CONTRIBUTION: ESCO0410

DATE: July 5, 2012

WORKING GROUP: Emergency Services Working Group (ESWG)

TITLE: Contribution for ESTF0071: Evaluation of the Proposed VoIP Solutions Inc. – Emergency

Information Informer (ELI) Methodology as Directed In the Letter Request from the

CRTC Chairman on December 22, 2011.

ISSUES ADDRESSED:

Part 1: Response to ESCO0406 Contribution from Canadian Cable Companies

Part 2: Response to ESCO0407 Contribution from Bell Canada

Part 3: Response ESCO0404 Response to Contribution from Ken Sluman

SOURCE: Peter Woodford

VoIP Solutions Inc.

Peter.woodford@voips911.com

DISTRIBUTION: All ESWG members on distribution list

NOTICE: This contribution has been prepared by VoIP Solutions to assist the Emergency Services

9-1-1 Working Group as a basis for discussion. This contribution should not be construed

as a binding proposal by VoIP Solutions or any other 9-1-1 Service Provider. Specifically,

VoIP Solutions reserves the right to amend, modify or withdraw this contribution at any

time.

Part 1

Response to ESCO0406 Contribution from Canadian Cable Companies

Response to ESCO0406 Contribution from Canadian Cable Companies (NOTE: excerpts of

original contribution are in black text, VoIP Solutions Comments are in blue text) Background: ESCO 0406 was presented by the contributors on a June 1 TIF 71 conference call by Peter Lang. It is important to note that only the persons indicated above were consulted in preparation of this document. As many of the comments in this document are directly related to “opinions’ of engineering, of manufacturers’ of edge equipments position and the positions of small Canadian ISP’s, it is very important to remember that NONE of these groups were consulted in the preparation of ESCO 0406. 3) Scope of Proposed Solution

1. To provide access to 9-1-1 service for all nomadic and fixed/non-native local VoIP service subscribers, the proposed solution requires that all ISPs in all regions, even those regions in which they are not Local Exchange Carriers, establish 9-1-1 agreements with the local 9-1-1 Service Provider. The regulatory framework to establish this does not exist today.

Response: If a telecommunications company wishes to provide telephony services and register those telephone numbers to the 9-1-1 database they must either become a CLEC/LEC which enables them to do so, or they must establish an agreement with the local 9-1-1 services provider. This process and regulation is in place and is quite clear. It is important to note that all companies contributing to this document provide internet services and voice services. Additionally, the number of ISP’s that provide internet services and no voice would account for a very small percentage of the overall Canadian Market, less than 10% of market. Also, CRTC 2012-137 has broached this arena by requiring carriers to re-sign contracts with ISP that provide telecom services to VoIP services providers 2. VoIP Solutions Inc. has indicated that encryption at any point in the VoIP call from the end device, to the VoIP SP, to the ELI database could cause the proposed solution to fail. Since the Cable Carrier has no control over the VoIP SP, there is no guarantee that the proposed solution would work. Response: VoIP Solutions' has not indicated that encryption at any point in the VoIP call would cause the solution to fail; quite to the contrary, the ISP methodology proposed is secure from end to end. The only portion of the call that WILL not be encrypted is the call setup portion which takes place in a secure environment and as such poses no security threat. Call encryption during the rest of the call pathway is recommended. 3. Unlike the circuit switched 9-1-1 system where calls can be delivered to the PSAP regardless of whether the ALI database is working, 9-1-1 calls over the VoIP Solutions system will not be delivered if the ELI database is offline for any reason. Response: The ISP methodology does not impact this scenario whatsoever; when the ISP Methodology Server/gateway presents an emergency call to the telephone network with an ANI it is treated in exactly the same way as a regular telephone line 911 call. The Selective Router determines which PSAP to route the call. If the ALI database is not working the call will be routed to the correct PSAP in exactly the same fashion as for a telephone line 911 call but will arrive to the PSAP without the ALI information. The call WILL BE delivered to the correct PSAP in the event of an ALI database failure. If the ELI database is down, the call would be routed to the PSAP for the area in which the server is located; it will not have correct address but will be delivered to a PSAP. With designed redundancy, this would be a rare occurrence, but is still better than current VoIP 9-1-1.

4. The VoIP Solutions proposal does not support softphones, Wi-Fi or wireless VoIP.

Response: The ISP methodology proposed by VoIP Solutions does work for softphones and for WiFi. The capability was demonstrated for ESWG at the Face to Face in Toronto as well as in the audited test results provided. It was also discussed that an enterprise and OTT cellular data versions of the same would be available shortly, but the ESWG has not been tasked to review those components. Please note, in the Face to Face demo, the internet connection utilized was a WiFi enable Bell LTE connection. The ISP Methodology works over wireless data, but unless the wireless data connection is static, the civic address will not be reliable. Example: Motorola Canopy that has been used for much of rural broadband roll outs in Canada. 4) Assessment 5. The Cable Carriers’ cable modem networks are not exposed to the Internet. This would mean that the ELI Server would need to be hosted on the Cable Carriers network. This is a fundamental change in design and raises some major security risks. Cable Carriers modems are connected via one port with multiple subnets, typically a minimum of two. One sub-net is not exposed to the internet and is utilized for Cable maintenance, provisioning and diagnostics. The other sub-nets are exposed to the internet to enable cable customers to surf the web. This will be the subnet connection the ISP Methodology edge client utilizes to communication with the server. This does not create a security breach as this is done utilizing a standard firewall or encrypted proxy. 6. At the present time we are not aware of any CableLabs® compliance/development work for embedded ELI functionality in DOCSIS specifications. DOCSIS® and PacketCable do not currently include provisions, to support the execution of third-party applications such as the ELI software proposed by this solution on a cable modem or embedded multimedia terminal adapter. The development of the DOCSIS specifications and the ensuing certification process will take a considerable amount time and then and only then will we be able to assert the availability of edge devices. Response: Cable Labs compliance and Docsis, Packet Cable are related to hardware design, configuration and build. The ISP Methodology as proposed by VoIP Solutions relies upon a software application (Not a hardware reconfiguration) on the edge device. Current era edge devices are responding to the ISP’s demands for more intelligent edge devices to drive higher quality internet experiences such as Fibre Op, higher speed cable connections, and other applications. The ISP Methodology edge client is one such application and does not impact the aforementioned standards. 7. In response to questions raised by parties at ESWG (refer to ESCO0388A for Q and A’s) regarding existing edge devices currently capable of supporting the ELI software, VoIP Solutions Inc. stated that the “brand makes and models are limitless”. However, VoIP Solutions Inc. has not provided information regarding any necessary capabilities or pre-requisites for the environment in which the ELI software will run. Thus, there is insufficient information to assess whether any existing device could actually support the proposed solution. Furthermore, for interoperation in cable networks, device vendors must have CableLabs® certification before any cable operator would ever consider upgrading or replacing any cable modem / edge device. Response: As indicated above, the ISP Methodology calls for a software application on the edge device not a hardware reconfiguration or upgrade. Current era edge devices are designed to operate additional edge applications to drive revenues for ISP’s – the ISP Methodology edge client is one such application. The current demo setup shown at Face to Face was operated on a 7 year old device which has approximately 200MHZ Broadcom CPU with a MIPS 32 processor. Load testing on this antiquated devoice revealed a 3.3% utility of overall processing capacity when

device was operating at maximum throughputs. If, as indicated below, Canadian Cable companies source the best and most cost effective edge devices this will present an issue. There has been no indication tha we would fail CableLabs compliance. 8. To effectively offer wide-scale deployment of consumer broadband, cable modems and eMTAs employed by cable operators are specifically and purposefully built by vendors with low amounts of memory and processor capabilities to keep costs low – thus these devices do not have the type of processor horsepower necessary for the level of deep packet inspection proposed by this solution. In fact, even for our own purposes, the DOCSIS® specifications only call out rudimentary filtering capabilities based strictly on IP Protocol, Source/Destination IP Address, ToS, or Source/Destination MAC address. They currently do not have the ability to inspect application layer headers as proposed by this solution. eMTA: Embedded Multi Terminal Adaptor – Response: As indicated above, the ISP Methodology calls for a software application on the edge device not a hardware reconfiguration or upgrade. Current era edge devices are designed to operate additional edge applications to drive revenues for ISP’s – the ISP Methodology edge client is one such application. Each manufacturer has established protocols for the provisioning of software on their devices, as such we are unable to specify at this time without knowledge of particular devices. Current edge devices likely cannot inspect application layer headers; that is what the ISP Methodology software running on the device will do. Load testing performed on the WRT54G Linksys router, designed in 2004, with the ELI ISP methodology Edge software, showed minimal degradation in edge device performance due to software edge client operation: a less than 1% (0.82%) degradation at 25 MB, or 80% of total capacity of the device. At 29 MB, 97% capacity, there was a 3.3% degradation in performance. Most internet connections in Canada cannot provide a high enough data stream to establish a measureable impact. 5) Operational Assessment 9. Today cable modems are assigned configuration files in the provisioning process that are defined by the subscriber service level. In the proposed solution, every subscriber would require a unique configuration file that associates it to the correct ELIN server for the region while also maintaining the correct service level – this is a massive change to the provisioning processes for all cable modems. There is a variety of existing provisioning mechanisms such as DHCP that are capable of simplifying any provisioning processes. The type if DHCP option to be selected, in most cases, will be selected to match up with each individual Cable Company’s current processes and those recommended by the manufacturer of their selected edge devices. 10. VoIP Solutions Inc. has indicated that the ELI software running on the subscriber device will be provisioned by an automated process. It is essential to provision the ELI software because any given instance may have a different 9-1-1 region and thus a different ELIN Server with which to associate. However, VoIP Solutions Inc. has not provided any guidance as to how exactly this provisioning process would take place, what specifications the provisioning process might follow, nor how to indicate to vendors the necessary sequence. Thus, there is insufficient information to assess the entire impact to existing provisioning processes. Each edge equipment manufacturer will have it s own provisioning protocols. The ELI provisioning procedure is flexibly designed to utilize a variety of such protocols. EX: DHCP 6) North American Standards 11. Canadian Cable Carriers currently source their equipment from manufacturers who serve the North American market and as such follow US standards development. As a result, such equipment vendors are unlikely to expend large amounts of resources and capital to take into account the development of an isolated standard specific to a solution adopted in Canada with a great deal of uncertainty whether it will be adopted in the U.S. The Cable Carriers therefore submit that the interface requirements as proposed by VoIP Solutions Inc. raise serious questions about the future capabilities of Canadian Cable Carriers to

continue to serve their customers using the most advanced, least costly equipment that can be purchased in the North American market. Response Please see items 6, 7 and 8 above. The suppliers to the Canadian cable companies, manufacture and sell equipment globally, not just in the Canadian market. As indicated they are manufactured to meet certain standards and protocols. The ISP methodology as presented is very much in line with the existing ISP edge device model and with activities taking place globally. If the Canadian Cable companies have, as indicated, sourced the most advanced and cost effective equipment on the North American market, they will have NO problems with their selection of equipment being capable of operating the edge client software as indicated in the ISP methodology. The edge device utilized for demonstration purpose was designed in 2004, has minimal processing capability and can operate with minimal performance impacts fron the ISP methodology edge client software up to 30MB. 12. Even if the specifications could be adapted and the vendors could be enticed to produce product, the Cable Carriers are likely to face upgrade and or replacement of existing deployed devices which would carry considerable expense. Response: THE ISP Methodology demonstrated and tested was operating on an edge device that is 7 years old. The edge client only requires a small portion of the operating system on this antiquated edge product. As the Canadian Cable Companies have indicated, they source the most advanced and cost effective equipment available; if this is in fact correct, they will have no issues with ISP Methodology operating on their current edge devices. As such, replacement or upgrades should not be necessary. 13. Additionally, the Cable Carriers risk massive future retrofit costs, up to and including additional modem replacement costs, if Canada later decides to conform to the NENA i3 standards which ultimately will be developed in the United States, Response:

NENA NG 9-1-1 i3 08-003

2. Network Access Network Providers (e.g.: DSL providers, fiber

network providers, WiMax providers, Long Term Evolution (LTE)

wireless carriers, etc.) have installed, provisioned and operated some

kind of location function for their networks. Location functions are

critical for 9-1-1 calls originating on an IP network because it provides

a 9-1-1 valid location to IP clients that bundle their location in the SIP

signaling to the ESInet

3. All calls entering the ESInet will normally have location information.

8.Since the legacy circuit-switched TDM network will very likely

continue to be used for the foreseeable future (both wireline and

wireless,) the i3 architecture defines a Legacy Network Gateway (LNG)

to interface between the legacy network and the ESInet

The ISP methodology proposed is comprised of two essential elements, an edge software client and a server/gateway (attached ELI NG 9-1-1 diagram). The edge client is provisioned by the ISP who validates the accurate civic address and ANI. The edge client recognizes when an emergency call is made, routes it through the VSP to the

server/gateway. The server gateway has the validated civic address (and other information) regarding the 9-1-1 call; it delivers the required information in the required format based upon the requirements of the 9-1-1 system. If it is a legacy system, it will provide an ANI to the legacy ILEC/9-1-1 service provider who routes the call through the system to the correct PSAP according to established protocols. If it is an NG 9-1-1 system, it provides the accurate civic address to the NG 9-1-1 system in the required format to the required location (LIS). The NG 9-1-1system takes this information and routes it through the NG 9-1-1 system according to established/or to be established processes. As such, the ISP Methodology is legacy and NG 9-1-1 compliant; therefore, it enhances Canada’s ability to work toward a transition from legacy to NG 9-1-1 by providing an immediate, short medium and long term solutions for VoIP Emergency Calling.

7) Cost Issues 14. There is insufficient information to adequately assess the entire costs associated with implementing the solution proposed by VoIP Solutions Inc. but the number of unknowns suggests that it could be enormous. It is not just the $1 per month per connection fee from VoIP Solutions. There are many unknowns, including whether the cable modems or edge devices will need to be upgraded or worse replaced, establishment of national-scale infrastructures to support the ELI infrastructure, such as the PRIs, gateways, or ELIN servers for each 9-1-1 serving area, on-boarding of 9-1-1 processes for Internet service areas where the ISP is not a CLEC, and the new provisioning processes for cable modems with unique configuration files for each device. Response: Please refer to items 6, 7, 8 11 and 12 above. If the Canadian Cable Companies, as they have indicated, they source the most advanced and cost effective equipment available, they will have no issues with ISP Methodology operating on their edge device and as such no upgrade or replacement costs associated with this methodology. The cost and deployment of “national scale” infrastructures such as PRI’s and gateways are commonplace activities and will be undertaken to meet or exceed industry standards by VoIP Solutions and WILL NOT be the responsibility of ISP’s. ELIN Servers (ISP Methodology Server/Gateway) for each 9-1-1 service area will remain intact and unchanged as will provisioning process for the configuration profiles for each edge device. “Onboarding” of 9-1-1 process for an ISP that is not a CLEC will only be unique if that ISP does not currently offer voice services. CRTC documents these companies represent less than 10% of market. Additionally, CRTC Decision 2012-137 has already have broached that space and process or regulation. As such, these issues are overstated and will pose no significant investment of change. 15. Significant additional analysis would be required to determine the overall costs of this proposal to the Canadian industry (ISPs, 9-1-1SPs as well as the underlying broadband service providers). There has been no discussion on how the parties would be able to recover their share of the overall costs. Response: Overall cost to Canadian Industry: ISP Edge client software is provided at no cost to the ISP’s to deploy. The ISP Methodology Server’Gateway network is deployed and paid for by the ISP methodology Service provider, in this case VoIP Solutions. This methodology utilizes existing 9-1-1 infrastructure and is also integratable into NG 9-1-1 (see 13 above and attached diagrams). This means the cost to deploy this ISP Methodology in Canada is MINIMAL as will be the transition to NG 9-1-1. Proposed method for 9-1-1 service providers cost recovery: ISP - $0.50/internet connection/month PSAP agencies (Provinces/Municipalities etc) $0.50/internet connection/month ISP Methodology Supplier $1/internet connection /month As indicated, all stakeholders in the 9-1-1 service delivery chain will participate in the funding process. This will offset 9-1-1 revenues lost by telephone line/fixed VoIP line loss and will also

enable funding for upgrades to NG 9-1-1 components. 8) Interconnection 16. In current Canadian implementations, a single PRI can only belong to one and only one 9-1-1municipal 9-1-1 serving area. Thus, there would necessarily need to be ‘at least’ one PRI for every 9-1-1 area and probably two for reliability. Areas with an NPA overlay also have separately defined serving areas. For example, Ontario areas served by Bell alone would necessitate a minimum of 1,172 new PRIs for the proposed solutions. VoIP Solutions has provided no information on the appropriate interconnection points. Response: The ISP methodology calls for the ISP Methodology/ELI server gateway to connect via PRI to a central office. Each area serviced by a Selective Router will require a PRI server connection (plus appropriate backup configurations to meet or exceed industry standards). As confirmed by Bernard Brabant, in the Ontario Region referenced, there are 12 selective routers, necessitating 12 PRI connections, plus required backups, for the region indicated. This a more than a manageable number. 17. Furthermore, since PRIs are delivered ‘in the market’ from the switch that serves the exchange, the solution would require either gateways in every market (thousands of gateways would need to be installed and maintained across the country) or the solution would requires that thousands of PRIs are backhauled over long distances to centralized ’regions’. Overall, either approach creates a very complex design and integration that is unlikely to be reliable. Response: The ISP methodology calls for the ISP Methodology/ ELI server gateway to connect via PRI to a central office. Each area serviced by a Selective Router will require a PRI server connection (plus appropriate backups).The overall design is rather simple and mimics the Selective Router map for Canada. 18. Not every Internet Service Provider offers phone service, so these PRIs would represent a substantial change to their networks and technical capabilities. Furthermore, even Internet Service Providers that do offer phone service in some areas don’t support phone service in all the areas where they operate, so these PRIs would again represent substantial technical and facilities changes to their network and processes. Response: The ISP methodology calls for the ISP Methodology/ELI server gateway to connect via PRI to a central office. Each area serviced by a Selective Router will require a PRI server connection (plus appropriate backups). These PRI’s are not the responsibilities of the ISP but the ISP Methodology Provider (VoIP Solutions) to source these from a supplier. As indicated 16, 17 & 18 above, the ELI Server design mimics the Selective Router map for Canada and is simple and manageble to implement, interconnect and maintain. 9) Conclusion 19. In summary, the Cable Carriers cannot support the VoIP Solutions proposal. As IP to IP Interconnection is in the early stages of being mandated, and as the Commission has directed the CISC to continue to work on NG9-1-1, a more comprehensive solution will likely be developed in the coming years making the VoIP Solutions Inc. proposal an interim solution. At this point, there are no discernible timelines for the proposed VoIP Solutions Inc. implementation and the cost is expected to be high. For these same reasons, the Canadian i2 solution was rejected (i.e. high cost, short lifetime before obsolescence), so should this proposal be rejected. It is more practical to focus financial and human resources on developing the more comprehensive and reliable NG9-1-1 solution than to spend time implementing this limited and under-developed proposal.

Conclusion: The comments and assumptions made in ESCO 0406 are the opinions of the authors and were made, admittedly, without expert opinion from small ISP’s, Engineering nor Equipment Manufacturers. To make claims on their behalf without consult is not appropriate or acceptable and has lead to inaccurate assumptions. NG9-1-1 is currently a work in progress and to date does not have an accurate and automatic civic address provisioning technology for nomadic VoIP except for VoIP Solutions ELI, as outlined in ISP Methodology. ESCO 0386 diagram titled ELI and NG 9-1-1 (Attached) and items 13 above clearly outlines ELI’s compatibility with NG 9-1-1 and the existing 9-1-1 legacy system and the ISP Methodology/ ELI complies with NENA i3 08-003 standard. As such this methodology is not an interim, but an immediate and long term solution. The costs to implement will only be a concern if the ISP has antiquated equipment, to the extent that it is significantly less capable than a circa 2004 edge that can operate this methodology at 97% capacity with less than 3.3% impact on performance. The ISP methodology proposed has a minimal implementation costs, is legacy and NG 9-1-1 compliant, had a design and connectivity that mimics the current Selective Router network design, and will advance Canada’s commitment to become NG9-1-1 compliant. As such, the Canadian Cable companies’ claims have not been substantiated as accurate nor factual; the conclusions cannot be accepted as valid.

Part 2

Response to Bell Contribution ESCO0407

Part 2 Response to Bell Contribution ESCO0407 (NOTE: excerpts of original

contribution are in black text, VoIP Solutions Comments are in blue text)

Conclusion

29. Based on all the above, the Commission concludes that the implementation of Ci2 is not viable due to

Ci2’s technical limitations in the face of evolving 9-1-1 technology, decreasing demand for and usage of

nomadic VoIP service, and the cost of Ci2 implementation.”

Following Telecom Decision 2005-21 the Emergency Service Working Group spent the next 5 years

assessing numerous VoIP solutions culminating with a non consensus report recommending a NENA i2

model with modifications suggested for use in Canada (Ci2). During the early stages of VoIP E911

solution considerations ESWG did briefly consider a “software” solution similar to the one proposed here.

It was quickly concluded that such a solution would be unfeasible and impractical and was subsequently

excluded from the VoIP Solution Matrix that was assessed by ESWG. Following a costing proceeding for

Ci2 as ordered by the Commission by numerous parties, the solution was ultimately rejected based on 3

criteria:

1. Technical limitations in the face of evolving 9-1-1 technology

2. Nomadic VoIP demand

3. Cost of E9-1-1 VoIP solution

Before a rigorous technical assessment is undertaken, Bell believes an overall assessment should be

performed in order to assess initial viability and offers this analysis under the category of Other as

requested by the Commission.

2. Proposed Solution

1. Technical limitations in the face of evolving 9-1-1 technology

The solution as proposed does not provide a clear evolution towards NG911 which is the logical and

stated progression of E911 service in Canada as noted in Telecom Decision 2010-387. In order to support

many of the proposed changes, new interfaces and systems will need to be developed to support routing,

validation and other E911 functions. The solutions offered in Ci2 are based on key systems that lead into

and support i3 and NG911. The interfaces and systems required to support this proposal are essentially

throw away systems that provide minimal future benefit with respect to the current direction of NG911.

1. a. ISP Methodology proposed does not enhance the direction towards NG 9-1-1

Response: The CRTC and Bell are clear; Canada is moving towards Next Generation 9-1-1. As

indicated in ESC0386 the ISP Methodology proposed is in line with NG 9-1-1:

“NENA NG 9-1-1 i3 08-003:

2. Network Access Network Providers (e.g.: DSL providers, fiber network providers, WiMax

providers, Long Term Evolution (LTE) wireless carriers, etc.) have installed, provisioned and

operated some kind of location function for their networks. Location functions are critical for

9-1-1 calls originating on an IP network because it provides a 9-1-1 valid location to IP clients

that bundle their location in the SIP signaling to the ESInet

3. All calls entering the ESInet will normally have location information.

4. Since the legacy circuit-switched TDM network will very likely continue to be used for the

foreseeable future (both wireline and wireless,) the i3 architecture defines a Legacy Network

Gateway (LNG) to interface between the legacy network and the ESInet”

The ISP methodology proposed is comprised of two essential elements, an edge software

client and a server/gateway (attached ELI NG 9-1-1 diagram). The edge client is

provisioned by the ISP who validates the accurate civic address and ANI. The edge client

recognizes when an emergency call is made, routes it through the VSP to the

server/gateway. The server gateway has the accurate civic address (and other information)

regarding the 9-1-1 call; it delivers the required information in the required format based

upon the protocols of the 9-1-1 system it is integrating with. If it is a legacy system, it will

provide an ANI to the legacy PSTN where the ILEC/9-1-1 service provider routes the call

through the system to the correct PSAP according to established protocols. If it is an NG 9-

1-1 system, the ISP methodology provides the accurate civic address to the NG 9-1-1 system

in the required format to the required location (LIS). The NG 9-1-1system takes this

information and routes it through the NG 9-1-1 system according to established/or to be

established (NG 9-1-1) processes.

The ISP Methodology is legacy and NG 9-1-1 compliant; therefore, it enhances Canada’s

ability to work toward a transition from legacy to NG 9-1-1 by providing an immediate,

short, and long term solution for VoIP Emergency Calling.

b. Is not compatible with IP PSAP’s

Response: As indicated in ESCO 0386, the attached ELI diagrams and above, the ISP

methodology does not connect to PSAP’s (legacy or IP Enabled); in a legacy environment

the IP methodology sends a POTS 9-1-1 call to a central office with an ANI, where upon the

ILEC/911 Services provider routes the call according to the protocols they have established.

In a NG 9-1-1 environment, the ISP methodology delivers the call and required address

location to the front end of the NG 9-1-1 system (LIS) whereby the NG 9-1-1 system then

processes and routes the call according to the processes inherent with NG 9-1-1.

c. Has emergency call routing challenges

Response: As indicated by the attached diagrams and above, all emergency call routing is

controlled and determined by the ILEC/9-1-1 services provider.

As such, the proposed methodology is very much in line with the NG 9-1-1 direction Canada

is going. The Methodology does not connect directly with legacy or IP Enabled PSAP, but

with the legacy and NG 9-1-1 systems that support and provide the required information to

IP enabled PSAP’s. Emergency call routing is the responsibility of the ILEC/Regional 911

services provider. The proposed methodology provides the required information in the

required format as established by the ILEC/911 services provider who routes the

emergency calls as they do currently (or in NG 9-1-1 evolved system), so there is NO impact

on emergency call routing.

2. Nomadic VoIP demand

In 2010, the nomadic VoIP demand was estimated to be approximately 200K-400K subscribers. This

estimate remains the same in 2012 therefore there is no additional demand above and beyond what was

reviewed in the 2010 proceedings.

Response: As indicated by the Contribution author statistical data reference on the Nomadic VoIP

demand come from research done for the Ci2 evaluation. James Ndirangu confirmed this data was

sourced from the CRTC Communication Monitoring Report. Attached is a CRTC Monitoring

report that shows Nomadic VoIP usage (Access Independent VoIP lines in 5.2.1 of the document) at

161,000. Appendix 8 lists the companies contributing to this report. Note that no VSP’s

contributed; not even included is Comwave, the Canadian company the CRTC, after an

investigation, found responsible for VoIP 9-1-1 failure that lead to a loss of life. The 161,000

nomadic VoIP users are from the traditional telecommunications providers whose primary

business is NOT VoIP. To utilize these incomplete results is neither prudent nor representative of

the actual numbers in the Canadian Marketplace.

Further points to be considered:

- Vonage has confirmed that they have 144, 000 Canadian nomadic subscribers as of

end of 2011; one VSP out of the thousands available has a near equivalent number of VoIP

customers as indicated in this report. Vonage year over year growth has been in double

digits for last 5 years.

- Several other VoIP Service Providers were polled by VoIP Solutions but were

hesitant to respond when told the information was to be utilized by VoIP Solutions for a

CRTC TIF 71 process, they were unable to locate any mention of this TIF 71 on the CRTC

website and declined to provide information: example Iristel a Canadian company with 4

Million* (Globe &Mail May 28) active Canadian VoIP numbers (mix of fixed and

nomadic).

- VoIP providers that can send or receive calls to the PSTN must provide 9-1-1

(CRTC 2005-21. As such, VSP’s such as Skype (900,000,000 million users and signing up

600,000 per day globally), Dell, G Voice (250,000 North American Users) and many, many

more must be considered.

- Below is a brief list of at least 6 companies providing Canadian telephone numbers

that can be forwarded to any VoIP account (PSTN diallable or not). This enables

any VSP that would normally only be pier to pier to have access to the PSTN and

would therefore be required to follow CRTC 9-1-1 regulations.

www.flexyphone.com www.new.onebox.com www.tollfreeforwarding.com

www.worldnumbers.com www.evoice.com www.telphin.com

- Shaw Communications chooses to launch WiFi instead of cellular (Globe and Mail

announcement September 1, 2011 attached). This is a Canadian example of the rapid rise in

WiFi usage in Canada. This increasing number of WiFi locationswill provide access to the

rapidly growing supply of WiFi enabled devices such as smartphones, tablets, laptops etc.

All voice applications on these devices when in WiFi mode are VoIP.

- “At Mobile World Congress 2012, the Small Cells Forum unveiled an initiative to

bring standards efforts within the 3GPP, Wi-Fi Alliance and others closer together. Now

there are signs of cooperation at the operator level, with the GSM Association announcing a

deal with the main body of WLan providers, the Wireless Broadband Alliance (WBA). The

two organizations are working together to create a framework to support seamless roaming

between 3G/4G networks and Wi-Fi hotspots, which could find its way into real systems

next year.”

http://www.rethink-wireless.com/2012/03/21/cellular-wi-fi-bodies-common-roaming.htm

UMA or cellular offloading of wireless traffic to WiFi is rapidly growing. The ISP

Methodology provides E9-1-1 for these devices with accurate addressing at the point of

access to the network.

- Since 2006 Bell Canada has experienced a more than 34%*(BCE annual statements)

decline in provisioned telephone lines.

- In the presentation the Bell Canada document, the author mentioned anecdotal

evidence: A Bell Canada Wholesale sales representative has indicated that the largest area

for growth in his business is to provide connectivity to VoIP companies. This comment is

validated by the CRTC’s initiative to pass Decision CRTC 2012-137 which states:

Ottawa, 7 March 2012

VoIP 9-1-1 service – Modified contractual condition

Telecom Decision CRTC 2012-137

File number: 8663-C12-201112820

In this decision, the Commission approves a modification to a condition that Canadian

carriers are required to include in their service contracts with local voice over Internet

Protocol (VoIP) service providers regarding 9-1-1 service. Specifically, this modified

contractual condition indicates that local VoIP service providers, and any or all of

their wholesale customers and subordinate wholesale customers, must comply with the

9-1-1 obligations applicable to local VoIP service providers.”

Why would it be necessary for the CRTC to pass this Decision if VoIP usage (wholesale

carrier sales to VoIP companies) was not growing rapidly?

- Finally, - Bell Canada deemed the VoIP 9-1-1 problem significant enough to invest

over 5 years, of their time and ESWG time, on Canadian i2. They also used a significant

portion of the presentation time of this contribution to continue to promote Canadian i2.

Why would they do so if this wasn’t a significant public safety problem?

The VoIP 9-1-1 challenge has been an issue for many years and has already resulted in

tragic consequences in Canada. All drivers of the problem continue to grow rapidly.

Bell ESCO 0407 quote from above “The interfaces and systems required to support this proposal are

essentially throw away systems that provide minimal future benefit with respect to the current direction of

NG911. “

Unfortunately, Bell has not been able to identify what required systems they deem essential

yet disposable. The ISP methodology consists of 2 new elements and as clarified above, both

elements are highly functional in both legacy and NG 9-1-1 environments. Bell has been

asked multiple times in writing to clarify and identify what elements they deem to be

“throw away”; they have not done so. As legacy and NG 9-1-1 elements do not have an

accurate and automatic civic addressing component (other than ELI) both of these elements

are immediate and long term.

3. Cost of E9-1-1 VoIP solution

In ESCO388 the following cost recovery model was suggested:

o Monthly fees:

software license, software maintenance & upgrades and server hosting.

• $0.50 /month for ISP (to install software and bill, collect and remit 9-1-1 fees in similar fashion as what

is done today for telephony 9-1-1)

• $0.50 for Province or Municipality responsible for 9-1-1 costs ie: PSAP’s.

Response: Please note, this suggested 9-1-1 fee is not an implementation cost but a monthly

operational cost that enables all participants to be compensated for their contribution to the

VoIP E9-1-1 supply chain. Monthly operational costs are not subject of this evaluation

report or in realm of ESWG responsibilities.

Using 2010 data that has been previously discussed in this proceeding, this equates to the following

estimated costs

8.6 million Canadian broadband subs in 2010 X $1.50 per month X 12 months (not including

municipal/provincial 9-1-1 fees/cal answer levies)

However since the 9-1-1 Service Provider requirements are ambiguous the base cost to ISPs not including

9-1-1 SP costs or municipal/provincial fees will be

All considered Ci2 costs were $180M (over a 5-7 year cost study) with minimal ongoing costs once

systems were established. This included the location determination platform (LDP) and all associated 9-1-

1 systems and interfaces.

Response: CRTC 2010-387 indicates that Ci2 implementation “costs were in excess of $180

M dollars” and there is no mention of this number including operational expenses; 2010-387

only mentions implementation costs. There is also no amortization period whatsoever

mention in 2010-387. Please note in Bell’s contribution comments above it is indicated there

would be a “minimal ongoing costs”; nowhere are these costs quantified. Are we to assume

from Bell that the with Ci2 the ISP’s would be required to invest in excess of $180 M and

not be allowed any capital or operational cost recovery? Without a monthly operational fee,

the ISP’s would not recover any operational or capital costs in Ci2.

Two additional points:

1. 2010-387 indicates Ci2 is technically incomplete:

“29.Based on all the above, the Commission concludes that the

implementation of Ci2 is not viable due to Ci2’s technical limitations...”

How can costs of implementation be accurately assessed until technical limitations are

addressed? I expect this is why the CRTC indicated in same Decision, that

2. VSP’s are an instrumental piece of the Ci2 design and technical process.

VSP’s implementation costs have also not been included in implementation costs for Ci2.

ESCO 0407 confirms Ci2 was too expensive and not all costs have been confirmed or

accounted for. It attempts to compare estimates of implementation costs to operational

costs. The ISP methodology capital costs for participants is negligible.

Commission’s analysis and determinations (2010-387)

26. Based on the record of the proceeding, the Commission estimates that the overall cost of

implementing Ci2 is more than $180 million.

Conclusion (2010-387)

29. Based on all the above, the Commission concludes that the implementation of Ci2 is not

viable due to Ci2’s technical limitations in the face of evolving 9-1-1 technology, decreasing

demand for and usage of nomadic VoIP service, and the cost of Ci2 implementation.

Implementation and operational costs are two different things. 2010-387 indicates the cost

to implement Ci2 is MORE THAN $180 M. The Cable Companies alone estimated the cost

to implement would be over $200 M dollars. These are all cost estimates for a solution that

is technically incomplete, with no way of knowing how much the total costs would be until

technical limitations are resolved. It is also important to note that the Ci2 implementation

cost estimates DO NOT include the costs for a key Ci2 contributor, the VoIP Service

Providers; these companies will also be required to establish LDP elements and the number

of VSP’s number in the thousands.

The cost of implementing the ISP methodology as proposed has a $0 capital cost (ISP Edge

software is given to ISP’s and server/gateways are established by ISP Methodology

supplier) – this is not an estimate. A fair comparison is $0 to an estimate that is more than

$180 Million for an acknowledged technically incomplete, short term solution.

Currently Provinces/Municipalities/Other PSAP operators fund their operations on 9-1-1

fees collected from cellular and telephone lines. With telephone lines declining significantly,

costs going up, CPT increasing due to lack of 911 call information and pocket dials (**Ken

Sluman Reports) and along with increased CPT comes increased costs. How are PSAP

operators going to maintain operations without a new long term funding model? How will

they address the growing costs plus the need to purchase new NG 9-1-1 elements without a

fee?

The Commissioner’s letter outlined the evaluation report was to include implementation

issues, not operational. Operational and tariff issues are not ESWG nor TIF 71 mandated

items. As such, the Cost of implementation of Ci2 is more than $180 million as compared to

the ISP Methodology costs of $0.

3. Conclusion

Based on the Commission’s test for E911 VoIP consideration established in Telecom Decision 2010-387

Bell submits that the current VoIP E911 solution falls short in every category in comparison to Ci2. Bell

sees no value in proceeding with an in-depth technical evaluation of the proposed solution. Furthermore

Bell feels that the time and energy of its 9-1-1 specialist would best be spent continuing with SMS T9-1-1

and Phase II Stage II priority work. Bell does not support the proposed E911 VoIP Solutions for the

aforementioned reasons and requests that this TIF be closed as soon as possible.

VOIPS Conclusion

TIF 71 purpose is to evaluate an ISP Methodology for E 9-1-1 for VoIP and is not intended as a

platform from which Bell to promote Ci2. ESCO 0407 claims remain unsubstantiated; The ISP

methodology as proposed comes with independent audited test results and has a net zero capital

cost to implement. The ISP methodology is legacy 9-1-1 capable and NG 9-1-1 compliant and, as

such, is both an immediate and long term solution for VoIP 9-1-1, aligning it with Canada’s NG 9-

1-1 direction. As a result, contribution ESCO 0407’s claims are unsubstantiated and they have not

been able to put forth a valid reason why this methodology should not be considered for

implementation.

Part 3

Response to ESCO0404 Contribution from Ken Sluman

Part 3 – Response to ESCO0404 Contribution from Ken Sluman (NOTE: excerpts of original

contribution are in black text, VoIP Solutions Comments are in blue text)

PSAP OPERATIONS:

In order to be able to respond effectively to disasters, emergencies and other life threatening events,

Public Safety Answering Points (PSAPs) must receive the most accurate information in the least amount

of time possible.

9-1-1 calls received from a landline generally provide the best information to the 9-1-1 call taker. The

subscriber’s name, address and call back number are immediately presented to the call taker in a format

which can often be directly transferred into the Computer Assisted Dispatch (CAD) system employed by

the emergency response service provider (police, fire or ambulance). The data must always be

confirmed verbally but the confirmation process is often far more rapid and accurate when Automatic

Number Identification (ANI) and Automatic Location Information (ALI) records are provided.

It must always be remembered that there are many urgent life threatening situations where the caller

may not be able to speak properly and/or their memories may be impaired (such as a stroke victim or a

person succumbing to smoke inhalation). In these cases, instant and accurate ANI/ALI information often

saves several critical minutes in directing the emergency response resources to where they are needed.

When a 9-1-1 call is placed through VoIP, there is often no relevant ANI/ALI data presented to the

Primary and/or Secondary PSAP. Language barriers, the nature of the emergency, background noise,

etc., all may result in delays or complete failures to obtain a call back number and/or a location from a

person whose life depends on a rapid response.

The proposed solution, if it were to function as explained, would significantly improve the quality of the

information received by PSAP call takers. ANI/ALI information would be provided as frequently and as

quickly as it is with landlines. Public safety would be enhanced.

OTHER BENEFITS:

The National Emergency Number Association (NENA) has published a recommended standard for the

time frame in which a 9-1-1 call should be answered. Ninety percent of 9-1-1 calls are to be answered

within ten seconds and ninety-five percent are to be answered within twenty seconds. Experience has

established that in order to meet that standard, the average amount of time a 9-1-1 call can be sitting in

a queue must not exceed six seconds.

9-1-1 calls which follow the current VoIP systems and practices are initially answered by a third party

and not the Primary PSAP. The third party call center service may or may not be provided by call takers

well trained and practiced in processing 9-1-1 calls as their primary function. When receiving a 9-1-1 call,

the third party call taker will first need to obtain the call back number, name of the caller and the

location of the emergency. The next step must be to determine which primary PSAP to send the call to.

Only then can the call can be transferred to the correct primary PSAP. Even if that process could be as

short as thirty seconds, the delay is five times longer than the NENA standard.

The proposed solution, if it functions as explained, would eliminate the need for the third party call

centre. It would allow for the 9-1-1 calls to be routed directly to the Primary Public Safety Answering

Point, significantly reducing delays in the required emergency response.

CONCLUSION:

The proposed solution has the potential to provide much better information in significantly less time to

the PSAP when a 9-1-1 call is placed through VoIP. Emergency response times should improve

significantly for those calls.

Comments: PSAP’s are the “front lines” of the 9-1-1 system and are forced to deal with the outcomes of

9-1-1 system deficiencies in a very stressful environment; this is their sole purpose and function. ESCO

0404 is an indication that a solution to provide accurate information for VoIP 911 calls is a necessity to

enable in order for PSAP’s to dispatch VoIP 911 calls within established parameters. Current call

redirection techniques are not sufficient and the proposed solution would allow for call information to

be provided to PSAP’s enabling them to perform their duties in an accurate and timely fashion in

accordance with established performance levels.

ADDITIONAL REFERENCES / ATTACHMENTS

1. CRTC Communications Monitoring Report for 2011:

http://www.crtc.gc.ca/eng/publications/reports/policymonitoring/2011/cmr2011.pdf

2. VoIP Solutions Diagram of ELI in an NG9-1-1 Environment (1 page Visio diagram – separate file)

3. NENA i3 Solution - Stage 3 (2 page attachment)

4. News Article - Shaw shuns cellular, bets on WiFi (2 page attachment)

NENA i3 Solution - Stage 3

Full Name: Detailed Functional and Interface Standards for the NENA i3 Solution

Document Type: Standard

Standard Number: 08-003 v1

This specification builds upon prior NENA publications including i3 requirements and architecture documents. Familiarity with the concepts, terminology and functional elements described in these documents is a prerequisite. While the requirements and architecture documents describe high level concepts, the present document describes only the detailed functional and external interfaces to those functional elements. If there are discrepancies between the requirements or architecture documents and this document, this document takes precedence. This document provides a baseline to other NG9-1-1 related specifications.

The i3 solution supports end-to-end IP connectivity; gateways are used to accommodate legacy wireline and wireless origination networks that are non-IP. NENA i3 introduces the concept of an Emergency Services IP network (ESInet), which is designed as an IP-based inter-network (network of networks) that can be shared by all public safety agencies that may be involved in any emergency. The i3 Public Safety Answering Point (PSAP) is capable of receiving IP-based signaling and media for delivery of emergency calls conformant to the i3 standard.

Getting to the i3 solution from where we are today means that we will have to go through a transition from existing legacy originating network and 9-1-1 PSAP interconnections to next generation interconnections. This document describes how NG9-1-1 works after transition, including ongoing interworking requirements for IP-based and TDM-based PSAPs and origination networks. It does not provide solutions for how PSAPs, origination networks, selective routers and ALI systems evolve. Rather, it describes the end point where conversion is complete. At that point, selective routers and existing ALI systems are decommissioned and all 9-1-1 calls are routed by the ECRF and arrive at the ESInet via SIP. The NENA NG9-1-1 Transition Planning Committee (NGTPC) will produce documents covering transition options and procedures.

This document supports IP-based and legacy TDM-based PSAPs.

TDM-based PSAPs are connected to the ESInet via a gateway (the Legacy PSAP Gateway). The definition of the Legacy PSAP Gateway is broad enough that both primary and secondary PSAPs that have not been upgraded may be served by this type of gateway.

Similarly, the scope includes gateways for legacy wireline and wireless origination networks (the Legacy Network Gateway) used by origination networks who cannot yet create call signaling matching the interfaces described in this document for the ESInet. It is not envisioned that legacy origination networks will evolve to IP interconnect in all cases, and thus the Legacy Network Gateways will be needed for a very long time. The document considers all wireline, wireless, and other types of networks with IP interfaces, including IMS networks, although the document only describes the external interfaces to the ESInet, which a conforming network must support. This document describes a common interface to the ESInet, to be used by all types of origination networks or devices. How origination networks, or devices within them, conform is not visible to the ESInet and is out of scope. NENA has endeavored to define this interface to be sufficiently aligned with the major types of originating networks, as defined by the prevalent SDOs (such as 3GPP, 3GPP2, IETF), that they are able to conform without significant modification to their architectures. However, it is recognized that IMS design has evolved in parallel with development of this document, and that further SDO convergence work will be required to align the details between i3 and related origination network 9-1-1 interfaces. The results of this convergence work will be documented in a future edition of this document. Further, regulatory policies will affect how this standard will evolve.

This specification defines a number of Functional Elements (FEs), with their external interfaces. An implementation of one or more FEs in a single indivisible unit (such as a physical box, or software load for a server) is compliant with this specification if it implements the functions as defined, and the external interfaces as defined for the assembly of FEs. Internal interfaces between FEs which are not exposed outside the implementation are not required to meet the standards herein, although it is recommended that they do.

This document describes the "end state” that has been reached after a migration from legacy TDM circuit-switched telephony, and the legacy E9-1-1 system built to support it, to an all IP-based telephony system with a corresponding IP-based Emergency Services IP network. To get to this "end state” it is critical to understand the

following underlying assumptions:

1. All calls entering the ESInet are SIP based. Gateways, if needed, are outside of, or on the edge of, the ESInet. IP services that are not native SIP based, have protocol interworking to SIP prior to being presented to the ESInet.

2. Access Network Providers (e.g.: DSL providers, fiber network providers, WiMax providers, Long Term Evolution (LTE) wireless carriers, etc.) have installed, provisioned and operated some kind of location function for their networks. Location functions are critical for 9-1-1 calls originating on an IP network because it provides a 9-1-1 valid location to IP clients that bundle their location in the SIP signaling to the ESInet.

3. All calls entering the ESInet will normally have location (which might be coarse, e.g., cell site/sector) in the signaling with the call.

4. 9-1-1 authorities have transitioned from the tabular MSAG and ESNs to GIS based Location Validation Function (LVF) and Emergency Call Routing Function (ECRF).

5. 9-1-1 authorities have accurate and complete GIS systems, which are used to provision the LVF and ECRF. A change to the 9-1-1Authority’s GIS system automatically propagates to the ECRF and LVF and immediately affects routing.

6. Civic location will be validated by the access network against the LVF prior to an emergency call being placed. This is analogous to MSAG validation.

7. Periodic revalidation of civic location against the LVF is also needed to assure that location remains valid as changes in the GIS system that affect existing civic locations are made.

8. Since the legacy circuit-switched TDM network will very likely continue to be used for the foreseeable future (both wireline and wireless,) the i3 architecture defines a Legacy Network Gateway (LNG) to interface between the legacy network and the ESInet.

9. Transition to i3 is complete when the existing Selective Router and ALI are no longer used. Even after that time, some PSAPs may not have upgraded to i3. The i3 architecture describes a Legacy PSAP Gateway (LPG) to interface between the ESInet and a legacy PSAP. The LPG supports the origination of an emergency call through the ESInet to a legacy PSAP as well as the transfer of an emergency call from/to an i3 PSAP to/from a legacy PSAP.

10. Federal, State and local laws, regulations and rules may need to be modified to support NG9-1-1 system deployment.

11. While NG9-1-1 is based on protocols that are international, and are designed to allow visitors and equipment not of North American origin to work with NG9-1-1, the specific protocol mechanisms, especially interworking of legacy telecom and ESInet protocols is North American-specific and may not be applicable in other areas.

Committee Name(s): VoIP/Packet

Created: June 14, 2011

Revised:

Reviewed:

Document: 08-003 v1 Detailed Functional and Interface Specification for the NENA i3 Solution

Shaw shuns cellular, bets on WiFi IAIN MARLOW — TELECOM REPORTER From Friday's Globe and Mail Published Thursday, Sep. 01, 2011 8:37AM EDT Last updated Thursday, Sep. 01, 2011 7:16PM EDT

Shaw Communications Inc. (SJR.B) has ditched a $1-billion plan to enter the hotly competitive cellphone

business, opting instead to take a cheaper route by offering customers WiFi access that plugs into the company’s broadband Internet network. After initiating a strategic review of the venture, jump-started when the company paid $190-million for wireless licences in 2008, Shaw’s executive team decided that it wasn’t worth building a full cellular network and taking on incumbent giants and eager new entrants in an increasingly competitive sector.

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Shaw Communications (SJR.B-T)

21.59 -0.81 -3.62% As of Sep 1, 2011 4:31

Shaw drops wireless plan

The startling retreat is the first major move by chief executive officer Brad Shaw, and erases three years of preparations by the company to enter the wireless business under his older brother Jim Shaw – who departed late last year as Shaw’s CEO.

“One of the things that we’re good at is looking at how we spend capital,” Shaw president Peter Bissonnette said in an interview. “This was just a horrible return on a significant investment.”

The company came to the decision as the Canadian wireless market, which Mr. Bissonnette characterized as “bleak,” sheds its former status as an oligarchic utopia. A flurry of upstarts, such as Mobilicity and Wind Mobile, have helped to whittle down the sector’s profit margins by offering rate plans as much as 60 per cent lower than those offered by industry giants such as Rogers Communications Inc. At the end of 2010, new entrants were responsible for nearly 30 per cent of net new wireless subscribers.

Shaw plans to exploit its dense network of fibre optic cables crisscrossing Western Canada, erecting WiFi hot spots in businesses, shopping centres, downtown rail lines and heavily trafficked areas of cities such as Vancouver and Calgary. The end result will be a data-focused alternative to an expensive cellular network that saves hundreds of millions of dollars for the company, while offering Internet customers wireless data services for tablets and smart phones.

“Anywhere people gather, we want to have an access point that will extend, essentially, our broadband pipe into their tablet or WiFi-enabled device,” Mr. Bissonnette said. After looking at the economics of building out a cellular network, he added, his colleagues said “For the next ten years we’re going to spend over a billion dollars building this network, but it’s never going to be over. You’re never finished building that network. And the margins are starting to deplete.”

But as margins start to come under strain at large wireless carriers such as Rogers as subscribers make fewer calls, future growth is increasingly about wireless data. Some analysts worry Shaw will lose out, gaining only incremental revenue from the increased pricing power that comes with a better Internet service. The company also spent $180-million on wireless infrastructure, only about $50-

million of which can be salvaged for a new WiFi venture. RBC Dominion Securities analyst Jonathan Allen warned investors to expect writedowns.

Dvai Ghose, a Canaccord Genuity analyst, said it was clear that Shaw and Rogers could not come to any agreement on a much-rumoured wireless collaboration. “We are underwhelmed by Shaw’s ‘wireless’ announcement,” Mr. Ghose wrote in a note to clients, adding that the deal “gives Shaw peripheral exposure at best to wireless data, the only real growth driver in the sector.”

But Shaw is not inventing the wheel: Cable companies south of the border, such as Cablevision Systems Corp., have already abandoned wireless network blueprints for a WiFi-only launch.

Scotia Capital analyst Jeff Fan said it’s a capital-efficient approach for cable companies to defend against traditional phone companies as they increasingly offer Internet and video services. In the U.S., Cablevision’s Optimum Online WiFi service has tried to fend off Verizon Communications Inc.’s FiOS offering. In Western Canada, Shaw is hoping to do the same against Telus’s renewed push of Optik TV.

“It’s a smart move,” Mr. Fan said. In the wireless industry, “if you ask any of the new entrants what they are experiencing now versus what they had expected two or three years ago before they launched, I think the conditions are completely different. It’s much more challenging than they thought.”

Quebecor Inc.’s cable unit, Vidéotron Ltée, has seen network-building costs erode many of the early returns from its one-year-old wireless network. And Mr. Bissonnette has clearly been paying attention to his Canadian cable peer’s quarterly results.

“Well, Quebecor, God bless ‘em, they believe they’re doing what’s right for themselves – I think they would acknowledge that it’s very expensive,” Mr. Bissonnette said. “I think we came to that conclusion really quickly.”