Telecom Commission Letter Addressed to Edward Antecol (WIND Mobile Corp.)

Ottawa, 22 July 2016

Our reference: 1011-NOC2016-0116

BY EMAIL

Edward Antecol
VP Regulatory and Carrier Relations
WIND Mobile Corp.
eantecol@windmobile.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 Mr. Antecol,

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 WIND Mobile Corp.

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) 16-53Footnote1 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. 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.
  6. 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?
  7. 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?
  8. 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.
  9. Refer to paragraph 5 of your intervention, in which you proposed that ESInets be interconnected at the provincial level (i.e. multiple ESInets) to form an IP-based inter-network (network of networks), or that there be one national ESInet shared by all public safety agencies. In addition, you proposed that an industry consortium be used to build/procure the ESInets and administer them. In paragraph 10, you proposed that standard procurement processes apply to ESInets and PSAP systems, and that processes should be implemented for the development of procurement requirements (including service level requirements), the issuance of an RFP, contracting, installation, and testing.
    1. Describe the process and arrangements contemplated with respect to the establishment of the consortium, including
      1. Which entities should be members of the proposed national consortium?
        • Would membership in this consortium 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?
      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?
    2. Explain how the proposed industry consortium would develop the procurement requirements (including service level requirements), as well as build/procure the ESInets and administer them?
      1. Would one or more ESInet operator(s) be chosen?
      2. 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?
      3. Would the single NG9-1-1 network operator be considered a telecommunications common carrier under the Telecommunications Act?
      4. 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?
      5. What formal mechanism, if any, would be instituted for the Commission to oversee this competitive bidding process? 
      6. How long would the term of the contract to provide the ESInets last, and would the process for choosing the national ESInet(s) operator(s) be repeated after the end of every contract term?
      7. Explain how and under what arrangements the ESInet(s) would interconnect with existing 9-1-1 networks, owned and maintained by ILECs, to ensure the seamless provision of 9-1-1 services?
      8. How would originating TSPs interconnect with the new ESInet(s) and under what interconnection arrangements? Would all TSPs have to establish new 9-1-1 interconnections with the ESInets?
      9. Explain how the ESInet(s) would interconnect with existing PSAPs? Would an ESInet operator have to establish new interconnections with each and every primary and secondary PSAP?

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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