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Telecom - Staff Letter addressed to Robert Olenick (Tbaytel)

Ottawa, 14 June 2023

Our reference: 8740-T8-202107531

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Distribution List

Subject: Introduction of Next Generation 9-1-1 (NG9-1-1) Service – Requests 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 in response to Telecom Decision 2021-199. In relation to the proposed tariffs, Commission staff requests additional supporting information from Tbaytel.

The questions appended to this letter are designed to guide the SILECs in identifying the costs associated with their originating networks, including transiting their originating traffic to the NG9-1-1 POIs (NG9-1-1 retail tariff), from the costs associated with their outsourced NG9-1-1 network, which are eligible for recovery under their NG9-1-1 wholesale tariff.footnote9

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.

The Commission requires the response or other documents to be submitted electronically by using the secured service “My CRTC Account” (Partner Log In or GCKey) and filling the “Telecom Cover Page” located on the Commission’s website.

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 Actfootnote10and in Broadcasting and Telecom Information Bulletin CRTC 2010-961footnote11, 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 (Appendix upon request only)

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.#

  1. For the following questions, refer to the tab, “Cost Data” in Appendix 1 to provide responses to the questions below, directly within the appendix. The following should also be consulted and noted in responding to the questions below:
    • The file, “Réponse-Response - 14 January 2022 - TBayTel - NG9-1-1 Attachment 1 to RFI Responses February 7, 2022 ABRIDGED”.
    • The “Diagramme | Diagram” tab within Appendix 1.
    • For the purpose of this RFI, the "originating network” refers to the wireline, wireless, or VoIP networks of the local exchange service providers where 9-1-1 emergency service requests originateNote de bas de page12.
    • For the purpose of this RFI, the “NG9-1-1 network” refers to all equipment, transmission facilities, databases, and systems between the point of interconnection of the originating network and the 9-1-1 network, up to the demarcation point of the 9-1-1 network with the PSAPfootnote13.
      1. In the column “Numerical location(s) on call flow diagram (Type "All" if applicable to entire NG9-1-1 network)”, refer to the NG9-1-1 Call Flow Diagram and state the corresponding circled number that corresponds to each listed cost component (if applicable) in the NG9-1-1 Call Flow Diagram.
      2. In the column “Description of cost component and purpose within NG9-1-1 network”, describe and state the purpose of each listed cost component, as it pertains to Tbaytel’s provisioning of the NG9-1-1 services.
      3. In the column “Cost component corresponding to wholesale NG9-1-1 rate, retail NG9-1-1 rate, or both?”, state whether each cost component is reflected in the wholesale NG9-1-1 rate, the retail NG9-1-1 rate, or both, using the dropdown selection.
      4. In the column “% of cost component that resides within Tbaytel’s Originating Network (0% - 100%)” state the proportion of each cost component that resides within Tbaytel’s originating network. 0% indicates that the cost component is entirely unrelated to Tbaytel’s originating network, while 100% indicates that the cost component is entirely related to Tbaytel’s originating network.
      5. In the column “% of cost component related to the transport of Tbaytel’s traffic to the SILEC Intermediate POIs (0% - 100%)”, state the proportion of each cost component that corresponds to the transport of traffic from Tbaytel’s originating network to Tbaytel’s designated intermediate POIs.
      6. In the column “% of cost component related to the transport of Tbaytel’s Originating NG9-1-1 Traffic from the SILEC Intermediate POIs to the Bell Canada POIs (SILEC Designated POIs) (0% - 100%)”, state the proportion of each cost component that corresponds to the transport of traffic from Tbaytel’s designated intermediate POIs to the Bell Canada POIs (SILEC designated POIs).
      7. In the column “% of cost component that resides within the Bell Canada NG9-1-1 Network (0% - 100%)”, state the proportion of each cost component that reflects Tbaytel’s function as a NG9-1-1 Network provider. 0% indicates that the component is entirely unrelated to the Bell Canada NG9-1-1 network, while 100% indicates that it is entirely related to the Bell Canada NG9-1-1 network.
  2. Refer to the response to CRTC Question 5b) in the confidential version of Tbaytel’s file, " Réponse-Response - 14 January 2022 - TBayTel - NG9-1-1 RFI Responses - February 7, 2022 ABRIDGED”, where it states:
    • “Outsourced Services are based on the Service Agreement at ## per NAS and/or WTN with demand being determined through Tbaytel’s 2022 Revenue Budget.”
    • Additionally, refer to “TABLE 1” in the confidential version of Tbaytel’s file, " Réponse-Response - 14 January 2022 - TBayTel - NG9-1-1 RFI Responses - February 7, 2022 ABRIDGED”:
      1. Confirm whether ## within the NG9-1-1 outsourced service agreement in place between Bell Canada Tbaytel is applicable to the following:
        1. Tbaytel as SILEC wireline demand
        2. Tbaytel as CLEC wireline demand
        3. CLECs wireline demand
        4. Tbaytel wireless demand
        5. Other WSP (wireline service providers) demand (other WSPs whose customers originate wireless calls within the Tbaytel territory)
  3. Refer to the “Diagramme | Diagram” in Appendix 1.
    1. Identify, referring to the circled numbers on the NG9-1-1 Call Flow Diagram, where competing carriers (such as CLECs and wireless carriers) connect to access the NG9-1-1 network through Tbaytel’s network.
    2. Referring to the circled numbers on the NG9-1-1 Call Flow Diagram, identify where the demarcation points are between Tbaytel and its NG9-1-1 provider. Specifically, in the context of call flow, identify where (i.e., the numerical location on the diagram) Tbaytel’s operations as an originating network provider ends and where its operations as a NG9-1-1 provider begins.
    3. Provide a revised call flow diagram that incorporates Tbaytel’s response to part b) of this question.
  4. The Commission, at Paragraph 85 of Telecom Regulatory Policy CRTC 2019-66footnote14 (TRP 2019-66), 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.”
    • Refer to the document, “Réponse-Response - 20 September 2022 - Tbaytel - Letter - RFI NG9-1-1 Tariffs - 10142022 ABRIDGED” dated 14 October 2022, filed in response to a Request for Information (RFI) by Commission staff dated 20 September 2022. In Tbaytel’s response to question 5c, it is reflected in a chart that the following cost components are all related to the transiting of the traffic to the POIs:
      • Design development fee,
      • Project delay costs,
      • Circuits,
      • Testing,
      • Wireless,
      • Outsource services, and
      • Switch software, licenses, and support.
      1. Confirm that these costs have been included in Tbaytel’s cost submissions and, if they have, provide an explanation as to how Tbaytel supports the inclusion of these costs, in light of Paragraph 85 of TRP 2019-66.
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