ARCHIVED - Telecom Commission Letter Addressed to Stephen Schmidt (TELUS Communications Company)

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Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116


Stephen Schmidt
Vice-President – Telecom Policy & Chief Regulatory Legal Counsel
TELUS Communications Company

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. Schmidt,

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 TELUS Communications Company.

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. Refer to paragraph 85 of your intervention, in which you indicated that annual reliability and resiliency reports regarding NG9-1-1 could be provided to the Commission, and that these reports could be identical to those regarding 9-1-1 network outages required by the Commission in Telecom Regulatory Policy 2016-165. 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. Refer to paragraphs 84 and 85 of your intervention, in which you indicated that the Commission should consider implementing quarterly reporting on NG9-1-1 network development, build and testing, security reports, as well as statistics and data related to PSAPs’ transition to NG9-1-1 infrastructure. Provide details regarding the specific data that should be part of these reports and explain, with supporting rationale, how such reports would help with the transition to NG9-1-1 networks or services and afterwards.
  3. 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.
  4. 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) 16-53Footnote1 result in the equipment manufacturers phasing out the capability to support TTY relay in their products.
  5. Refer to paragraph 71 of your intervention, in which you submitted that if funding from the Government of Canada is unavailable, the Commission should explore expanding the National Contribution Fund to include funding for the NG9-1-1 network and that 9-1-1 services should be designated as a basic telecommunications service under section 46.5 of the Telecommunications Act. Therefore, companies that build and operate the NG9-1-1 network could be eligible for funds from the National Contribution Fund for their capital and operating expenditures.
    1. If the National Contribution Fund were used to fund NG9-1-1,
      1. what steps would be required to set up such a fund?
      2. what would be an appropriate contribution formula?
      3. to whom would the obligation to contribute apply?
      4. how should such a fund be managed?
      5. what should be the associated reporting requirements?
      6. 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 National Contribution Fund model?
    2. Describe if and how your proposal of using the National Contribution Fund for NG9-1-1 would affect your company’s overall costs of providing NG9-1-1 services; the ease of administration; the transition to NG9-1-1; and consumers.
  6. 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:
    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  
  7. 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.
  8. 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?
  9. 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.
  10. 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?
  11. 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?
  12. 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.


Footnote 1

On 29 April 2016, the FCC issued NPRM 16-53 (, 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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