Telecom - Staff Letter addressed to the Distribution List

Gatineau, 7 May 2025

Our Reference: 8665-C12-201507008 8621-C12-01/08

BY EMAIL

Distribution List

Subject: Request for Information regarding the Introduction of Emergency Location Service for Wireless Service Providers

In Telecom Decision 2023-235, the Commission directed the adoption of the Emergency Location Service (ELS) aggregation model whereby Bell Canada (Bell) and TELUS Communications Inc. (TELUS) act as national aggregators, including in Saskatchewan Telecommunications’ (SaskTel) territory.

To support ELS, the Commission also directed facilities-based wireless service providers (WSPs) to reconfigure their existing next-generation 9-1-1 (NG9-1-1) interconnections to Bell and/or TELUS, and new facilities-based WSPs to establish interconnection to Bell and/or TELUS.

On 28 March 2024 and 18 April 2024 respectively, TELUS and Bell filed tariff notices (TN) to incorporate the provision of ELS into their tariffs. TELUS filed TN 589 to revise its General Tariff (CRTC 21461), Item 1001, Next Generation 9-1-1 service. Bell filed TN 983 to revise its National Services Tariff (CRTC 7400). The Commission approved these tariffs on an interim basis in Telecom Order 2024-97.

On 6 September 2024, in response to a 16 August 2024 staff request for information (RFI), Bell and TELUS confirmed that ELS is available for facilities-based WSPs in SaskTel’s territory.

TELUS and Bell’s responses to the staff RFI notwithstanding, it is Commission staff’s understanding, based on a recent ESWG letter, that while national WSPs should interconnect to both Bell and TELUS for the purpose of ELS aggregation, regional WSPs need only connect to either Bell or TELUS, depending on which territory they are operating in. However, based on responses to staff’s RFI on 16 August 2024, it is also staff’s understanding that neither Bell nor TELUS account for Saskatchewan-based wireless customer counts in their tariffs.

In light of this, staff is seeking clarification from parties to better understand the provision of ELS aggregation services in Saskatchewan.

In that respect, the process and associated dates are as follows:

• Commission staff requests that each of the applicants individually submit their respective responses to the attached RFIs no later than 21 May 2025.
• Parties can submit comments with respect to the response(s) to the attached requests for information, by 4 June 2025.
• Parties may file replies to the above-noted comments by 11 June 2025.

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.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, 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 Étienne Robelin for

Suneil Kanjeekal
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.: Chris Noonan, CRTC, chris.noonan@crtc.gc.ca
Stais Armstrong, CRTC, 819-775-0401, Stacey.Armstrong@crtc.gc.ca
Daniel Cardozo, CRTC, 819-962-5720, Daniel.Cardozo@crtc.gc.ca
Landon Entwistle, CRTC, Landon.Entwistle@crtc.gc.ca

Attach. (2)

1. Distribution List
2. Request for Information (RFI) Questions

Distribution List

National ELS Aggregators

Bell Canada, bell.regulatory@bell.ca
TELUS Communications Inc., regulatory.affairs@telus.com

Wireless Service Providers

Saskatchewan Telecommunications, document.control@sasktel.com

Intervenors

Rogers Communications Canada Inc., regulatory@rci.rogers.com
Quebecor Media Inc., regaffairs@quebecor.com

Requests for Information (RFI)

Questions for Saskatchewan Telecommunications (as a regional WSP)

• Q1. Identify which ELS aggregator(s) SaskTel (WSP) uses to obtain ELS location data in Saskatchewan.
• Q2.
  1. Provide a copy of all agreements, relevant tariff pages and supporting documentation with the aggregator(s) that detail how SaskTel obtains ELS location data.
  2. If there are no such agreements in place, explain how SaskTel obtains its ELS location data.

Questions for Bell Canada (as national ELS aggregator)

• Q3. For the following questions, refer to page 3 of the file, “16 August 2024 - 240906-Bell Canada(CRTC)16Aug24-1 TN 983”, wherein Bell Canada states, in respect to Bell Canada National Services Tariff (NST), CRTC 7400, Item 602 – Advanced Mobile Location (AML) Service (Bell NST Item 602):

  “… we have chosen not to implement new processes to charge for this service outside our incumbent operating territories.”

  1. Identify which, if any, WSPs operating in Saskatchewan use ELS aggregation services from Bell Canada.
  2. Identify the applicable section of Bell NST Item 602 and provide copies of all arrangements and other supporting documentation that outlines Bell Canada’s provision of ELS aggregation services to WSPs operating in Saskatchewan.
  3. In light of Bell Canada’s responses to Q3 a) and Q3 b) above, would it be necessary for Bell Canada to refile Bell NST Item 602 to include the provision of ELS aggregation services to WSPs in Saskatchewan? The response, whether in the affirmative or negative, must include appropriate evidence and supporting rationale.
  4. If Bell Canada believes there is any additional information or documentation relevant to the provisioning and delivery of ELS aggregation services in Saskatchewan, include such information or documentation in Bell Canada’s response.

Questions for TELUS Communications Inc. (as national ELS aggregator)

• Q4. For the following questions, refer to the file, “16 August 2024 - TELUS_CRTC_16Aug24_1”, wherein TELUS states, in respect to TELUS General Tariff CRTC 21461, Item 1001 – Next Generation 9-1-1 Service. (TELUS GT Item 1001):

  “TELUS confirms that it is providing ELS for facilities-based WSPs in SaskTel’s territory, as per the directives outlined in Telecom Decision 2023-235.”

  1. Identify which, if any, WSPs operating in Saskatchewan use ELS aggregation services from TELUS.
  2. Identify the applicable section of TELUS GT Item 1001 and provide copies of all arrangements and other supporting documentation that outlines TELUS’ provision of ELS aggregation services to WSPs operating in Saskatchewan.

  3. On page 2 of the referenced file, TELUS stated:

     “TELUS estimates that incorporating Saskatchewan's wireless demand would reduce the monthly rate by approximately 10% from the currently approved interim rate of $0.0073.”

     TELUS further stated:

     “[should] the Commission determine that a modified tariff is appropriate, TELUS is prepared to submit an updated cost study and tariff pages in accordance with the Commission's determinations in this matter.”

     In light of TELUS’ statements above and its responses to Q4 a) and Q4 b), file an updated cost study and indicate if it would it be necessary for TELUS to refile TELUS GT Item 1001 to include the provision of ELS aggregation services to WSPs in Saskatchewan. The response, whether in the affirmative or negative, must include appropriate evidence and supporting rationale.

  4. If TELUS believes there is any additional information or documentation relevant to the provisioning and delivery of ELS aggregation services in Saskatchewan, include such information or documentation in TELUS’ response.

Date modified:

2025-05-07