Telecom Commission Letter Addressed to Dennis Béland (Québecor Média inc.)
Ottawa, 22 July 2016
Our reference: 1011-NOC2016-0116
Vice president, Regulatory affairs, Telecommunications
Québecor Média inc.
RE: Establishment of a regulatory framework for next-generation 9-1-1 in Canada, Telecom Notice of Consultation 2016-116 – Requests for information
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 Québecor Média inc..
Responses to these requests for information are to be filed with the Commission by 23 August 2016.
Original signed by
A/Director, Competition and Emergency Services Policy
c.c. Renée Doiron, CRTC, 819-997-2755, Renee.Doiron@crtc.gc.ca
James Ndirangu, CRTC, 819-997-3670, James.Ndirangu@crtc.gc.ca
- 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.
- 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.
- 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 benefits, feasibility, challenges, and possible risks as well as mitigation strategies to address those challenges and risks.
- 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?
- 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.
- 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.
- 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 Messager (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”).
- 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.
- 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.
- 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.
- Provide your view on the functionality that could be provided via this application.
- 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.
- 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.
- Are you aware of other countries that have developed mobile applications and, if so, what lessons were learned?
- 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?
- 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.
- Refer to paragraphs 18 to 20 and 25 of your intervention, in which you proposed that there should be a single NG9-1-1 network operator to serve Canada, and that this operator should be chosen by a national consortium through an RFP process.
- Clarify whether you are proposing that there should be one national NG9-1-1 network to receive all 9-1-1 calls from subscribers across Canada?
- Explain how, from a technical and operational standpoint, and under what arrangements (e.g. agreements between parties) this single NG9-1-1 network operator would interconnect with existing 9-1-1 networks, owned and maintained by ILECs, to ensure the seamless provision of 9-1-1 services during the transition to NG9-1-1?
- Explain how, from a technical and operational standpoint, originating TSPs would interconnect with this single NG9-1-1 network operator and under what interconnection arrangements? Would all TSPs have to establish new 9-1-1 interconnections with the national NG9-1-1 network operator?
- Explain how, from a technical and operational standpoint, and under what arrangements this single NG9-1-1 network operator would interconnect with existing PSAPs? Would the NG9-1-1 network operator have to establish new interconnections with each and every primary and secondary PSAP?
- Would the single NG9-1-1 network operator have to establish and enter into 9-1-1 agreements with all provincial and municipal governments responsible for the PSAPs?
- Would the single NG9-1-1 network operator be a telecommunications common carrier under the Telecommunications Act?
- What principles would guide the choice of operator and what, if any, oversight would the Commission have with respect to the selection of the NG9-1-1 network operator and the principles used to guide the selection process?
- If the proposed single NG9-1-1 network operator were to be chosen through an RFP process, how long would the term of the contract to provide the NG9-1-1 network last, and would the process for choosing the national ESInet(s) operator be repeated after the end of every contract term?
- Describe the process and arrangements contemplated with respect to the establishment of the proposed national consortium, including
- which entities should be members of this consortium and whether membership in this consortium would be mandatory or voluntary. If mandatory, what mechanism would be used to mandate participation? If voluntary, what mechanisms should be relied upon to ensure that membership is representative and not unduly restricted?
- what would be the consortium’s governance structure and responsibilities?
- what oversight would the Commission have over the consortium and how should this oversight be exercised to ensure accountability?
- Refer to paragraph 19 of your intervention, in which you submitted “We are of the opinion that there exist many advantages in regards to the establishment of a central independent entity to manage and operate NG9-1-1 network in Canada. Assuming Commission involvement is required to ensure NG9-1-1 funding, what mechanisms should be used to recover the set-up and operational costs involved under your proposal?
- 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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