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Telecom - Staff Letter addressed to Jonathan Holmes (Independent Telecommunications Providers Association)

Ottawa, 14 June 2023

Our references: 8740-Q29-202107466; 8740-B6-202107325; 8740-B7-202107341; 8740-C1-202107226; 8740-E25-202107333; 8740-H3-202107440; 8740-H4-202107432; 8740-L3-202107482; 8740-N24-202107367; 8740-N23-202107359; 8740-N10-202107375; 8740-Q2-202107581; 8740-S4-202107458; 8740-W3-202107383; 8740-T7-202107557; 8740-W4-202107474

BY EMAIL

Jonathan Holmes
Executive Director
Independent Telecommunications Providers Association
29 Peevers Cres.
Newmarket, ON L3Y 7T5
jonathan.holmes@itpa.ca

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 the 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 ILECFootnote8, 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.Footnote9

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 the Independent Telecommunications Providers Association (ITPA) member SILECs, as set out in the Distribution List.

The questions appended to this letter are designed to guide the ITPA member 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, including the NG9-1-1 POIs, which are eligible for recovery under their NG9-1-1 wholesale tariff.Footnote10

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 ActFootnote11and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote12, 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.#

Section 1:  Questions for ITPA Member SILECs

  1. For the following questions, refer to the tab, “Table 3” in Appendix 1 to provide responses to the questions below, directly within the tabs “Table 3” within Appendix 1. The following should also be consulted and noted in responding to the questions below:
    • “Table 3 Network Commissioning” in the confidential version of each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_ Costing_Model_with_Wireless_Revised_06Sep2022_ABRIDGED”
    • The “Diagramme | Diagram” tab within Appendix 1.
    • For the purpose of this RFI, the "SILEC Originating Network” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “38” on the call flow diagram), refers to the wireline, wireless, or VoIP networks of the local exchange service providers where 9-1-1 emergency service requests originateFootnote13.
    • For the purpose of this RFI, the “Bell Canada NG9-1-1 network” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “41” on the call flow diagram), refers to all equipment, transmission facilities, databases, and systems between the Bell Canada POIs / SILEC designated POIs (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “36” & “37” on the call flow diagram) up to the demarcation point of the NG9-1-1 network with the PSAPFootnote14.
      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 related to Network Commissioning (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 of the Network Commissioning cost components, as it pertains to the ITPA member SILEC’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 of the Network Commissioning cost components 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 the SILEC Originating Network (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “38” on the call flow diagram), state the proportion of each of the Network Commissioning cost components that resides within the ITPA member SILEC originating network. 0% indicates that the cost component is entirely unrelated to the ITPA member SILEC originating network, while 100% indicates that the cost component is entirely related to the ITPA member SILEC originating network.
      5. In the column “% of cost component related to the transport of the SILEC Originating NG9-1-1 Traffic to the SILEC Intermediate POIs (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “39” on the call flow diagram), state the proportion of each of the Network Commissioning cost components that corresponds to the transport of traffic from the ITPA member SILEC originating network to the ITPA member SILEC’s designated intermediate POIs.
      6. In the column “% of cost component related to the transport of the SILEC Originating NG9-1-1 Traffic from the SILEC Intermediate POIs to the Bell Canada POIs (SILEC Designated POIs) (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “40” on the call flow diagram), state the proportion of each of the Network Commissioning cost components that corresponds to the transport of traffic from the ITPA member SILEC’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%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “41” on the call flow diagram), state the proportion of each of the Network Commissioning cost components that reflects the ITPA member SILEC’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. For the following questions, refer to the tab “Table 4” in Appendix 1 to provide responses to the questions below, directly within the tabs “Table 4” within Appendix 1. The following should also be consulted and noted in responding to the questions below:
    • “Table 4 Hardware, Equipment” in the confidential version of each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_ Costing_Model_with_Wireless_Revised_06Sep2022_ABRIDGED”
    • The “Diagramme | Diagram” tab within Appendix 1.
    • For the purpose of this RFI, the "SILEC Originating Network” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “38” on the call flow diagram), refers to the wireline, wireless, or VoIP networks of the local exchange service providers where 9-1-1 emergency service requests originate.
    • For the purpose of this RFI, the “Bell Canada NG9-1-1 network” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “41” on the call flow diagram), refers to all equipment, transmission facilities, databases, and systems between the Bell Canada POIs / SILEC designated POIs (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “36” & “37” on the call flow diagram) up to the demarcation point of the NG9-1-1 network with the PSAP.
      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 related to Metaswitch or Switch Upgrades and Hardware (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 of the Metaswitch or Switch Upgrades and Hardware cost components, as it pertains to the ITPA member SILEC’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 of the Metaswitch or Switch Upgrades and Hardware cost components 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 the SILEC Originating Network (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “38” on the call flow diagram), state the proportion of each of the Metaswitch or Switch Upgrades and Hardware cost components that resides within the ITPA member SILEC originating network. 0% indicates that the cost component is entirely unrelated to the ITPA member SILEC originating network, while 100% indicates that the cost component is entirely related to the ITPA member SILEC originating network.
      5. In the column “% of cost component related to the transport of the SILEC Originating NG9-1-1 Traffic to the SILEC Intermediate POIs (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “39” on the call flow diagram), state the proportion of each of the Metaswitch or Switch Upgrades and Hardware cost components that corresponds to the transport of traffic from the ITPA member SILEC originating network to the ITPA member SILEC’s designated intermediate POIs.
      6. In the column “% of cost component related to the transport of the SILEC Originating NG9-1-1 Traffic from the SILEC Intermediate POIs to the Bell Canada POIs (SILEC Designated POIs) (0% - 100%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “40” on the call flow diagram), state the proportion of each of the Metaswitch or Switch Upgrades and Hardware cost components that corresponds to the transport of traffic from the ITPA member SILEC’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%)” (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical location “41” on the call flow diagram) , state the proportion of each of the Metaswitch or Switch Upgrades and Hardware cost components that reflects the ITPA member SILEC’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.
  3. Refer to the response to CRTC Question 5 b) in the confidential version of each ITPA Member SILEC’s file, " Réponse-Response - ITPA - 18 February 2022 - Claude_Doucet_CRTC_NG9-1-1_Proposed_Tariffs_ITPA_RFI_Responses_Attachment_2_07Feb2022_ABRIDGED”, where it states: ##
    • For the following questions, refer to the ## within the NG9-1-1 outsourced service agreement in place between Bell Canada and the ITPA member SILECs:
      1. Confirm whether ## within the NG9-1-1 outsourced service agreement in place between Bell Canada and the ITPA member SILECs are applicable to the following:
        1. The ITPA member SILECs’ NG9-1-1 retail wireline residential demand
        2. The ITPA member SILECs’ NG9-1-1 retail wireline business demand
        3. The ITPA member SILECs’ NG9-1-1 retail wireless residential demand
        4. The ITPA member SILECs’ NG9-1-1 retail wireless business demand
        5. Wholesale wireline residential demand
        6. Wholesale wireless business demand
        7. Other wireless service providers (WSPs) whose customers originate wireless residential calls within the ITPA member SILECs’ territory
        8. Other wireless service providers (WSPs) whose customers originate wireless business calls within the ITPA member SILECs’ territory
      2. Refer to tab “Table 2 – SILEC NAS and WSP” and tab “Demand Forecast Table” in the confidential version of each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 - Claude_Doucet_CRTC_NG9-1-1_Proposed_Tariffs_ITPA_RFI_Responses_Attachment_2_07Feb2022_ABRIDGED”. Restate the previously submitted demand as follows:
        1. The ITPA member SILECs’ NG9-1-1 retail wireline residential demand
        2. The ITPA member SILECs’ NG9-1-1 retail wireline business demand
        3. The ITPA member SILECs’ NG9-1-1 retail wireless residential demand
        4. The ITPA member SILECs’ NG9-1-1 retail wireless business demand
        5. Wholesale wireline residential demand
        6. Wholesale wireless business demand
        7. Other wireless service providers (WSPs) whose customers originate wireless residential calls within the ITPA member SILECs’ territory
        8. Other wireless service providers (WSPs) whose customers originate wireless business calls within the ITPA member SILECs’ territory
      3. Is there a commercial agreement between the ITPA member SILECs 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 to the ITPA member SILEC designated / Bell Canada POIs?
  4. Refer to the tab “Table 3 Network Commissioning” in the confidential version of each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 July 2022 – [SILEC Name and TN Number] NG911_Costing_Model_with_Wireless_Revised_06Sep2022_ABRIDGED”.
    1. If costs related to circuit rentals were included in each respective SILEC’s cost study, state the rationale for the inclusion of such costs, and provide a description of the types of circuits rented, including an explanation as to how it differs from the costs associated with the outsourced services to Bell Canada.
  5. Refer to the tab “Table 4 Hardware, Equipment” in the confidential version of each ITPA Member SILEC’s file, "Réponse-Response - ITPA - 18 February 2022 – [SILEC Name and TN Number] NG911_ Costing_Model_with_Wireless_Revised_06Sep2022_ABRIDGED”. Where costs related to switch upgrades were included in any particular SILEC’s cost study:
    1. State the rationale for upgrading the switches within the ITPA member SILEC originating network and / or from the ITPA member SILEC Originating Network (including the SILEC intermediate POIs) to the Bell Canada POIs (as depicted within Appendix 1, tab “Diagramme | Diagram”, numerical locations “39” and “40” on the call flow diagram), and
    2. State the rationale for the inclusion of the aforementioned costs.
  6. Refer to the tab “Diagramme | Diagram” in Appendix 1.
    1. Identify, referring to the circled numbers on the NG 9-1-1 Call Flow Diagram, where competitive local exchange carriers and wireless carriers connect to access the NG9-1-1 network through the ITPA member SILEC territory.
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