Telecom Commission Letter Addressed to Howard Slawner (Rogers Communications Canada Inc.)

Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116

BY EMAIL

Howard Slawner
Vice President, Regulatory Telecom
Rogers Communications Canada Inc.
rwi_gr@rci.rogers.com
simon-pierre.olivier@rci.rogers.com
nathalie.sageau@rci.rogers.com

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

Dear Mr. Slawner:

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 Rogers Communications Canada 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. 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.
  2. 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.  
  3. 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.
  4. 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?
  5. Refer to paragraph 34 of your intervention, in which you submitted that NG9-1-1 provides an opportunity to re-examine current 9-1-1 service funding mechanisms. You submitted that the incumbent local exchange carriers’ 9-1-1 tariffs are placing an unnecessary burden on the entire 9-1-1 system, and that a national consortium overseeing a single 9-1-1 database vendor selected through a competitive bidding process could result in significant operational and cost efficiencies.
    1. If a national consortium were created for the purpose of funding NG9-1-1,
      1. what steps would be required to set up such a consortium?
      2. what would be the consortium’s responsibilities?
      3. what would be appropriate mechanisms for funding the establishment and operation of the NG9-1-1 network by the consortium/administrator?
      4. what would be the appropriate voting structure within the consortium?
      5. regarding the possibility of existing 9-1-1 networks and NG9-1-1 networks operating concurrently, describe how the existing tariff-based funding model should be transitioned to a consortium-based funding model?
    2. Describe if and how your proposal of using a national consortium for NG9-1-1 would affect: your overall costs of providing NG9-1-1 services; the ease of administration; the transition to NG9-1-1; and consumers.
  6. 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.
  7. 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?
  8. 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?
  9. 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.
  10. Refer to paragraph 19 of your intervention, in which you proposed that a centralized primary PSAP be explored as an alternative to the ILECs’ 9-1-1 network model.
    1. Explain how this centralized PSAP would affect the deployment of NG9-1-1 network(s) and network interconnection arrangements with TSPs and PSAPs, as well as the potential continued use of existing 9-1-1 networks during the transition.
      1. Are you proposing that there should be one national primary PSAP to receive all 9-1-1 calls from subscribers across Canada?
      2. Explain what role existing primary and secondary PSAPs would play under this proposal, as well as the network and procedural arrangements that would be required to connect to them?
      3. Explain the network and 9-1-1 stakeholder arrangements required for this centralized PSAP to potentially interconnect with a national NG9-1-1 network or regional NG9-1-1 networks?
      4. Explain the 9-1-1 stakeholder arrangements and network changes required for this centralized PSAP to interconnect with the ILECs’ existing 9-1-1 networks during the transition?
      5. Explain the role and purpose of the NG9-1-1 network(s) under this proposal.
      6. What are the pros and cons of this proposal? For example, would 9-1-1 call routing not take longer if human intervention is necessary or an additional PSAP is added into the 9-1-1 call handling process?
      7. Are there other countries where this centralized primary PSAP model is being used? If so, are there lessons to be learned?
    2. Who should be responsible for establishing such a centralized PSAP; funding its operations; and determining its 9-1-1 call-handling policies and procedures, as well as arrangements with either primary PSAPs, secondary PSAPs and downstream emergency responder agency dispatchers?
    3. Explain what roles provincial/territorial and municipal governments would play in establishing and managing this centralized PSAP?
    4. How would arrangements and agreements with primary PSAPs, secondary PSAPs, or emergency responder agency dispatchers be established, and under what legislative framework?
  11. Refer to paragraphs 26 to 27 of your intervention, in which you proposed that a single NG9-1-1 network operator should serve Canada, and that this operator should be chosen by a national consortium through an RFP process. In paragraph 28, you proposed that the consortium be responsible for maintaining a single, nationwide database for call-routing purposes, along with the ALI/Phase II location information.
    1. 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?
    2. 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?
    3. Explain how, from a technical and operational standpoint, originating TSPs would interconnect with this new 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?
    4. 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?
    5. 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?
    6. Would the single NG9-1-1 network operator be a telecommunications common carrier under the Telecommunications Act?
    7. What principles would guide the choice of NG9-1-1 network 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?
    8. What formal mechanism, if any, would be instituted for the Commission to oversee this competitive bidding process? 
    9. 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?
    10. Describe the process and arrangements contemplated with respect to the establishment of the proposed national consortium, including
      1. Which entities should be members of this consortium and would membership in this consortium would be mandatory or voluntary. If mandatory, what mechanism should be used to mandate participation? If voluntary, what mechanisms should be relied upon to ensure that membership is representative and not unduly restricted?
      2. What would be the consortium’s governance structure and responsibilities?
      3. What oversight would the Commission have over the consortium and how should this oversight be exercised to ensure accountability?
    11. Explain what function the proposed centralized database would play in an NG9-1-1 network in relation to the current ALI database, new NG9-1-1 databases, or components that are expected to be replaced in the long term?
      1. Would the single NG9-1-1 network operator also be responsible for build and for maintaining this centralized database?
      2. If a different operator is responsible, would the operator be a telecommunications common carrier under the Telecommunications Act?

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?”.

Return to footnote 1

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