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Telecom - Procedural Letter addressed to the Distribution List

Ottawa, 17 May 2022

Our reference: 8633-T66-202201755

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Distribution List

RE:  TELUS Part 1 Application for reclassification of SILECs as ONPs for the purposes of NG9-1-1

In the next-generation 9-1-1 (NG9-1-1) framework, Footnote1 the Commission directed all incumbent local exchange carriers (ILECs) to establish their NG9-1-1 networks and to provide NG9-1-1 Voice wherever public safety answering points (PSAPs) have been established in a particular region. The Commission also established in the framework that for the purposes of NG9-1-1, the term “ILECs” includes both large and small ILECs (SILECs).

On 21 April 2022, TELUS Communications Inc. (TELUS) filed a Part 1 application in which it submitted that the Commission erred in making SILECs NG9-1-1 service providers. Consequently, TELUS is requesting that SILECs be reclassified as originating network providers (ONPs) for the purposes of the Commission’s regulatory regime.

SILECs

Each SILEC is to file with the Commission responses to the following requests for information (RFIs):

  1. At present, are there any PSAPs that are physically located in your incumbent serving territory? If yes, identify such PSAPs and whether they are primary PSAPs (P-PSAPs) or secondary PSAPs (S-PSAPs).
  2. For each PSAP identified in your response to question 1 above, specify whether the transmission facilities connecting with that PSAP for the purpose of 9-1-1 and non-9-1-1 (i.e. administrative/non-emergency traffic) communications are owned by yourself or a large ILEC.
  3. For each PSAP identified in your response to question 1 above, specify whether you have any agreements in place. In the event that SILECs are reclassified as ONPs for the purpose of NG9-1-1 implementation, what will be the impact on these agreements?

Large ILECs

Each large ILEC is to file with the Commission responses to the following RFIs:

  1. Identify all existing P- and S-PSAPs that are physically located in a SILEC incumbent operating territory. For each such PSAPs, specify whether it is directly connected to transmission facilities that you own.
  2. In the event that you are required to provide NG9-1-1 connectivity to PSAPs outside of your incumbent serving territory, what would be the impact on your NG9-1-1 tariff, including rates, terms and conditions, and/or creation of new agreements?

SILECs and large ILECs

Each SILEC and large ILEC is to file with the Commission responses to the following RFIs:

  1. To date, what costs have you incurred as a result of SILECs being classified as NG9-1-1 network providers in the NG9-1-1 framework that you would not have incurred had SILECs been classified as an ONP (i.e. not NG9-1-1 network providers)? Itemize and describe in detail each cost element that is responsive to this question. Furthermore, quantify all relevant costs and provide all relevant formulas, facts, and assumptions employed to determine these costs.
  2. In the event that the Commission reclassifies some or all SILECs as ONPs, would you remain liable for certain expenditures as a result of NG9-1-1 outsourcing agreements in place (i.e. agreements between a SILEC and a large ILEC whereby the latter provides facilities and services to the SILEC in order for this last to meet its obligations as an NG9-1-1 network operator). Itemize and describe in detail each cost element that is responsive to this question. Furthermore, quantify all relevant costs and provide all relevant formulas, facts, and assumptions employed to determine these costs.
  3. In the event that the Commission determines that some or all SILECs should no longer be classified as an NG9-1-1 network provider, what mechanism would be available to you to recover those costs identified in response to questions 4 and 5 above? Would the Commission have the authority to require that any relevant monies already paid be refunded and terminate any unrealized obligations arising from NG9-1-1 outsourcing agreements and, if yes, what is the statutory basis for such authority?
  4. In the event that SILECs are reclassified as ONPs for the purpose of NG9-1-1 implementation, would there be any impact on your company arising from a relevant NG9-1-1 outsourcing agreement that is not captured by your responses to the above questions? If yes, describe the impact.
  5. Should a P- or S-PSAP be physically located in a SILEC incumbent operating territory (including any PSAPs that may be established in the future), would the Commission have the statutory authority to require a given large ILEC to build and operate transmission facilities for the purposes of establishing connectivity with such a PSAP and, if yes, what is the statutory basis for such authority? In answering this question, account for situations where the relevant large ILEC does not operate as a competitive local exchange carrier in the territory where the PSAP would be physically located.
  6. In the event that SILECs are reclassified as ONPs for the purpose of NG9-1-1 implementation, would the Commission be required to:
    1. Issue interconnection orders in order for the SILECs to interconnect with a large ILEC for the purposes of NG9-1-1? Would similar orders need to be applied to other Local Exchange Carriers operating outside the large ILECs’ incumbent operating territory?
    2. Amend the existing conditions of service imposed on ONPs and telecommunications service providers with regards to the delivery of their NG9-1-1 traffic?
    3. Amend any terms and conditions in the large ILEC’s NG9-1-1 tariffs?

Provide all relevant details.

  1. Provide your views on any additional impacts that would result from the reclassification of SILECs as ONPs for the purpose of NG91-1 implementation not captured by the RFIs above.

All responses to the above RFIs are to be filed with the Commission by 7 June 2022. Consequently, the intervention and reply deadlines for the underlying TELUS Part 1 application are extended to 21 June 22 and 4 July 2022 respectively. Commission staff requests that all responses to the RFIs include complete supporting evidence and rationale.

Parties to the TELUS Part 1 application may respond to answers provided by other parties to the above RFIs as part of their interventions. Parties who filed interventions with the Commission prior to receiving these RFIs may submit an amended intervention.

Furthermore, the Commission is in receipt of an intervention filed by the Independent Telecommunications Providers Association (the ITPA) on behalf of its members. This intervention, which is dated 5 May 2022, is restricted to procedural concerns. The ITPA is invited to file an updated intervention that responds to the substance of TELUS’ application.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementations
Telecommunications

c.c.:   Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca
Independent Telecommunications Providers Association

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