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ARCHIVED - Telecom Commission Letter Addressed to Distribution List

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Ottawa, 17 June 2016

Our reference:  1011-NOC2016-0115

BY E-MAIL

Distribution list

RE: Participation by wireless service providers in the National Public Alerting System, Telecom Notice of Consultation CRTC 2016-115 – Requests for Information

Dear Madam or Sir:

Pursuant to paragraph 23 of Telecom Notice of Consultation CRTC 2016-115, and in order to assist the Commission in its consideration of the issues set out in that Notice, attached are requests for information from the Commission.

Wireless Service Providers (WSPs)Footnote 1 , Emergency Management Organizations (EMOs), and specific parties that have provided interventions supporting Short Message Service (SMS)-based Wireless Public Alerting (WPA) (herein referred to as other parties). Questions specific to WSPs are attached in Appendix 1, questions specific to EMOs are attached in Appendix 2, and questions specific to other parties are attached in Appendix 3. Note that some parties are included in multiple categories, and are asked to respond to all questions addressed to them.

Responses to the questions set out in the attachments are to be filed no later than 15 July 2016. These submissions must be received, not merely sent, by that date.

Responses should be provided in a single document, addressing requests for information, in order to facilitate accessibility and administrative processing. WSPs, EMOs and other parties may choose to coordinate and file their responses in conjunction with other organizations who share their position. These responses will be published on the Commission’s website under the file number identified above.

We also ask that you repeat each question in your response.

As set out in section 39 of the Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filling confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential, or provide reasons why an abridged version cannot be filed.

Should you have any questions regarding this letter, please contact Nathalie Péloquin by email at nathalie.peloquin@crtc.gc.ca.

Sincerely,

[Original Signed]

Steven Harroun
Director General
Strategic Policy

c.c.: Grégoire Bérubé (gregoire.berube@crtc.gc.ca)
Nathalie Péloquin (nathalie.peloquin@crtc.gc.ca)

Enclosures

Distribution List

Wireless Service Providers (WSPs)

Emergency Management Organizations (EMOs)

Other Parties

Appendix 1: Interrogatories for Wireless Service Providers (WSPs)

  1. Other than costs associated with the purchase of compatible mobile devices, will there be additional charges on subscribers’ invoices to cover, in whole or in part, the costs of implementation and maintenance of Wireless Public Alerting (WPA)? If so, please provide estimates of these charges.
  2. If WPA is implemented, how can the Commission ensure that there is a consistent user experience regardless of the underlying technology?
  3. Under your network’s typical usage pattern, if an alert were issued in a dense urban area with 1,000,000 compatible mobile devices, identify how long would it take for the alert to reach all devices with Cell Broadcast (CB) and Location-Based Short Message Service (LB-SMS) messages.
  4. Identify how many Short Message Service (SMS) messages per second your network currently processes. In your response, provide both the average and the peak number of SMS message per second, and identify the maximum possible capacity.
  5. In a number of interventions, it is submitted that alerts delivered over LB-SMS can reach all of a network’s users. Explain how a LB-SMS solution that targets all generations of mobile networks (2G, 3G, 4G/LTE) would affect the implementation time and cost of WPA.
  6. Specify how many SMS messages your system can queue. In your response, explain:
    1. whether there is a mechanism to prioritize alerts over other SMS messages;
    2. how many attempts are made to deliver an SMS message before it is discarded, and over what time period.
  7. In SMS-based WPA, explain how the delivery order of phone numbers would be determined.
  8. During a major event (e.g. sports games, large public gatherings, emergencies), where the mobile network is under heavy stress, explain how the delivery of alerts would be impacted for CB and LB-SMS.
  9. Explain how French accent characters – especially those not included in the GSM 7-bit alphabet – are handled in SMS messages, and what proportion of devices on your network are capable of receiving these accent characters.
  10. In its intervention at paragraph 9 Bruce Power suggests that LB-SMS WPA can be implemented today, and at paragraphs 21-22 Bruce Power submits should be used until a Cell Broadcast (CB) solution is ready (approximately 12 months, as many interventions stated). Explain whether and how such an implementation plan would affect the cost and time required to deploy WPA. In your response, address whether any additional cost ultimately be borne by the consumer.
  11. At paragraph 29 of Rogers Communications Canada Inc.’s intervention, the company discusses that SMS messages can be easily spoofed. Mobility & Wireless Solutions’ intervention (paragraph 29) says “With LB-SMS, the public could not be certain that an alert message was sent by an Authorized […] Alerting Authority”.  Explain how consumers can be assured of the authenticity of an SMS-based wireless public alert. 
  12. In their intervention, Mobility & Wireless Solutions mentions that five tests per year “will result in user frustration and alert fatigue” (paragraph 7).
    1. Comment on how “user frustration and alert fatigue” would affect the success of the WPA initiative.
    2. Comment on whether the Commission should mandate a specific testing frequency, and explain.
    3. Comment on whether test alerts should be displayed on subscribers’ mobile devices in the same format as non-test alerts.
  13. Senior Officials Responsible for Emergency Management (SOREM) has set out a list of alerts which have been identified as Broadcast Immediately (BI) (this list can be found at: https://alerts.pelmorex.com/download/public/Broadcast%20Immediately%20-NAAD%20System%20Support%20Policy%20-%20V2.0%2020-Nov-2014.pdf). This list of “broadcast immediately” alerts has been used by the Commission in the context of the distribution of emergency alert messages by broadcasting undertakings.
    1. Comment on whether any or all of the same emergency situations identified in that list should be required to be distributed as alerts to mobile devices.
    2. Should a new subcategory be defined to determine which subset of BI alerts are distributed through WPA? If so, should alerts in this subcategory have a new flag that identifies them for distribution through WPA?

Appendix 2: Interrogatories for Emergency Management Organizations (EMOs)

  1. In their intervention, Mobility & Wireless Solutions mentions that five tests per year “will result in user frustration and alert fatigue” (paragraph 7).
    1. Comment on how “user frustration and alert fatigue” would affect the success of the WPA initiative.
    2. Comment on whether the Commission should mandate a specific testing frequency, and explain.
    3. Comment on whether test alerts should be displayed on subscribers’ mobile devices in the same format as non-test alerts.
  2. Senior Officials Responsible for Emergency Management (SOREM) has set out a list of alerts which have been identified as Broadcast Immediately (BI) (this list can be found at: https://alerts.pelmorex.com/download/public/Broadcast%20Immediately%20-NAAD%20System%20Support%20Policy%20-%20V2.0%2020-Nov-2014.pdf). This list of “broadcast immediately” alerts has been used by the Commission in the context of the distribution of emergency alert messages by broadcasting undertakings. 
    1. Comment on whether any or all of the same emergency situations identified in that list should be required to be distributed as alerts to mobile devices.
    2. Should a new subcategory be defined to determine which subset of BI alerts are distributed through WPA? If so, should alerts in this subcategory have a new flag that identifies them for distribution through WPA?

Appendix 3: Interrogatories for Other Parties

  1. Specify how many SMS messages your system can queue. In your response, explain:
    1. whether there is a mechanism to prioritize alerts over other SMS messages;
    2. how many attempts are made to deliver an SMS message before it is discarded, and over what time period.
  2. In SMS-based WPA, explain how the delivery order of phone numbers would be determined.
  3. During a major event (e.g. sports games, large public gatherings, emergencies), where the mobile network is under heavy stress, explain how the delivery of alerts would be impacted for CB and LB-SMS.
  4. Explain how French accent characters – especially those not included in the GSM 7-bit alphabet – are handled in SMS messages, and what proportion of devices on your network are capable of receiving these accent characters.
  5. In its intervention at paragraph 9 Bruce Power suggests that LB-SMS WPA can be implemented today, and at paragraphs 21-22 Bruce Power submits should be used until a Cell Broadcast (CB) solution is ready (approximately 12 months, as many interventions stated). Explain whether and how such an implementation plan would affect the cost and time required to deploy WPA. In your response, address whether any additional cost ultimately be borne by the consumer.
  6. At paragraph 29 of Rogers Communications Canada Inc.’s intervention, the company discusses that SMS messages can be easily spoofed. Mobility & Wireless Solutions’ intervention (paragraph 29) says “With LB-SMS, the public could not be certain that an alert message was sent by an Authorized […] Alerting Authority”.  Explain how consumers can be assured of the authenticity of an SMS-based wireless public alert. 

Footnotes

Footnote 1

Wireless service providers include wireless carriers and non-carriers (resellers) that provide mobile wireless services.

Return to footnote 1

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