Telecom - Staff Letter addressed to the Distribution List
Ottawa, 31 May 2024
Our reference: 1011-NOC2020-0326
BY EMAIL
Distribution List
Subject: Telecommunications Service Provider Compliance with Next Generation 9-1-1 Obligations
In Establishment of new deadlines for Canada’s transition to next-generation 9-1-1, Telecom Decision CRTC 2021-199, 14 June 2021, the Commission directed Telecommunications Service Providers (TSPs) [For the purposes of this letter, TSPs are telephone service providers that offer wireline and/or wireless local exchange telephone services, including local voice over Internet Protocol (VoIP) services.], throughout their operating territories, to:
- make the necessary changes to support next generation 9-1-1 (NG 9-1-1) Voice in their originating networks that are technically capable of supporting NG9-1-1 Voice, including completing all NG9-1-1 production onboarding activities, by 1 March 2022; and
- begin providing, by 1 March 2022, NG9-1-1 Voice to their customers served by networks that are technically capable of supporting NG9-1-1 Voice, wherever public safety answering points have been established in a particular region by directing their NG9-1-1 Voice traffic to the appropriate NG9-1-1 points of interconnection (POIs).
These obligations are subject to the following exception: if a TSP provides voice services over an originating network that is technically not capable of supporting NG9-1-1 Voice, that provider is required to continue to support the existing 9-1-1 voice service for the remaining life of the network and will be responsible for the TSP gateways and for funding them.
Further, in CISC Emergency Services Working Group consensus items—Next-generation 9-1-1 technical and operational considerations and trial logistics, Telecom Decision CRTC 2018-217, 28 June 2018, the Commission directed Originating Network Providers to support both Internet Protocol version 4 (IPv4) and Internet Protocol version 6 (IPv6), either by supporting the industry best practice of Dual Stack to provide simultaneous IPv4 and IPv6 operations or, in the event the originating network has infrastructure that is not able to support both IPv4 and IPv6, by performing Network Address Protocol—Protocol Translation (NAP-PT) within the originating network’s Emergency Services IP Networks next-generation core services.
On 23 February 2022, the Commission received a letter from Allstream Business Inc., Bell Canada (on behalf of itself and its affiliates), Bragg Communications Inc. (carrying on business as Eastlink), Distributel Communications Limited and Primus Management ULC, Freedom Mobile Inc. and Shaw, Rogers, TBayTel, SaskTel, TELUS and Westman Media Cooperative Ltd (operating as Westman Communications Group), and Beanfield Technologies Inc. advising the Commission that while Bell Canada (Bell), TELUS Communications Inc. (TELUS), and Saskatchewan Telecommunication (SaskTel) (collectively referred to as “the NG9-1-1 network providers”) had established their NG9-1-1 networks, NG9-1-1 production onboarding activities will have only been completed for a subset of TSPs by the 1 March 2022 deadline. The signatories cited the quantity of carriers needing to onboard and the sequential approach to onboarding as the cause for these delays. The NG9-1-1 network providers that were signatories to the letter committed to reporting on the status of TSP onboarding on a monthly basis.
Abridged versions of these reports can be found on the record of Call for comments—Establishment of new deadlines for Canada’s transition to next-generation 9-1-1, Telecom Notice of Consultation CRTC 2020-326, 4 September 2020, under “Reports.”
In a subsequent letter filed with the Commission on 25 March 2022, the NG9-1-1 network providers indicated while they could report on TSP onboarding activities and progress, they were unable to provide information in relation to enhanced 9-1-1 (E9-1-1) to NG9-1-1 traffic migration, citing that given that traffic migration progress is within each individual TSP’s control, NG9-1-1 service providers have limited visibility into this metric and therefore cannot meaningfully comment on it.
Based on monthly onboarding progress reports, approximately 83% of TSPs that are to be interconnected and served by the NG9-1-1 networks have completed their onboarding activities. However, staff has limited visibility into the status of each TSP’s E9-1-1 to NG9-1-1 traffic migration, including the date by which this migration is expected to be complete.
As such, Commission staff requests that each TSP provide by 14 June 2024, for each service they and/or their subsidiaries operate (Competitive Local Exchange Carrier operations, Small Local Incumbent Exchange Carrier operations, Wireless Carrier operations, etc.) that has or will be interconnected with their NG9-1-1 network providers’ network, a status report in which they are to
- Specify the number of subscribers whose services have been or will be migrated from E9-1-1 to NG9-1-1, broken down by applicable province;
- Confirm the date(s) by which they have or will have completed all onboarding activities with their NG9-1-1 network provider(s);
- Confirm the date(s) by which they have or will have completed the migration of traffic from the E9-1-1 network(s) to the NG9-1-1 network(s);
- Indicate whether any of their originating networks are not capable of supporting NG9-1-1 Voice, and if so, whether they intend to use a Legacy Network Gateway, in which areas, by when, and how many subscribers will be impacted; and
- Confirm in what matter they are supporting both IPv4 and IPv6 (Dual Stack or NAP-PT); if a TSP is not supporting both, explain why not, by which date it will be, and through which manner it will do so.
These reports requested from TSPs are meant to supplement the monthly reports filed by the NG9-1-1 network providers. NG9-1-1 network provider reports are neither modified nor replaced as a result of this request.
All TSPs are reminded that the obligations set out in Telecom Decision 2021-199 remain in place. This letter should not be understood as absolving or otherwise providing tacit acquiescence to any failure to fulfill applicable Commission-mandated obligations by either NG9-1-1 network providers or originating network providers. Commission staff reminds the TSPs that failure to meet regulatory obligations in relation to NG9-1-1 implementation could expose them to remedial action, including the imposition of Administrative Monetary Penalties.
Where a document is to be filed or served by a specific date, the document must be received, not merely sent, by that date. Additionally, all submissions to the Commission must be filed via My CRTC Account, must refer to the file number noted above, and must be addressed to the Secretary General.
As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin 2010-961, as amended by Broadcasting and Telecom Information Bulletin 2010-961-1, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation of 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 Étienne Robelin for
Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector
c.c.: Étienne Robelin, CRTC, Etienne.Robelin@crtc.gc.ca
Landon Entwistle, CRTC, Landon.Entwistle@crtc.gc.ca
Distribution List
Bell Aliant Regional Communications LP: bell.regulatory@bell.ca
Allstream Inc: william.mcconnell@zayo.com
Amtelecom LP: regulatory.matters@corp.eastlink.ca
Beanfield Technologies Inc: imad@beanfield.com
Bell Canada: bell.regulatory@bell.ca
Bell Mobility Inc: bell.regulatory@bell.ca
Bell West Inc: bell.regulatory@bell.ca
Brooke Telecom Co-operative Ltd: geoff@brooketel.coop
Bruce Telecom Ontario Inc: sharon.bell@brucetelecom.com
City West Telephone Corporation: joelle.barfoot@cwct.ca
Cochrane Telecom Services Inc: roxanne.desroches@cochranetel.ca
CoopTel, coop de télécommunication: cbreskelly@cooptel.coop
Courcelles Telephone: reglementaire@sogetel.com
Distributel Communications Ltd: bell.regulatory@bell.ca
Eastlink: regulatory.matters@corp.eastlink.ca
Exatel Inc (Vianet): regulatory@vianet.ca
Execulink Telecom Inc: regulatory@execulinktelecom.ca
Fido Solutions Inc: regulatory@rci.rogers.com
Freedom Mobile Inc: regaffairs@quebecor.com
Globility Communications Corporation (Primus Telecommunications Canada Inc): regulatory-registration@distributel.ca
Gosfield North Communication Co-operative Ltd: regulatory@gosfieldtel.ca
Téléphone Guèvremont Inc: bell.regulatory@bell.ca
Hay Communications Co-operative Ltd: angela@haymail.ca
Huron Telecommunications Co-Operative Ltd: regulatory@hurontel.on.ca
Lambton Telephone: reglementaire@sogetel.com
The Lansdowne Rural Telephone Company Ltd: regulatory@nexicomgroup.net
Managed Network Systems Inc: regulatory@nexicomgroup.net
Groupe Maskatel Québec LP: bell.regulatory@bell.ca
Mornington Communications Co-operative Limited: regulatory@mornington.ca
Nexicom Communications Inc: regulatory@nexicomgroup.net
North Frontenac Telephone Corporation Ltd: smaclin@nftctelecom.com
North Renfrew Telephone Company Limited Trade: steve@wtccommunications.ca
People’s Tel LP: regulatory.matters@corp.eastlink.ca
Quadro Communications Co-operative Inc: barry.stone@quadro.ne t
RFNow Inc: roberteslinger@cssionline.com
Rogers Communications Canada Inc: regulatory@rci.rogers.com
Roxborough Telephone Company Ltd: tjwbeach@ontarioeast.net
Saskatchewan Telecommunications: document.control@sasktel.com
Shaw Telecom Inc: regulatory.finance@sjrb.ca
Sogetel Inc: reglementaire@sogetel.com
9315-1884 Québec Inc: reglementaire@sogetel.com
TbayTel: tbtregulatory@tbaytel.com
Telephone Milot: reglementaire@sogetel.com
TELUS Communications Inc: regulatory.affairs@telus.com
Tuckersmith Communications Co-operative Ltd: regulatory@tccmail.ca
Vidéotron ltée: regaffairs@quebecor.com
Westman Media Cooperative Ltd: eastonc@westmancom.com
The Westport Telephone Company Ltd: accounting@wtccommunications.ca
Wightman Communications Ltd: regulatory@wightman.ca
Xplore Inc: legal@xplore.ca
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