Telecom - Procedural Letter addressed to the Distribution list for Notice of Consultation 2022-65

Ottawa, 4 May 2022

Our reference: 1011-NOC2022-0065


Distribution list for Notice of Consultation 2022-65

Subject: Request to suspend the Notice of Consultation 2022-65 proceeding pending resolution of a Part 1 application filed by TELUS

In Telecom Notice of Consultation 2022-65, Funding next-generation 9-1-1 access services through the National Contribution Fund, 8 March 2022 (NoC 2022-65),Footnote1 the Commission called for comments on whether the provision of NG9-1-1 access services by telecommunications service providers (TSPs) should be funded, in whole or in part, through the National Contribution Fund.

The Commission received 17 interventions by the 21 April 2022 deadline. The current deadline for replies is 6 May 2022.  

On 21 April 2022, TELUS Communications Inc. (TELUS) filed a Part 1 application in which it submitted that the Commission erred in requiring SILECs to be made NG9-1-1 service providers.Footnote2 Consequently, TELUS is requesting that small incumbent local exchange carriers (SILECs) be reclassified as originating network providers (ONPs) within the NG9-1-1 ecosystem.

As part of its application, TELUS requested that the NoC 2022-65 proceeding should be suspended pending the disposition of its Part 1 application. TELUS submitted that if the relief requested in its application is granted and SILECs are designated as ONPs, instead of NG9-1-1 service providers, the rates for their customers would come into line with those of the large incumbent local exchange carriers (ILECs), fully resolving, according to TELUS, the issues that the Commission seeks to address in NoC 2022-65.

The Commission received letters in support of TELUS’ request to suspend the NoC 2022-65 from Rogers Communications Canada Inc. (Rogers), the Comité 9-1-1 du Syndicat canadien de la fonction publique au Québec (Comité 9-1-1), and Saskatchewan Telecommunications (SaskTel).

Commission staff considers that it would not be in the public interest to suspend the process associated with the NoC 2022-65 proceeding. In this regard, staff underscores the critically important role played by 9-1-1 access services in Canadian society. Furthermore, staff notes that interventions with respect to NoC 2022-65 have already been formulated and received and replies would ordinarily be restricted to responding to such interventions.

Commission staff acknowledges that a decision on TELUS’ application may have an impact on the proceeding initiated by NoC 2022-65. However, given the importance of 9-1-1 access services and the public interest in proceeding with their implementation in a timely manner, staff considers that it would be preferable to amend the process associated with the NoC 2022-65 proceeding in order to develop a proper record that accounts for TELUS’ application. As such, staff is addressing the attached Request for Information (RFI) to all parties to the NoC 2022-65 proceeding, and amending the deadline for reply comments in order to account for the RFI.

Accordingly, parties to the NoC 2022-65 proceeding have until 13 May 2022 to respond to the attached RFI.

Moreover, the deadline for filing replies with respect to NoC 2022-65, is hereby extended from 06 May 22 to 24 May 22.


Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

c.c. Étienne Robelin, CRTC,

Distribution List :;;;;;;;;;;;;;;;

Attach. (1)

Request for Information

Refer to, among other things, the Commission’s call for comments in Telecom Notice of Consultation 2022-65, your prior intervention as part of this same proceeding, and the above-mentioned Part 1 application subsequently filed by TELUS Communications Inc. (TELUS) on 21 April 2022.Footnote3

If the Commission were eventually to grant the relief requested by TELUS in its application, would this impact or modify your views on whether the provision of Next Generation 9-1-1 (NG9-1-1) access services by Telecommunications Service Providers (TSPs) should be funded, in whole or in part, through the National Contribution Fund (NCF)? Provide a complete response with detailed rationale why or why not and all evidence on which your response is based.

As part of responding to the above, parties are also to consider the full range of questions numbered Q1 through Q7 in the Commission’s call for comments starting at paragraph 16 of NoC 2022-65.

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