ARCHIVED - Telecom Commission Letter addressed to various parties interested in the request for information – Enhanced 9-1-1 wireless location accuracy

Ottawa, 19 December 2014

File No.: 8638-C12-201412791

BY EMAIL

To: Distribution List

Request for information – Enhanced 9-1-1 wireless location accuracy

In Telecom Decision 2003-53^{Footnote 1}, the Commission determined that it would not be appropriate to require wireless carriers to enter subscriber records in Automatic Location Identifier (ALI) databases for 9-1-1 purposes. The Commission noted that there had been improvements in the availability of accurate wireless location determination technologies and it would be more effective and cost-efficient for all parties to focus on these improvements.

Consequently, wireless carriers were directed to provide Wireless Enhanced 9-1-1 Phase I service, including the provision to Public Safety Answering Points (PSAPs) of a wireless 9-1-1 caller’s telephone number along with the cell site address and cell sector.  The Commission also directed wireless carriers to maintain toll-free telephone access and continuous staffing of at least one of their operations centres, in order to promptly assist authorized PSAP personnel seeking other subscriber information in emergency situations.

Subsequently, in Telecom Regulatory Policy 2009-40^{Footnote 2}, the Commission required all wireless companies to implement Wireless Enhanced 9-1-1 Phase II including the provision to the 9-1-1 call taker of the caller’s estimated latitude and longitude coordinates using Global Positioning System (GPS) and triangulation technologies.

In the proceeding leading to the Commission’s 9-1-1 Action Plan^{Footnote 3} a number of PSAPs submitted that wireless location information provided to them would be improved if all wireless subscribers handsets had the capability to use GPS to identify the location of a 9-1-1 caller (referred to in this letter as a GPS-enabled handset).  In addition, some PSAPs indicated that automatically providing them with a wireless subscribers billing address with every wireless 9-1-1 call would assist them in certain circumstances in quickly identifying the location of a wireless 9-1-1 caller, compared to having to request this information by calling the wireless carriers.

The Commission’s 9-1-1 Action Plan identified the improvement of wireless location accuracy as being a high priority for the Commission and for Canadians and stated that a fact-finding exercise would be initiated by the Commission in 2014/15 to:

1. understand the penetration of GPS-enabled handsets, as the availability of this technology often leads to more accurate location information;
2. assess the reliability and technical feasibility of providing PSAPs with a wireless subscriber’s billing address for 9-1-1 purposes at the time of an emergency.

This fact-finding exercise will assist the Commission in determining whether to initiate a review of its 9-1-1 policies, including the provision of wireless subscriber addresses to PSAPs, as set out in Decision 2003-53.

As such, all companies identified in the distribution list are to file responses to the questions set out in the Appendices with the Commission by 17 February 2015. These submissions must be received, not merely sent, by that date. You must submit your documents electronically using the secured service “My CRTC Account” (Partner Log In or GCKey) on the CRTC’s webpage (crtc.gc.ca) and fill in the “Broadcasting and Telecom Cover page” located on this web page. On this web page, you will also find a link to information on the submission of applications to the Commission. See: “Submitting applications and other documents to the CRTC using My CRTC Account.” 

This letter and all subsequent correspondence will be added to a public record, and may be incorporated into the public record of any subsequent public proceeding initiated by the Commission.  However, information may be designated confidential pursuant to section 39 of the Telecom Act and Broadcasting and Telecom Information Bulletin CRTC 2010-961.

Yours sincerely,

Original signed by

Chris Seidl

Executive Director, Telecommunications

c.c.: Renée Doiron, CRTC, 819-997-2755, renee.doiron@crtc.gc.ca
Josiane Lord, CRTC, 819-576-2568, josiane.lord@crtc.gc.ca

Distribution List:

Bell Mobility Inc., bell.regulatory@bell.ca
Bell Aliant Regional Communications, Limited Partnership, regulatory@bellaliant.ca  
Nexicom Mobility Inc., pdowns@nexicomgroup.net
TBayTel, stephen.scofich@tbaytel.com   
Huron Telecommunications Co-operative Limited, regulatory@hurontel.on.ca
Hay Communications Co-operative Limited, a.schneider@hay.net  
Inukshuk Wireless Partnership, don.falle@inukshuk.ca  
Rogers Communications Partnership, rwi_gr@rci.rogers.com  
TELUS Communications company, regulatory.affiars@telus.com
MTS Inc., iworkstation@mtsallstream.com
Airtel Wireless LTD, jason.bennett@airtelwireless.ca
Shaw Telecom Inc., Regulatory@sjrb.ca
Lynx Mobility Inc., marcille@atmacinta.com
Execulink Telecom Inc., jonathan.scott@execulink.com
Videotron G.P., regaffairs@quebecor.com
Wightman Telecom Ltd., kgugan@wightman.ca
Quadro Communications Co-operative Inc., barry.stone@quadro.net
Bragg Communications Incorporated (EastLink), regulatory.matters@corp.eastlink.ca
Sogetel Mobilité inc., reglementation@sogetel.com  
Northwestel Inc., regulatoryaffairs@nwtel.ca
SSI Micro Ltd., regulatory@ssimicro.com
Gogo Connectivity Ltd., mkoch@goodmans.ca
Brooke Telecom Co-operative Ltd., jim@brooketel.ca
Ice Wireless Inc., regulatory@icewireless.ca  
Fido Solutions Inc., regulatory.aff@fidomobile.ca
Saskatchewan Telecommunications, document.control@sasktel.com
Télébec, Limited Partnership, reglementa@telebec.com
CityWest Mobility Corp., Heather.bishop@cwct.ca
KMTS, reglementa@telebec.com
Mornington Communications Co-operative Limited, rbanks@mornington.ca
NorthernTel, Limited Partnership, reglementa@telebec.com
Globalive Wireless Management Corp. (Wind Mobile), lisagoetz@globalive.com
Public Mobile Inc., regulatory.affairs@telus.com   
Data & Audio Visual Enterprises Wireless Inc. (Mobilicity), gary.wong@mobilicity.ca
Manitoba Netset Ltd. (NetSet Communications), dhardy@mbnetset.ca  
TerreStar Solutions Inc., jan.skora@terrestar.ca

Appendix 1 - Wireless location determination technology

1. Provide your company’s views, with supporting rationale, on the appropriateness of using GPS as the primary means for determining the location of Canadians dialling 9-1-1 from a wireless handset.
2. With respect to wireless location determination technology(ies) that are used to determine the location of wireless 9-1-1 callers (e.g. Assisted-GPS, Observed Time Difference Of Arrival, Cell ID + Round Trip Time, etc.):
   1. list the technology(ies) currently deployed in your network.
   2. describe, with supporting rationale,  how the various technologies work and interact with each other, as applicable, at the time of handling a 9-1-1 call. 
   3. explain whether a particular technology acts as the primary technology, and explain whether the technology(ies) are network or handset-based.
3. Are you planning to upgrade your current wireless location technology(ies) within the next 5 years?
   1. if not, discuss the criteria used to determine that upgrades are not necessary or justified.
   2. if so, discuss the criteria used to determine which wireless location technology(ies) you are considering, the expected improvements or advantages and the expected implementation timelines.
4. With regards to wireless handsets that your company offered to customers in the last 12 months, provide the following information:

5. With regards to wireless handsets currently carried by your customers, provide the following information:

6. Describe with supporting data and rationale what steps would be involved in transitioning all current and future customers to GPS enabled handsets.
7. Estimate the timeframe, with supporting rationale, in which the percentage of your total subscriber base carrying GPS-enabled handsets will reach 80%, 90% and 100%?

Appendix 2 – The use of wireless subscriber billing records for 9-1-1 purposes

1. Comment, with supporting rationale, on whether the determinations made in Decision 2003-53,with regards to the assistance of PSAP personnel seeking subscriber information in emergency situations and that it is not required for wireless carriers to input subscriber records into the ALI database,shouldbe re-examined.
2. Given the various methods customers currently use to acquire a wireless handset, :
   1. For what percentage of wireless subscribers does your company currently collect and store billing addresses?  If this information is only collected for a subset of your customer base, explain why.
   2. Is the billing address information collected for both post and pre-paid subscribers?
   3. Is the billing address information periodically examined to ensure that the information is up-to-date and/or accurate?
3. In order to automatically  provide  customer billing addresses to PSAPs at the initiation of a 9-1-1 call from a wireless device:
   1. What changes would your company need to make, including to its technology, procedures, billing systems?
   2. What measures would be necessary to ensure that the billing address information is accurate and kept up-to-date? 
   3. What would be required to provide the subscriber information for which you do not currently have a billing address, if applicable?
4. With the change in subscribers habits and the use of wireless handsets as primary devices, :
   1. Does your company currently collect and store wireless subscribers’ user-inputted addresses? 
   2. If not, or if this information is only collected for a subset of your customer base, explain why.
   3. What changes would your company need to make, including to its technology, procedures, and billing systems to collect and store wireless subscribers’ user-inputted addresses for all of its customers?
      1. What measures would be necessary to ensure that the user-inputted information is accurate and kept up-to-date? 
5. Do you anticipate any issues related to the privacy of customer information that would be raised by automatically providing PSAPs with billing addresses or user-inputted addresses when a wireless 9-1-1 call is placed?
6. For the companies currently responsible for the management of ALI databases,  comment on the technical feasibility of inputting either wireless subscribers’ billing or user-inputted records into the ALI database:
   1. How would this capability be implemented, what would be the impact on your company and on Canadians, and what timeframe would your company require to implement this capability?
   2. If this solution is not feasible, indicate why, with supporting rationale. Are there alternative technical solutions that could be developed?  If so, explain the alternative with supporting rationale. What would be the impact on your company and your customers, and what timeframe would your company required to implement this alternate capability?
7. In regards to your 24/7 operations centre providing subscriber information to PSAP personnel in an emergency situation: 
   1. Provide the number of wireless 9-1-1 calls that have been made by your subscribers in the last 6 months.
   2. Provide the number of calls PSAPs have made to your operations centre requesting subscriber billing address information in the last 6 months.
   3. Describe the process followed by your 24/7 operations centre to provide subscriber information to PSAPs including but not limited to authentication procedures.
8. Comment on the reliability of customer billing address information in the identification of the location of a wireless subscriber making a 9-1-1 call. 
9. Comment on the reliability of user-inputted address information, which may or may not be the same as the customer’s billing address, in the identification of the location of a wireless subscriber making a 9-1-1 call.

Date modified:

2014-12-19