ARCHIVED - Telecom Decision CRTC 2014-630

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Ottawa, 5 December 2014

File numbers: 8665-Y15-201407247 and Northwestel Tariff Notice 917

Northwestel Inc. - Application to approve an Emergency Response Auto-Select service as proposed by the Yukon Government

The Commission approves Northwestel’s application to provide an Emergency Response Auto-Select service as proposed by the Yukon Government for communities that currently do not have 9-1-1 service, subject to amendments and conditions. Due to the special circumstances of this case, the tariff approved in this decision will have a limited duration and remain in effect until 28 July 2016 pending the introduction of 9-1-1 service that is more comparable to the rest of Canada. This temporary service will provide residents of Yukon with a faster and easier way to seek help during emergencies.

Introduction

1. Effective access to emergency services is critical to the health and safety of citizens, and is an important part of ensuring that Canadians have access to a world-class communications system. The provision of 9-1-1 services is a collaboration between telecommunications service providers and provincial/territorial/municipal governments who are responsible for emergency responders (such as police, fire, and emergency medical services) and for the establishment, funding, and management of Public Safety Answering Points (PSAPs) that dispatch them.

2. The Commission’s role in the provision of 9-1-1 services under the Telecommunications Act is threefold.

   • First, it exercises regulatory oversight over the telecommunications access provided by telecommunications service providers, including 9-1-1 network connections, service features, and capability, to enable Canadians to contact provincial/territorial/municipal government established or designated PSAPs that are responsible for providing 9-1-1 services covering a defined area.

   • Second, it is responsible for the administration of telephone numbers, which includes determining the use of three-digit numbers, such as 9-1-1 and 4-1-1. Part of this responsibility is to ensure that the N-1-1 numbers are used appropriately and to maintain public confidence that the numbers permit access to services the Commission has designated them for.

   • Third, the Commission approves tariffs setting out the rates, terms, and conditions with respect to the provision of 9-1-1 service by Canadian carriers.

3. At this time, there are two types of 9-1-1 service: Basic 9-1-1 and Enhanced 9-1-1 (E9-1-1).

   • Basic 9-1-1 service consists of routing a 9-1-1 dialed call to a live 9-1-1 call taker at a designated PSAP. The call taker may then dispatch the required emergency response service (police, fire, or emergency medical services) to the location of the emergency.

   • E9-1-1 service includes all of the capabilities provided by Basic 9-1-1 service, as well as the provision of the 9-1-1 caller’s information to the 9-1-1 call taker, including the caller’s location and telephone number.

4. In Yukon, Basic 9-1-1 service has been provided in the Whitehorse catchment area,^{Footnote 1} covering 77% of the territory’s population, since 1995. This service is provided by a PSAP managed by the Royal Canadian Mounted Police (RCMP), established in Whitehorse, as a result of an agreement between the Yukon Government, the city of Whitehorse, and the RCMP.

5. Currently 9-1-1 service is unavailable outside of the Whitehorse catchment area. As the Yukon Government has not yet established or designated a PSAP for these unserved areas, telephone service subscribers in these areas access emergency services by dialing the local seven-digit telephone numbers of the local emergency responders in their community.

Process

6. The Commission received an application from the Yukon Government, dated 28 July 2014, in which the Yukon Government proposed the implementation of an interim Emergency Response Auto-Select (ERAS) service during the 16 to 24 months required to implement Basic 9-1-1 service throughout Yukon. ERAS service would provide 9-1-1 callers within all communities of Yukon - excluding Whitehorse, where Basic 9-1-1 service is available - with access to an automated answering system directing callers to select #1 to reach the police, #2 to reach the fire department, and #3 to reach emergency medical services.

7. Subsequently, on 6 August 2014, the Commission received an application from Northwestel Inc. (Northwestel), under Tariff Notice 917 (TN 917), in which the company requested that the Commission approve a tariff setting out the rates, terms, and conditions for the proposed ERAS service.

8. The above-referenced applications were combined into one process by Commission staff letter dated 19 August 2014.

9. The Commission received interventions from Ice Wireless Inc. and Iristel Inc. (collectively, Ice/Iristel), the Utilities Consumers’ Group, and one individual. The public record of this proceeding, which closed on 8 September 2014, is available on the Commission’s website at www.crtc.gc.ca or by using the file numbers provided above.

Applications

Yukon Government

10. The Yukon Government submitted that access to emergency service in communities outside of the Whitehorse catchment area is inadequate for residents and for visitors, arguing that a plan for access to Basic 9-1-1 service is required. With this acknowledgement, the Yukon Government indicated that it faces several challenges in implementing Basic 9-1-1 service in all Yukon communities. In a majority of the smaller Yukon communities, emergency medical and fire services are volunteer-based organizations with operating hours that may be very limited and can vary on a seasonal basis; allocation of resources between communities is not possible because of the inability to communicate and coordinate responses.

11. The Yukon Government submitted that there are several concurrent components to the Basic 9-1-1 implementation plan set out in its application: the implementation of its proposed interim ERAS solution; the modification of the Whitehorse PSAP to accommodate increased access to Basic 9-1-1 service; and the evaluation of solutions for the provision of universal access to Basic 9-1-1 service in every Yukon community. In order to implement this plan, the Yukon Government is working in conjunction with Northwestel, the RCMP, local communities, and emergency service providers.

12. In the Yukon Government’s view, its proposed interim ERAS solution would provide an immediate improvement to accessing emergency responders, as ERAS service would enable wireline and wireless subscribers to dial 9-1-1 in order to reach an automated answering system directing callers to local community emergency services, instead of having to remember a local seven-digit number.

13. The Yukon Government noted that if an ERAS caller selected #2 for the fire department or #3 for emergency medical services, and the call was not answered, the caller would be required to hang up, redial, and then select #1 for the police (RCMP). In the event that the local RCMP personnel does not answer the call, it is then forwarded to the RCMP managed-PSAP in Whitehorse. 

14. Under the Yukon Government’s proposal, ERAS service would be provided to telephone subscribers within all communities of Yukon, outside of the Whitehorse catchment area, and be equally accessible to wireline and wireless telephones, subject to a carrier’s participation and the compatibility of wireless devices. The Yukon Government would also bear the costs of the interim solution and would discontinue ERAS service as soon as a permanent Basic 9-1-1 system is available throughout Yukon.

15. The Yukon Government submitted that consumer notification is an important aspect of its plan. Immediately upon approval of the proposed ERAS service, it would lead a public awareness campaign targeted at each affected community to inform them of the functionality, availability, characteristics, and limitations of ERAS service. As well, the Yukon Government would emphasize that ERAS service will be phased out as Basic 9-1-1 service becomes available throughout Yukon within the next 12 to 20 months.

Northwestel’s TN 917

16. Northwestel requested that the Commission approve the introduction of ERAS service and that the rates be effective the date of approval, with an implementation date of 30 days following approval.

17. Northwestel noted that ERAS service does not provide the calling features associated with its Basic 9-1-1 service, nor does it include features associated with E9-1-1 service. Northwestel would provision the service using its voice mail platform and use its call forwarding service to deliver all 9-1-1 dialed calls to the voice mail platform.

18. Northwestel indicated that the Yukon Government will be the sole customer for ERAS service and will pay all charges for it to cover all communities outside of the Whitehorse catchment area; no charge will be incurred by callers or imposed on telephone service subscribers.

Positions of parties

19. Ice/Iristel submitted that ERAS service does not provide Basic 9-1-1 service, and, hence, the Commission should not approve it. Ice/Iristel noted that they had made a proposal to the Yukon Government in April 2014 to provide live Basic 9-1-1 services to every community in Yukon within six months. Further, if the Yukon Government issued a Request for Proposals for a PSAP to provide Basic 9-1-1 services in Yukon, they and possibly other parties would be interested in providing the PSAP service.

20. The Utilities Consumers’ Group and an individual supported Ice/Iristel’s proposal, objecting to the implementation of ERAS service and the further delay in providing Basic 9-1-1 services throughout Yukon.

21. The Yukon Government filed letters from the Association of Yukon Fire Chiefs (AYFC) and the Association of Yukon Communities supporting the interim implementation of ERAS service as a stop gap measure, under the condition that the Yukon Government implements a permanent territory-wide Basic 9-1-1 service as soon as possible.

22. The AYFC submitted that ERAS service will help solve the considerable problem of citizens not knowing the seven-digit telephone numbers in the various communities; as such, it was a good first step. However, it would not be satisfied with ERAS service or Basic 9-1-1 service, as it is committed to having a modern E9-1-1 service provided across Yukon, as in the rest of Canada, with the ability to eventually move to Next Generation 9-1-1 service.

Reply comments

23. The Yukon Government argued that the coordination of emergency services, including the provision and establishment of a PSAP, is its responsibility, and is outside the scope of the applications being considered in this process.

24. The Yukon Government submitted that it is continuing to work on the technical and operational aspects of implementing Basic 9-1-1 service in all Yukon communities, and it is premature at this time to decide on, or consider specific technology solutions for, implementing Basic 9-1-1 service.

25. Northwestel noted that it is prepared and technically ready to implement Basic 9-1-1 service in all Yukon communities, and will do so in conjunction with the operational readiness of the Yukon Government in rural communities.

26. Northwestel submitted that, since ERAS service would utilize 9-1-1 number dialing, it is of utmost importance for Yukon residents to be aware of its availability, characteristics, and limitations relative to Basic 9-1-1 service provided in Whitehorse and the E9-1-1 service provided in other parts of Canada. Thus, the company supported the Yukon Government’s communication plan, indicating that it is ready to support the communication of consumer information on ERAS upon approval of the service.

Commission’s analysis and determinations

27. The Commission notes that residents of and visitors to Yukon, outside of the Whitehorse catchment area, do not have access to emergency service comparable to other parts of the country. The Commission considers that implementation of Basic 9-1-1 service across Yukon is critical to addressing this imbalance and protecting the safety of all Canadians.

28. The Commission notes that the Yukon Government has committed to providing Basic 9-1-1 service to all communities in Yukon within the next 12 to 20 months. However, the Yukon Government faces a number of challenges in implementing Basic 9-1-1 service where it is not currently available, the most important of which is the establishment or official designation of a PSAP, which is its responsibility. The Commission will therefore not address the proposal by Ice/Iristel to provide PSAP services, as it is not within the Commission’s jurisdiction, and therefore it is outside of the scope of this proceeding.

29. While, as noted above, the Commission considers that it is important that Canadians in the communities in Yukon that do not have 9-1-1 service get access to 9-1-1 service as it is provided in Whitehorse and surrounding areas and the rest of Canada, the Commission accepts that this is not possible in the immediate future. Hence, it is appropriate to examine Northwestel’s tariff application as a temporary means of accessing emergency services in the territory.

30. The Commission considers that the ability to dial 9-1-1 instead of a distinct local seven-digit telephone number to access each emergency responder in a community is a more efficient and faster way for the public to seek help during emergencies. At the same time, the Commission is concerned, as discussed below, that allowing 9-1-1 to be used as the number to access a level of emergency services that is inferior to Basic 9-1-1 service, let alone E9-1-1 service, could negatively impact the perception and the reliance placed by Canadians vis-à-vis the use of the 9-1-1 number.
31.  ERAS service does not meet the minimum criteria to qualify as a Basic 9-1-1 service because the calls would be not be routed to a PSAP with live 9-1-1 call takers. Instead, the call would be routed first to an automated answering system, and then to the selected local emergency responders. In addition, given that the formal organizational structures required to ensure that emergency responders are always available would not yet have been implemented by the Yukon Government throughout Yukon, it is possible that emergency responders may not be in a position to answer the ERAS calls.

32. Furthermore, as proposed by the Yukon Government, if an ERAS caller selects #2 for the fire department or #3 for emergency medical services, and the call were not answered, the caller would be required to hang up and dial #1 for the police.^{Footnote 2} The Commission considers that Canadians dialing 9-1-1 during emergencies expect that their call will be answered, and that the requirement to hang up and redial is inefficient and will be confusing to some callers, which in the case of a life-threatening emergency could potentially lead to dire consequences. 

33. On balance, the Commission is persuaded that, notwithstanding its limitations, ERAS is an appropriate temporary solution pending the establishment of 9-1-1 service, as it is provided in the rest of Canada.

34. However, the Commission considers that it is important to mitigate the risk of an ERAS call not being answered, and determines that all 9-1-1 ERAS calls must be answered by an emergency service provider without the caller having to hang up and redial. To comply with this condition, Northwestel will need to modify the proposed ERAS solution to ensure that when 9-1-1 calls to fire departments and emergency medical services are not answered within a certain time frame, the call is automatically re-routed to either the local RCMP detachment or directly to the PSAP in Whitehorse. The existing arrangements that forward to the PSAP in Whitehorse those calls that are not answered by the local RCMP detachments are also to be maintained.

35. The Commission considers that the Yukon Government is in the best position to determine the time frame or the number of rings that are appropriate before the ERAS call is re-routed. The Yukon Government also has to make the necessary arrangements with the RCMP and the Whitehorse PSAP on how to handle ERAS calls re-routed to them.

36. To further reduce the risks that ERAS service poses, the Commission notes that the Yukon Government has committed to conducting a comprehensive public awareness campaign targeting each affected community. The Commission considers that such an education campaign would serve to inform the public about ERAS service, and limit any confusion on the part of Canadians.

37. The Commission has examined Northwestel’s proposed rates and does not have any concerns about the rates set out in its application, noting that the Yukon Government, as the sole customer for the ERAS service, strongly supports the tariff.

38. In light of the above, the Commission approves Northwestel’s application to provide ERAS service as proposed by the Yukon Government, subject to the amendments and conditions summarized below.

39. The Commissions directs Northwestel to include the following text in its tariff:

    • the tariff for ERAS service is effective until 28 July 2016, and

    • provision of this service is conditional on the Yukon Government conducting a comprehensive public awareness campaign for residents and visitors in each community where ERAS will be implemented, educating the public on (i) how ERAS service functions, and (ii) its availability, characteristics, and limitations, as well as informing the public of the plans to provide Basic 9-1-1 service and further enhancements, including the Yukon Government’s commitment to implement Basic 9-1-1 service throughout Yukon, by 28 July 2016 at the latest.

40. The approval of Northwestel’s application, as modified above, is also conditional on the following: Northwestel must modify the proposed ERAS service to ensure that, when 9-1-1 calls to fire stations and emergency medical services are not answered, the call is to be automatically re-routed to the local RCMP detachment or directly to the PSAP in Whitehorse. Where a call to the local RCMP detachment is not answered, the call will be automatically forwarded to the PSAP in Whitehorse.

41. Northwestel is to issue revised tariff pages reflecting the above-noted amendments and modifications within 30 days of the date of this decision,^{Footnote 3} and is directed to provide a description in a cover letter of how it modified the service to meet the above-referenced condition.

Secretary General

Date modified:

2014-12-05