ITPA wants national NG911 rate; incumbents tell CRTC not to use, or to limit, funding

The Independent Telecommunications Providers Association (ITPA) is suggesting to the CRTC that it establish a single low national next-generation 911 (NG911) rate for all Canadians, because having different rates between service providers competing for the same customers “will have a detrimental impact on competitive market forces.” The ITPA filed its comments May 24 in a reply to a CRTC consultation on funding the rollout of NG911 service through the National Contribution Fund (NCF). The CRTC estimated that funding NG911 could add approximately $55 million annually to the NCF for the next five years. When telecom service providers (TSPs) filed tariff notices for the deployment of NG911, the regulator noticed that costs were higher in certain regions of the country. The suggested tariffs for the large ILECs ranged from $0.0951 to $0.22. ITPA took the position that the rate should be set at the lowest large ILEC rate and any NG911 network providers that cannot recover all their costs should then be eligible for subsidization through the fund. Telus, in its April intervention, asked the CRTC to postpone the consultation and instead reclassify small incumbent local exchange carriers (SILECs) from its current status as NG911 service providers. The incumbent argued SILECs lack the expertise needed to self-provide the service. Telus Corp. reiterated in its May 24 reply that if the request is adopted it would “drastically reduce” NG911 costs “and is the best way to address the affordability concerns” raised by the CRTC. In its current reply, the ITPA said it would not comment on that issue because in early May it had already argued to the commission that Telus’ request is “five years too late”. The ITPA said at the time that negotiations have already begun, it will harm the public interest, and “make a mockery” of the commission’s processes. Quebecor Inc., Le Comité 911 du Syndicat canadien de la fonction publique au Québec, Xplornet Communications Inc., Shaw Communications Inc., Rogers Communications Inc., SSi Micro Ltd., and Saskatchewan Telecommunications Holding Corp. all supported Telus’ request. The Public Interest Advocacy Centre (PIAC) recommended that only select parties be eligible for the fund. The organization supported the use of the fund but insisted that it would be “extremely disruptive and challenging” to cover all NG911 costs and have the fund apply to all ILECs. PIAC recommended the fund only cover SILECs’ NG911 costs, specifically those that cannot be recovered through a reasonably priced tariff. PIAC further suggested that if other ILECs’ tariff rates, aside from SILECs, exceed the lowest approved SILEC rates, then those ILECs should seek the difference between their tariff rate and the lowest SILEC rate from the fund. “Our main concern is the delay in the eventual rollout of the NG911 service that may result from covering all NG911 costs,” PIAC wrote. Shaw Communications Inc. opposed the ITPA’s and PIAC’s positions, with the latter arguing in its intervention that the fund will “provide much needed clarity and transparency as to what 911 funds are needed and how they are spent.” Both Shaw and SaskTel said that if the commission does not grant Telus’ request, the commission should still deny the use of the fund or use it only for high-cost situations with end-users paying some amount. Shaw argued that it will not see “any prospect of improved transparency” if the commission were to use the fund because NG911 network providers will presumably claim that its financial information is confidential. According to Shaw, contributing service providers will have little insight into how the NG911 network providers were using their disbursements. “We also believe that it is not necessarily a deficiency of the tariff process itself that gave rise to the unjust and unreasonable rates proposed by the ITPA’s membership,” Shaw wrote, noting that Rogers Communications Inc. argued in its intervention that without meaningful financial information, ITPA’s SILECs’ rates appear to be “grossly inflated.” Shaw also told the CRTC it should wait until it decides to reclassify SILECs as originating network providers (ONPs) within its NG911 ecosystem and until it has a chance to review NG911 cost studies. “Given that the commission’s review of the ILECs’ and SILECs’ cost studies is still underway, the commission should not assume that their NG9-1-1 rates will not change,” the company wrote. Shaw noted that SaskTel initially proposed a wholesale NG911 access fee of $0.2193 but after review it found errors in its initial application that resulted in a lower fee of $0.1828. “There could very well be errors in the SILECs’ cost studies that are contributing to their excessively high rates,” Shaw argued. SaskTel raised concern that the proposed cost-recovery method would also finance events not directly linked to NG911 emergency services. “We suggest that SILEC customers pay only the amount that customers of the ILEC providing service in that geographic area pay, with the remainder to be funded via the NCF,” SaskTel wrote. Bell, in its May 24 reply, also agreed that the CRTC should limit the funding to essential costs that cannot be recovered through reasonable tariffed rates. Bell suggested that the rate for SILEC operating territories be set at $0.45 per network access services (NAS) per month. “Should our proposal be adopted, we estimate that the required increase to the NCF would be approximately $2 million, which is a significant increase. However, such an increase is significantly less than the estimated $55 million… and is unlikely to cause an undue hardship on any provider,” Bell wrote. – Reporting by Jenna Cocullo at jcocullo@thewirereport.ca and editing by Michael Lee-Murphy at mleemurphy@thewirereport.ca.

ITPA wants national NG911 rate; incumbents tell CRTC not to use, or to limit, funding

News | May 25, 2022

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ITPA wants national NG911 rate; incumbents tell CRTC not to use, or to limit, funding

News | May 25, 2022

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