Telecom - Commission Letter addressed to Howard Slawner (Rogers Communications Canada Inc.)

Ottawa, 13 April 2022

Our reference:  1011-NOC2022-0065

BY EMAIL

Howard Slawner
Vice President – Regulatory Telecom
Rogers Communications Canada Inc.
regulatory@rci.rogers.com


RE: Request for clarification regarding the estimated $55 million annual NG9-1-1 contribution to the NCF

The Commissionissued Call for comments – Funding next-generation 9-1-1 access services through the National Contribution Fund, Telecom Notice of Consultation CRTC 2022-65, 8 March 2022 (the Notice), in which it initiated a proceeding to examine whether the provision of next-generation 9-1-1 (NG9-1-1) access services by telecommunications service providers should be funded, in whole or in part, through the National Contribution Fund (NCF).

Within the Notice, the Commission stated that “…it is estimated that funding NG9-1-1 could add approximately $55 million annually to the NCF for the next five years to cover the costs associated with the NG9-1-1 networks of the large and small ILECs.”

On 6 April 2022, the Commission received a request for clarification from Rogers Communications Canada Inc. (Rogers), indicating that they were unable to arrive at the $55 million/year figure as referenced above. Rogers submitted that the Commission should put on the public record a table showing the NG9-1-1 present worth of Annualized Cost (PWAC) per Incumbent Local Exchange Carriers (ILEC) and Small Incumbent Local Exchange Carriers (SILEC).

Staff notes that PWAC data was filed with the Commission in confidence. As such, it is not expected to be shared on the public record, nor was it used in the Commission’s calculations. In light of this, staff offers the following response to the request for clarification:

The estimated $55 million in annual contribution requirements necessary to fund the costs associated with NG9-1-1 networks was derived on the basis of information provided on the confidential record by the NG9-1-1 network providers (i.e. the large ILECs and SILECs) in support of their initial proposed NG9-1-1 tariffs. The inputs provided may be adjusted as required through a thorough analysis of the submitted costs studies. The cost inputs over the 5-year study period provided by all ILECs and SILECs resulted in an average annual cost of approximately $55M per year.

Staff considers that this information may assist parties and interested persons in developing their positions on relevant matters and informing their eventual submissions. Therefore, staff is including this response on the record of the proceeding initiated by the above referenced Notice.

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

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