 March 2022.

In a letter issued 17 March 2022, Commission staff requested that, in lieu of the monthly report proposed by the Signatories, the NG9-1-1 service providers file with the Commission by 1 April 2022, an initial plan in which they were 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 TSPs 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 networks; 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.

Staff also requested that subsequent to the filing of this initial plan, the NG9-1-1 service providers, by 8 April 2022 and on a weekly basis thereafter, file a status report on the progression of each TSP 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.

In response to these requests, the NG9-1-1 service providers filed the 25 March 2022 Letter submitting that weekly reporting was unlikely to show tangible progress in many cases due to the nature of onboarding activities, and that it was not a productive use of NG9-1-1 service provider resources and indeed may result in further delays. The NG9-1-1 service providers proposed that monthly reports are the best way to balance these realities with the needs of Commission staff being kept abreast of progress towards the completion of onboarding of ONPs to the NG9-1-1 service providers NG9-1-1 networks. The NG9-1-1 service providers further committed to notifying Commission staff by email between monthly reports when: 1) they experience challenges with ONPs being unable or unwilling to progress their onboarding, or 2) any ONPs complete their onboarding processes.

Further, the NG9-1-1 service providers submitted that while they were in a position to report on ONP onboarding activities and progress, they were unable to provide the information requested in relation to E9-1-1 to NG9-1-1 traffic migration. In this regard, the NG9-1-1 service providers submitted that given that traffic migration progress is within each individual ONP’s control, NG9-1-1 service providers have limited visibility into this metric and therefore cannot meaningfully comment on it.

Having regard to the above, Commission staff is satisfied that monthly reports on NG9-1-1 onboarding activities are sufficient for staff to maintain effective awareness of the progress in onboarding activities while being sensitive to both the matters into which these service providers have meaningful visibility and the burden that more frequent reporting would place upon the NG9-1-1 service providers. As such, staff requests that NG9-1-1 service providers file, on a monthly basis, a status report on the progression of each TSP, in which they are to

  1. Provide the anticipated final end date by which all NG9-1-1 production onboarding activities will be completed and by which all TSPs Footnote1 will be in a position to route all their relevant 9-1-1 traffic over the NG9-1-1 service provider’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 networksFootnote2 ; 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 status as of the reporting date, 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. a clear indication of and detailed justification for any deviation with respect to the previous monthly report.

The NG9-1-1 service providers having filed their initial plan by 1 April 2022, the first monthly update report is therefore due by 1 May 2022.
Staff notes, however, that should the reports filed with the Commission either increase existing concerns or raise new concerns with regards to timely progress towards full implementation of NG9-1-1, further changes to the reporting frequency and/or the information to be contained in the relevant reports may be warranted.
Staff reminds the NG9-1-1 service providers that they are to serve all 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 Independent Telecommunications Providers Association and individual small incumbent local exchange carriers with whom it has NG9-1-1 related agreements.
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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