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Telecom - Staff Letter addressed to the Distribution List

Ottawa, 16 August 2024

Reference(s): 8740-T66-202401412, 8740-B20-202402048

BY EMAIL

Distribution List

Subject: TELUS Tariff Notice 589 - Introduction of Emergency Location Service and Bell Canada Tariff Notice 983 - Introduction of Advanced Mobile Location Functionality for Wireless Service Providers

In Telecom Decision 2023-235, the Commission directed Bell Canada and TELUS Communications Inc. (TELUS), as facilities-based wireless services providers, to provision Emergency Location Service (ELS) handset-based location technology for 4G wireless networks, and for 5G wireless networks where they have been implemented, in areas with NG9-1-1 service by 30 April 2024.Footnote1

On 28 March 2024, TELUS filed Tariff Notice 589 (TN 589) to revise its General Tariff (CRTC 21461), Item 1001, Next Generation 9-1-1 Service (“NG9-1-1”) to incorporate the provision of ELS.

On 18 April 2024, Bell Canada filed Tariff Notice 983 (TN 983) to revise its National Services Tariff (CRTC 7400) to introduce Item 602 – Advanced Mobile Location Service, to incorporate the provision of ELS.

On 8 May 2024, the Commission approved, on an interim basis, both TN 589 and TN 983.Footnote2

Commission staff notes that the analysis is ongoing but additional information is required. To assist in the analysis, Commission staff requests that Bell Canada and TELUS provide responses to the following request for information (RFI) by 6 September 2024.

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 responses 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 ActFootnote3 and in Broadcasting and Telecom Information Bulletin CRTC 2010-961Footnote4, 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

Attach. (2)

Distribution List

Applicants

Bell Canada

TELUS Communications Inc.

Interveners

Québecor Média inc.

Rogers Communications Canada Inc.

Request for Information

Questions for TELUS and Bell Canada

  1. For the following questions, refer to Telecom Decision 2023-235Footnote5.

    Paragraph 37 states:

    “the Commission considers that the aggregation model whereby Bell Canada and [TELUS] act as national aggregators, including in Saskatchewan Telecommunications’ [Saskatchewan Telecommunications (SaskTel)] territory, provides a good foundation for the interconnections required to facilitate the future inclusion of additional handset-determined data subject to future determinations by the Commission.”

    Further, paragraph 50 states:

    “the Commission directs Bell Canada and [TELUS] as the aggregators for ELS, and all facilities-based WSPs, to take steps in preparation for the implementation of ELS”

    Given that the Commission identifies Bell Canada and TELUS as national aggregators for ELS:

    1. Confirm that the company is making the ELS available for facilities-based WSPs across Canada, as per the directives outlined in Telecom Decision 2023-235.  If it is not, explain with justification why not.
    2. Confirm that the company is providing the ELS for facilities-based WSPs in SaskTel’s territory, as per the directives outlined in Telecom Decision 2023-235. If it is not, explain with justification why not.
    3. Refer to TELUS’ cost study, “TN-589 Att 2 – Abridged.XLS”, and Bell Canada’s cost study, “PROPOSED - GROUP B - Bell Canada TN 983 - ATT - APP 1_ABR.XLS”.
      1. State whether the costs and related demand for the provision of ELS for WSPs in Canada, including those operating in SaskTel’s territory, are reflected in each company’s respective cost study.
      2. If the answer is “yes” to question 1) c) i), identify where the ELS demand in SaskTel territory is captured within the company’s respective cost model.
      3. If the answer is “yes” to question 1) c) i), identify where the costs for ELS in SaskTel territory are captured within the company’s respective cost model.
    4. If the responses to any of the above questions necessitate the revision or addition of any supporting documentation filed in connection with TELUS TN 589 or Bell Canada TN 983, include such documentation in each company’s respective responses.

Questions for TELUS

  1. Refer to the document, “TN-589 Att 1.pdf” filed by TELUS in connection with TN 589, dated 28 March 2024.

    In paragraph 15, TELUS stated that its wholesale monthly rate, per wireless network access, “shall apply to all facilities-based WSPs operating within TELUS’ [incumbents local exchange carrier (ILEC)] territories in AB, BC, and QC.”

    Further, in paragraph 24, TELUS stated:

    “[the] demand for ELS consists of end-users for facilities-based WSPs that interconnect with TELUS for the NG9-1-1 service through designated Points of Interconnection available in AB and BC.”

    Additionally, in paragraph 34, TELUS stated:

    “[the] study follows an all-carrier approach to develop the average cost per unit service demand. The approach is applied to (i) all tariffed demand for the service (wholesale), and (ii) the Company’s non-tariffed retail wireless demand in AB and BC. Any costs incurred by the Company for the service are apportioned using tariffed and non-tariffed demand forecasts, where costs related to the non-tariffed demand are excluded from the study.”
    1. Confirm whether TELUS has, or forecasts to have, any wholesale network access service (NAS) in Quebec that would be subject to its proposed ELS tariff.
    2. If TELUS does have wholesale NAS in Quebec subject to the proposed ELS tariff, itemize which, if any, costs associated with the provision of ELS service to TELUS’ Quebec NAS are included in the cost study, “TN-589 Att 2 – Abridged.xls”, which was filed in support of TN 589.
    3. If TELUS does have wholesale NAS in Quebec subject to the proposed ELS tariff, but costs associated with the provision of ELS service to TELUS’ Quebec NAS are not included in the cost study, “TN-589 Att 2 – Abridged.xls”, which was filed in support of TN 589, explain why they were not included.
    4. If TELUS does not have wholesale NAS in Quebec subject to the proposed ELS tariff, state why TELUS has stated in paragraph 15 that its monthly wholesale rate would apply in Quebec.
    5. Explain, with supporting rationale, the appropriateness of using a proposed tariff rate developed using only information from TELUS’ Alberta and British Columbia territory for its wholesale customers in Quebec.
    6. If the responses to any of the above questions necessitate the revision of any supporting documentation filed in connection with TN 589, include such documentation in TELUS’ response.
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