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Telecom - Staff Letter addressed to Philippe Gauvin (Bell Canada)

Ottawa, 14 June 2023

Our references: 8740-T8-202107531, 8740-Q29-202107466; 8740-B6-202107325; 8740-B7-202107341; 8740-C1-202107226; 8740-C41-202107599; 8740-E25-202107333; 8740-H3-202107440; 8740-H4-202107432; 8740-G2-202107680; 8740-L3-202107482; 8740-M5-202107416; 8740-N24-202107367; 8740-N23-202107359; 8740-N7-202107549; 8740-N10-202107375; 8740-Q2-202107581; 8740-S4-202107458; 8740-W3-202107383; 8740-T7-202107557; 8740-W4-202107474

BY EMAIL

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

Subject: Introduction of Next Generation 9-1-1 (NG9-1-1) Service – Request for Information

In Telecom Decision 2021-199,Footnote1 the Commission directed all NG9-1-1 network providers to file proposed wholesale and retail tariffs no later than 1 November 2021. These tariffs are to include proposed rates supported by cost studies that reflect the incremental costs of adding new NG9-1-1 networks, services, or functionalities. The Commission received tariff applications, as well as supporting information, from the telecommunications providers referenced in the Distribution List further to the direction provided under Telecom Decision 2021-199, requesting approval for proposed changes to their national services tariffs to introduce NG9-1-1 Service.

In its NG9-1-1 framework,Footnote2 the Commission determined that incumbent local exchange carriers (ILECs) would be NG9-1-1 network providers and directed ILECs to establish NG9-1-1 networks within their territories. The Commission also directed Telecommunication Service Providers (TSPs) to provide NG9-1-1 Voice in their originating networks; these TSPs are also known as originating network providers.Footnote3

The ILECs play two key roles in the provision of NG9-1-1: as originating networkFootnote4 providers for their own retail subscribers, and as NG9-1-1 networkFootnote5 providers, who are, among other things, responsible for transiting 9-1-1 calls originated within their territory from all originating network providers to the appropriate public safety answering point (PSAP). To increase the efficiency and cost-effectiveness of the NG9-1-1 network architecture, the Commission later set out an interconnection framework including the establishment of NG9-1-1 points of interconnection (POIs) for the originating network providers to interconnect to the NG9-1-1 network providers.Footnote6  In that framework, the Commission determined that all TSPs, including small TSPs operating originating networks, are responsible for the costs associated with the transitioning of their subscribers’ NG9-1-1 calls to the NG9-1-1 POIs.Footnote7  This is in addition to their responsibility for the costs associated with upgrades to their originating networks for the provision of NG9-1-1. 

The NG9-1-1 network providers have the choice of building their own NG9-1-1 networks or outsourcing to another ILEC. The small incumbent local exchange carriers (SILECs) have opted to outsource it to their neighbouring large ILEC (Bell Canada in Ontario and Québec) and have designated their NG9-1-1 POIs as those of the neighbouring large ILEC, as per the interconnection framework.  As such, the 9-1-1 calls originating from all originating network providers within the SILECs’ territories are interconnected to the SILECs’ designated NG9-1-1 POI, which is also Bell Canada’s POI. In Telecom Regulatory Policy 2019-66 (TRP 2019-66), the Commission determined that in terms of NG9-1-1, the only traffic that transits to the NG9-1-1 network is the SILECs’ originating 9-1-1 traffic. Accordingly, the Commission determined that all TSPs, including small TSPs operating originating networks, are responsible for the costs to transit their NG9-1-1 traffic to the NG9-1-1 POIs.Footnote8

Commission staff have reviewed the applications and all supporting information and documentation filed by the Independent Telecommunications Providers Association (ITPA) member SILECs and Tbaytel, as set out in the Distribution List in response to Telecom Decision 2021-199. In relation to the proposed tariffs, Commission staff requests additional supporting information from Bell Canada in respect to the service agreement it has in place with the SILECs in respect to the provision of NG9-1-1 service.

The questions appended to this letter are designed to guide Commission staff in ascertaining whether the costs associated with the SILECs’ outsourcing of their NG9-1-1 services pertain to their originating networks (including transiting their originating traffic to the NG9-1-1 POIs) or their outsourced NG9-1-1 network.

In that respect, the process and associated dates are as follows:

All documents filed and served must be received, not merely sent, by the date provided. Parties are to send an electronic copy of all documents to Commission staff copied on this letter.

An abridged copy of this letter and all related correspondence will be added to the public record of the proceeding.

As set out in section 39 of the Telecommunications ActFootnote9and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote10, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Sincerely,

Original signed by

Chris Noonan
Director, Competitor Services & Costing Implementation
Telecommunications Sector

c.c.:   

Stais Armstrong, CRTC, 819-775-0401, stacey.armstrong@crtc.gc.ca;
Daniel Cardozo, CRTC, 819-962-5720, daniel.cardozo@crtc.gc.ca;
B. Natraj (Nat Natraj), CRTC, 819-953-5081, nat.natraj@crtc.gc.ca
Applicants
Interveners

Attach. (2)

  1. Distribution List
  2. Request for Information (RFI) Questions

Distribution List

Applicants - ITPA member SILECs

Company, Tariff Notice Number, Our Reference Number, Company Contact

Applicants - All Other Telecommunications Providers

Company, Tariff Notice Number, Our Reference Number, Company Contact

Interveners

Organization; Organization Representative(s); Organization Contact

Requests for Information (RFI)

#Denotes information filed in confidence#

For the following questions, refer to the ## within the NG9-1-1 outsourced service agreement in place between Bell Canada and the SILECs (both the ITPA member SILECs and Tbaytel).

  1. Confirm whether the SILECs incur the ## within the NG9-1-1 outsourced service agreement for:
    1. The SILECs’ subscribers’ NG9-1-1 traffic
    2. Wholesale NAS (including competitive local exchange carriers and third-party wireless users).
  2. State the proportion of the cost of the ## within the NG9-1-1 outsourced service agreement that pertains to the SILEC originating networkFootnote11 (0-100%). 0% indicates that the cost component is entirely unrelated to the SILEC originating network, while 100% indicates that the cost component is entirely related to the SILEC originating network.
  3. State the proportion of the cost of the ## within the NG9-1-1 outsourced service agreement that pertains to the SILEC’s function as a NG9-1-1 network providerFootnote12 (0-100%). 0% indicates that the cost component is entirely unrelated to the NG9-1-1 network, while 100% indicates that it is entirely related to the NG9-1-1 network.
  4. State the proportion of the cost of the ## within the NG9-1-1 outsourced service agreement that pertains to:
    1. The transport of traffic from the SILEC’s originating network to the SILEC’s intermediate POI
    2. From the SILEC’s intermediate POI to their designated NG9-1-1 POI (0-100%).
  5. Was the SILEC wireline traffic from the SILEC’s originating network considered within the establishment of the aforementioned ##?
  6. If the wireless demand is included within the establishment of the aforementioned ##, was the SILEC customer originated wireless traffic considered?
  7. If the wireless demand is included within the establishment of the aforementioned ##, was the other wireless service providers customer originated traffic within the SILECs’ territory considered?
  8. Is there a commercial agreement between the ITPA and the wireless service providers whose customers originate calls within the ITPA member SILECs’ territory to cover the costs of the ITPA member SILECs delivering wireless service provider customer originated NG9-1-1 calls from the ITPA member SILEC designated / Bell Canada POI to the designated PSAP?
  9. Are there commercial agreements between Bell Canada and the wireless service providers whose customers originate calls within the ITPA member SILECs’ territory to cover the costs of Bell Canada delivering wireless service provider customer originated NG9-1-1 calls from the Bell Canada POI to the designated PSAP?
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