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ARCHIVED - Telecom Commission Letter Addressed to Philippe Gauvin (Bell Canada)

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Ottawa, 3 February 2015

Our reference: 8638-C12-201412791

BY EMAIL

Philippe Gauvin
Senior Legal Counsel
Bell Canada
Floor 19, 160 Elgin Street
Ottawa, Ontario K2P 2C4
Bell.regulatory@bell.ca

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

This is in response to Bell Canada’s letter dated 27 January 2015 regarding Commission staff’s 19 December 2014 letter, requesting information associated with Enhanced 9-1-1 wireless location accuracy.

The purpose of this letter is to respond to Bell Canada’s request that certain questions relating to the potential use of wireless subscriber billing records or user-inputted address for 9-1-1 purposes not be answered by the individual companies identified in Commission staff’s letter, but instead referred to the CRTC interconnection Steering Committee’s (CISC’s) Emergency Services Working Group (ESWG). Commission staff notes Bell Canada’s belief that referral of certain questions to the CISC ESWG will more quickly yield better information for the Commission, industry and the Canadian public. Commission staff is also aware that there is currently no standard agreed-upon industry proposal or technical model for the use of subscriber billing records or user inputted address information to improve wireless location accuracy and that, as such, the various parties’ answers are likely to provide varying views of the issues.

However, the Commission stated in its 9-1-1 Action planFootnote 1 that a fact-finding exercise would be initiated by the Commission in 2014/15 to assess the reliability and technical feasibility of providing public safety answering points (PSAPs) with a wireless subscriber’s billing address for 9-1-1 purposes at the time of an emergency. This fact-finding exercise is intended to 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.

Commission staff notes that, on 30 January 2015, it received letters from Bragg Communications Inc., carrying on business as Eastlink, Rogers Communications Partnership and Québécor Média, all submitting that the Commission should proceed with its investigation as currently set out and deny Bell Canada’s procedural request.

Commission staff is of the view that requesting information from individual wireless service providers (WSPs) is the appropriate approach to obtaining information on this important topic. It also believes that WSPs should be given the opportunity to share their interpretation of the issues and their assessment of the feasibility and reliability of using billing address or user-inputted information in emergency situations.

Therefore, Commission staff denies Bell Canada’s request to refer questions 1, 3, 6, 8, and 9 in Appendix 2 of Commission staff’s 19 December 2014 letter. Commission staff continues to expect parties’ answers to all questions included in its 19 December 2014 letter to be filed by 17 February 2015.

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.

Yours sincerely,

Original signed by

Chris Seidl
Executive Director
Telecommunications Sector

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 of 19 December 2014 letter

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, rob.olenick@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., affaires_reglementaires@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

Footnote 1

9-1-1 Action Plan, Telecom Regulatory Policy CRTC 2014-342,, 25 June 2014

Return to footnote 1 referrer

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