Telecom Commission Letter Addressed to Grainne M. Grande (MTS Inc.)

Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116

BY EMAIL

Grainne M. Grande
Director Regulatory & Privacy Officer
MTS Inc.
regulatory@mts.ca

RE:     Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116 – Requests for information

Dear Ms. Grande:

Pursuant to the procedure set out in Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116, 29 March 2016, attached are requests for information addressed to MTS Inc.

Responses to these requests for information are to be filed with the Commission by 23 August 2016.

Sincerely,

Original signed by Kim Wardle for/

Sheehan Carter
A/Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.    Renée Doiron, CRTC, 819-997-2755, Renee.Doiron@crtc.gc.ca
James Ndirangu, CRTC, 819-997-3670, James.Ndirangu@crtc.gc.ca

Attach. (1)


Attachment 1

  1. Refer to your response to question 11 in your intervention, in which you indicated that the reporting requirements regarding 9-1-1 network outages outlined in Telecom Regulatory Policy 2016-165 should be extended to NG9-1-1. Specifically, in that decision, the Commission required all 9-1-1 network providers to file with it an annual report on 9-1-1 network outages that cause 9-1-1 service outages, i.e. 9-1-1 network outages during which any number of 9-1-1 calls are not delivered to the primary PSAP’s demarcation point. Indicate, with supporting rationale, whether this current reporting requirement should be extended to methods of communication other than by telephone. If so, indicate to which method(s) the reporting requirement should be extended and if modifications should be made to the requirement to accommodate them.
  2. For each year in the period from 2010 to 2015, provide the number of TTY-relay calls completed. Specify how many of these are 9-1-1 calls.
  3. Explain the impact on your ability to offer TTY terminal equipment that support TTY 9-1-1 calls or their availability to consumers should the United States Federal Communications Commission (FCC) Notice of Proposed Rulemaking (NPRM) 16-53Footnote 1 result in the equipment manufacturers phasing out the capability to support TTY relay in their products. 
  4. In terms of funding the 9-1-1 networks and services that are under the Commission’s jurisdiction, refer to paragraph 11 of your intervention, in which you submitted that the current funding model, which uses Commission-approved tariffed rates, (i) provides the industry with the most appropriate means to recover its costs, (ii) is understood by both the industry and consumers, and (iii) is working well. You further submitted that it is essential that the cost recovery method for NG9-1-1 does not discourage or impede the evolution to NG9-1-1 and that telecommunications service providers must be able to recover the costs to upgrade their existing 9-1-1 systems and, in some cases, replace their 9-1-1 network with NG9-1-1 components and features.
    1. If the current funding model were used to fund NG9-1-1 networks, would any modifications be required? If so, describe these modifications and provide supporting rationale.
    2. How should existing 9-1-1 tariffs be transitioned to NG9-1-1 tariffs?
    3. Would the current tariff funding model for NG9-1-1 benefit consumers? If so, how?
  5. With respect to funding for current 9-1-1 networks, identify the revenues that your company derives from various sources, specifying total dollar amounts for the year 2015, by completing the following table:
    Funding for current 9-1-1 networks
    Revenue source Revenue in 2015 ($M)
    From the company’s wireline subscribers (in-territory)  
    From the company’s wireless subscribers(in-territory)  
    From charges to other service providers  
    a. competitive local exchange carriers  
    b. wireless service providers  
    c. other  
    Total  
  6. Refer to paragraph 10 of Ontario Provincial Police’s intervention, in which it submitted that “In order to ensure that NG9-1-1 services do not downgrade or delay emergency response, it is imperative that secondary PSAP agencies be in a position to support the same types of communication methods as the primary PSAPs”. Explain, with supporting rationale, whether secondary PSAPs should be interconnected to NG9-1-1 network(s), including the associated feasibility, benefits, challenges, and possible risks as well as mitigation strategies to address those challenges and risks.
  7. If so, should the interconnection of secondary PSAPs to the NG9-1-1 network(s) be included in the NG9-1-1 funding model and, if so, how should the cost of the interconnection be funded?
  8. PSAPs have stressed the importance of the provision of automatic location information as a pre-requisite to the rollout of the use of text messaging to 9-1-1 by the general public.
    1. Provide your view on the status and feasibility of automatically providing location information with a text messaging service used by all Canadians in an NG9-1-1 environment.
    2. Given the popularity and variability of mobile applications, explain how best to manage the various texting and instant messaging technologies that could be used in an NG9-1-1 environment (e.g. standards-based [Short Message Service (SMS), Multimedia Message Service (MMS), and Real-time Text (RTT)], proprietary [BlackBerry Messenger (BBM), imessage], over the top — such as Facebook messenger, Snapchat, and Whatsapp). Include any limitations, such as whether location information is available, whether multimedia (e.g. pictures and videos) can be attached, and delivery priority (e.g. delivered on a “best-effort basis”).
    3. Refer to paragraph 12 of Calgary 9-1-1’s intervention, in which it indicated that the use of SMS is declining in favour of application-based messaging services. Provide your view on usage trends for the various texting methods, as well as how these trends will impact which methods of communication consumers will use in the future and for which methods the Commission should mandate support to be used to access 9-1-1.
  9. In paragraphs 32 to 34 of its intervention, Calgary 9-1-1 submitted that developing an NG9-1-1 mobile application may provide a transparent, end-to-end connection between users and PSAPs.
    1. Provide your view on the feasibility, benefits, and/or challenges of developing such an application, which entities should be responsible for developing and managing such an application, and if such an application should be built for use across Canada. 
    2. Provide your view on the functionality that could be provided via this application.
    3. Provide your view on the feasibility, benefits, and/or challenges of funnelling voice and text messages in which emergency responses are requested via a mobile application.
    4. Provide your view on whether a mobile application could be used to collect additional user-inputted data, the data that should be collected, as well as the benefits and challenges of this approach.
    5. Are you aware of other countries that have developed mobile applications and, if so, what lessons were learned?
  10. In paragraphs 36 and 38 of its intervention, Toronto Police Service submitted that data used for emergency service purposes must come from a reliable, verifiable source, so that erroneous information does not complicate or impede emergency responses. Who should verify this data and how?
  11. Leveraging lessons learned during the recent rollout of Text with 9-1-1 for Canadians who are Deaf, hard of hearing, or have a communication disability, should the rollout of NG9-1-1 services be coordinated and rolled out at the regional, provincial, or individual PSAP level? Explain the benefits, challenges, and risk mitigation strategies associated with your proposal.

Footnotes

Footnote 1

On 29 April 2016, the FCC issued NPRM 16-53 (https://www.fcc.gov/document/real-time-text-nprm), in which it proposed amendments to its rules “to facilitate a transition from outdated text telephone (TTY) technology to a reliable and interoperable means of providing real-time text communication for people who are deaf, hard of hearing, speech disabled, and deaf-blind over Internet Protocol (IP)-enabled networks and services.” Specifically, in Appendix C, paragraph 3, the FCC seeks comment on “…its proposal that service providers should be required to make their RTT services interoperable with TTY technology supported by circuit-switched networks, and when that requirement should sunset” [emphasis added]. In paragraph 65, the FCC seeks comment on “…what events or measures should trigger a sunset of the residual obligation for wireless networks to be backward compatible with TTY technology.” In paragraph 99, the FCC seeks comment on “…how should TTY support obligations be modified as wireline networks discontinue their circuit-switched services?”.

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