ARCHIVED - Telecom Commission Letter Addressed to Paul Cowling (Shaw Telecom G.P.)

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Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116


Paul Cowling
VP, Legal and Regulatory Affairs
Shaw Telecom G.P. 

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. Cowling:

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

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,
James Ndirangu, CRTC, 819-997-3670,

Attach. (1)

Attachment 1

  1. NG9-1-1-capable PSAPswill not only continue to receive and process 9-1-1 voice calls using existing 9-1-1 services, but may also interact with Canadians using new NG9-1-1 services, i.e. new methods of communication, such as text or multimedia messaging services, social media, and telematics (e.g. automatic collision notification systems in vehicles, medical alert systems, sensors, and alarms of various types). From the perspective of emergency responders,
  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) 16-53 result in the equipment manufacturers phasing out the capability to support TTY relay in their products.
  3. Refer to your response to Q.9 at page 12 of Attachment 1 to your intervention in which you submitted that with respect to how best to oversee or provide funding for the transition to NG9-1-1, the Commission may wish to explore a model similar to that used by the industry to establish national porting services through the Canadian Local Number Portability Consortium. You submitted that this type of industry manager approach for NG9-1-1 services could provide similar benefits, such as centralized administration, management of competitive bidding and vendor relationships, and greater cost efficiencies than the current regional approach to 9‑1-1 services.
    1. If an industry manager/consortium approach were created for the purpose of funding NG9-1-1, provide additional details such as: what steps would be required to set up such a consortium; what would be the consortium’s responsibilities; what would be appropriate mechanisms for funding the establishment and operation of the NG9-1-1 network by the consortium/administrator; what would be the appropriate voting structure within the consortium; and 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.
  4. 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.
  5. 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?
  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 10 of your intervention, in which you proposed that the Commission should establish one, or more, interconnected national ESInet(s) and that the national ESInet provider(s) should be selected through a transparent competitive bidding process. You also proposed that provincial/territorial governments should establish regional ESInets to support the PSAPs’ transition to NG9-1-1, and that all regional ESInets should be required to interconnect to the national ESInet(s) for the routing of SIP-enabled 9-1-1 calls
    1. Clarify whether you are proposing that there be a single national NG9-1-1 network to receive all 9-1-1 calls from subscribers across Canada, with another redundant national ESInet, or whether there should be multiple national ESInets managed by different ESInet providers? What would be the pros and cons of your proposal and why?
    2. Explain the purpose of establishing the proposed regional ESInets if a national ESInet(s) has/have been established?
    3. Explain the process that provincial/territorial or municipal governments would undertake to establish the proposed regional ESInets?
    4. Explain how, from a technical and operational standpoint, and under what arrangements the national ESInet(s) and reginal ESInets would interconnect with the existing 9-1-1 networks, owned and maintained by ILECs, to ensure the seamless provision of 9-1-1 services during the transition
    5. Explain how, from a technical and operational standpoint, originating TSPs would interconnect with the national ESInet(s) and/or regional ESInets, and under what interconnection arrangements? Would all TSPs have to establish new 9-1-1 interconnections with the national ESInet(s) or regional ESInets?
    6. Explain how, from a technical and operational standpoint, the national ESInet(s) would interconnect with existing PSAPs and the regional ESInets, and under what interconnection arrangements? Would the national ESInet operator(s) have to establish new interconnections with each and every primary and secondary PSAP?
    7. Would the ESInet operator(s) have to establish and enter into 9-1-1 agreements with all provincial and municipal governments responsible for the PSAPs and/or the regional ESInets?
    8. Would the national ESInet operator(s), and/or the provincial/territorial governments that establish the proposed regional ESInets, be telecommunications common carriers under the Telecommunications Act?
    9. Would the PSAPs connect with a regional or national ESInet, and how would the Commission ensure that the PSAPs connect with such networks in the event that they are not operated by the existing 9-1-1 network provider, with which PSAPs currently interface?
    10. Do you anticipate the establishment of conditions of service requiring the routing of all 9‑1‑1 communications over these national/regional ESInets, and to whom would these conditions of service apply?
    11. If the proposed national ESInet operator(s) would be selected through a competitive bidding process
      i.which entity would conduct this process?
      ii. would the Commission, or any other government authority, oversee the ESInet operator selection process?
      iii. what formal mechanism(s), if any, would be instituted to oversee this competitive bidding process and what principles should guide the selection process?
      iv. how long would the term of the contract to provide the national ESInet(s) last, and would the process for choosing the national ESInet(s) be repeated at the end of every contract term?
  11. In paragraph 10 of your submission, you proposed the establishment of a National Location Verification Database containing the Master Street Address Guide for all regions across Canada, and that all network access providers (e.g. ILECs, CLECs, ISPs, WSPs, WISPs, resellers, and satellite operators) create LIS databases for all endpoints within their networks to enable location discoverability
    1. Explain what functions the proposed National Location Verification Database and LIS, GIS, or other NG9-1-1-location-related databases or components would have in an NG9-1-1 network, and in relation to each other.
    2. Clarify why, if it is beneficial to have a National Location Verification Database, it would not similarly be beneficial to have a national, regional, or centralized LIS database(s)?
    3. Explain which entity would be responsible for establishing, maintaining, and funding the proposed National Location Verification Database. Would there be any government or regulatory oversight over this entity, and if so, by whom?
    4. What arrangements would be required to ensure that the National Location Verification Database is kept accurate and up to date based on changes or additions of street addresses by municipal governments nationwide?
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