ARCHIVED - Telecom Commission Letter addressed to Distribution List

Ottawa, 23 October 2015

File No.: 8638-C12-201412791

BY EMAIL

To: Distribution List

Re:   Conclusion of the request for information – Enhanced 9-1-1 wireless location accuracy

In June 2014, in Telecom Regulatory Policy 2014-342, the Commission published its 9-1-1 action plan which laid out key initiatives aimed at enhancing the 9-1-1 system for Canadians.  Included in the Commission’s determinations was a commitment to initiate a fact-finding exercise in 2014/15:  

1. to understand the penetration of Global Positioning System (GPS) -enabled handsets, as the availability of this technology often leads to more accurate location information; and
2. 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 letter is intended to summarize the information gathered on these topics and to conclude the fact-finding exercise, which was initiated via a Commission staff letter, dated 19 December 2014.  Wireless service providers (WSPs) and 9-1-1 network providers responses are available on the Commission’s website under file number 8638-C12-201412791.Where information was filed in confidence, an abridged version has been provided. 

Wireless location determination technologies and the penetration of GPS-enabled handsets

The results of the fact-finding reveal that WSPs in Canada have proactively deployed hybrid location determination technologies that combine handset capabilities with network capabilities to offer the most accurate caller-location information possible to PSAPs. This includes hybrid location technologies such as assisted-GPS and network-based technologies such as tower location, Round-trip time, and Advanced Forward Link Trilateration. These technologies are the most advanced location technologies available on the market. Many WSPs reported that they plan to adopt new location determination technologies, as they become available, in order to provide more accurate location information to PSAPs in the future.

The Commission acknowledged in its 9-1-1 action plan that the availability of GPS technology often leads to more accurate location information. With respect to GPS-enabled handset penetration, WSPs indicated that 90% to 100% of mobile handsets currently offered to their customers are GPS-enabled, and they conservatively^{Footnote 1}estimated that approximately 85% of wireless devices currently in use in Canada are GPS-enabled.^{Footnote 2} WSPs added that, based on their observation of the average handset life cycle, they expect market forces and customer demand for newer, GPS-enabled handsets to drive the percentage of GPS-enabled handsets in Canada to near 100% within the next two to three years.

The Commission recognizes that Canadian WSPs have chosen to continually upgrade their networks and systems, to offer the latest and most advanced mobile handsets, and to deploy the most accurate location determination technologies available on the market. The Commission expects WSPs to continue to invest in the best-available wireless location determination technologies as these technologies evolve. The Commission will also continue to evaluate the WSPs’ location accuracy performance as part of the wireless location accuracy monitoring process, in which all WSPs are required to participate.^{Footnote 3} As such, the Commission determines that no other follow-up process is required on these issues at this time.

The automatic provision by WSPs of wireless subscriber addresses for 9-1-1 purposes

In Telecom Decision 2003-53, the Commission mandated WSPs to establish toll-dfree, 24/7 operations call centres in order to assist authorized PSAP personnel in promptly obtaining subscriber information in emergency situations. The Commission made this determination in recognition of (i) the difficulties associated with WSPs inputting wireless subscriber records into the ALI (automatic location information) database, (ii) the challenges associated with WSPs automatically providing wireless subscriber addresses to PSAPs, including the high costs and lack of reliability of subscriber billing addresses for 9-1-1 purposes, and (iii) the many technical and administrative problems associated with WSPs automatically providing subscriber addresses to PSAPs.

The Commission therefore determined that it would be more effective and cost-efficient for all parties to focus on implementing location determination technologies that would provide the actual location of wireless subscribers at the time of a 9-1-1 call rather than implementing a solution that would provide PSAPs with a subscriber’s address.

Subsequently, in Telecom Regulatory Policy 2009-40, the Commission mandated WSPs to implement advanced location determination technologies that rely on GPS and network-based technologies to provide PSAPs with the estimated location of wireless 9-1-1 callers. As a result, WSPs today provide Wireless Phase II Enhanced 9-1-1 services to their customers, wherever PSAPs support these services.

As part of this fact-finding, the Commission sought updated information on the reliability and technical feasibility of automatically providing PSAPs with a wireless subscriber’s billing address for 9-1-1 purposes. WSPs indicated in their responses that subscriber billing addresses remain unreliable in identifying the location of a wireless 9-1-1 caller since the caller is mobile and is not necessarily located at that address at the time of the 9-1-1 call. A 9-1-1 caller’s billing address may also be different from their residential address if the person who pays for the wireless service is not the 9-1-1 caller (through family plans, business plans, etc.) or if the billing address is a post office box. Furthermore, e-billing customers and pre-paid customers are typically not required to provide or update their billing address information.

Generally, WSPs and 9-1-1 network providers indicated that the numerous challenges inherent in implementing an automated solution, as identified in Telecom Decision 2003-53, remain. Specifically, WSPs would have to overcome significant technical and administrative challenges, and implement costly changes to their 9-1-1 and billing systems. Most indicated that the cost of implementing an automated solution would far outweigh the benefits, considering that the CRTC has already mandated all WSPs to provide PSAPs with access to a 24/7 operation centre which enables them to request this type of customer information, and more, regarding a 9-1-1 caller^{Footnote 4}.

Most WSPs added that their efforts would be best invested in improvements to wireless location accuracy technologies that provide a 9-1-1 caller’s actual location, rather than in automating the provision of wireless subscriber billing address information.

The Commission notes that Bell Canada proposed a solution to the CISC Emergency Services Working Group which would permit WSPs to automatically provide wireless subscriber address information to PSAPs. However, based on the results of the fact-finding process, regardless of the mechanism used to deliver addresses for 9-1-1 purposes to PSAPs, the Commission is of the view that the underlying facts and circumstances which lead to the Commission’s existing policy regarding the process to provide wireless subscriber billing records to PSAPs have not changed in a manner that supports a policy review. As such, the Commission considers that it remains appropriate for WSPs to continue to provide wireless subscriber billing address information to PSAPs via their 24/7 operations centers, as mandated by the Commission. Consequently, the Commission continues to be of the view that WSPs’ efforts would be best invested in continuing to proactively upgrade and improve their existing caller location determination systems to further enhance location accuracy, rather than automating the provision to PSAPs of wireless subscriber address information that may not indicate the actual location of the 9-1-1 caller.

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. As such, as announced in its Three-year plan, the Commission will initiate a proceeding in 2016 to develop the regulatory framework for the provision of NG9-1-1 services for telecommunications service providers. 

Sincerely,

Original signed by Luc Bégin for/

John Traversy
Secretary General

c.c.: Renée Doiron, CRTC, 819-997-2755, renee.doiron@crtc.gc.ca
Mylène Germain, CRTC, 819-635-4538, mylene.germain@ic.gc.ca

Distribution List:

CISC Emergency Services Working Group, Chris.Kellett@ESWG9-1-1.ca
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

Date modified:

2015-10-23