ARCHIVED - Telecom Commission Letter Addressed to Distribution List

Ottawa, 21 December 2017

Our reference: 8662-P82-201707580

BY EMAIL

Distribution

Re:  Part 1 application to review and vary certain determinations made in Telecom Regulatory Policy 2017-182 by a group of PSAPs and 9-1-1 service organizations in Canada: Requests for information

Dear Madam, Sir:

In order to assist the Commission in its consideration of the issues set out in the above-named Part 1 application, Commission staff requests information from three large incumbent local exchange carriers (ILECs) as well as the Applicant (representing the list of PSAPs and authorities detailed in Appendix A of the application).  Questions specific to the ILECs are included in Appendix 1 and questions specific to the Applicant are included in Appendix 2.  The responses to these requests for information must be filed via My CRTC Account by 16 February 2018.^Footnote1

The Applicant is requested to provide a single, consolidated response, reflecting the views of PSAPs and authorities detailed in Appendix A of the application.  All responses from the Applicant and ILECs will be published on the Commission’s website under the file number identified above.

Interveners may file additional submissions to supplement or modify their interventions to respond to matters raised in the responses to the requests for information, and serve copies on all other parties, by 2 March 2018.  In addition, other interested parties who wish to file interventions to the additional information on the record may do so by that same date, serving copies on all other parties.  The Applicant may file a final submission in reply to matters raised in the responses to the requests for information and intervener submissions, and serve copies on all other parties, by 9 March 2018.

As set out in section 39 of the Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential.  A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure.  Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Should you have any questions regarding this letter, please contact Joel McGrath by email at joel.mcgrath@crtc.gc.ca.

Sincerely,

Original signed by

Philippe Kent
Director, Competition & Emergency Services Policy
Telecommunications Sector

c.c:  Renée Doiron, CRTC, 819-997-2755, renee.doiron@crtc.gc.ca
Joel McGrath, CRTC 819-635-7485, joel.mcgrath@crtc.gc.ca

attach:  NOC 2016-116 Intervener distribution list – Appendix 3

Distribution List

Large ILECs
Bell Canada bell.regulatory@bell.ca
Saskatchewan Telecommunications document.control@sasktel.com
TELUS Communications Company regulatory.affairs@telus.com

Applicant (on behalf of Public Safety Answering Points and authorities detailed in Appendix A of the Part 1 Application)
New Brunswick 9-1-1 Bureau, diane.b.pelletier@gnb.ca

Appendix 1

Interrogatories for Bell Canada, TELUS Communications Company and Saskatchewan Telecommunications

1. How does your company define the emergency services call centres in operation in your territory? Your response should indicate how you differentiate between primary PSAPs, secondary PSAPs, and other emergency services call centres and should include differences in call taking functionality such as triage and dispatch as appropriate.
2. List the individual PSAPs that operate in your serving territory and that are connected to your current 9-1-1 network. Your response should be submitted using the attached spreadsheet.
3. With regards to your company’s existing 9-1-1 tariffs, if access circuits to secondary PSAPs, as defined in your response above, are included:
   1. Does your company provision circuits to all or some secondary PSAPs in your territory?
   2. What criteria are applied to determine secondary PSAP connection eligibility and where is this criteria set out (e.g. agreements between your company and the province/municipality)?  Provide a sample copy of the document(s) setting out this criteria as appropriate.
4. In regards to the criteria used to determine the type and number of circuits provisioned to primary PSAPs and secondary PSAPs in your territory:
   1. Provide the criteria used to determine the type and number of circuits.
   2. Does your company or the PSAP make this determination?
   3. Where are the criteria set out?  Provide a sample copy of the document(s) as appropriate.
5. Describe how access circuits currently provisioned to primary and secondary PSAPs are monitored and managed by your company and comment on whether you see costs and/or risks associated to maintaining the reliability, resiliency and security of networks if your company is not the provider of access circuits to certain secondary PSAPs in your territory?
6. Are there any other risks to the roll-out of NG9-1-1 services of which the Commission should be aware if access circuits to secondary PSAPs are not included in your NG9-1-1 tariffs?
7. Refer to paragraph 16) c. of the Application, in which it was indicated that:

   …we are introducing the same issue seen with the Text with 9-1-1 implementation over the past four years (i.e., lack of an end-to-end platform delivery that has resulted in frustrations and delays. For NG9-1-1, this could result in never realizing a complete implementation of NG9-1-1 across Canada.

   Considering this statement, with regards to the connection of secondary PSAPs during the implementation and operation of the existing Text with 9-1-1 service, provide any implementation lessons learned that would positively or negatively affect the adoption of NG9-1-1 services by PSAPs in your operating territory.

8. With regards to secondary PSAPs in your operating territory that are currently Text with 9-1-1 and In-Call Location Update enabled, describe the incremental work effort required to prepare these organizations for NG9-1-1 services from a network perspective.
9. Do you expect the number of secondary PSAPs in Canada to significantly increase or decrease in the future and, if so, why?
10. If the Commission were to vary Telecom Regulatory Policy 2017-182 as requested by the Applicant, are there other Commission decisions that would require modification, for example in CRTC TRP 2017-182?  If so, specify the appropriate change.

Appendix 2

Interrogatories for Applicant

The Applicant should provide a single, consolidated response, reflecting the views of PSAPs and authorities detailed in Appendix A of the application, in order to facilitate accessibility and administrative processing.

1. How do you define the emergency services call centres in operation in Canada? Your response should indicate how you differentiate between primary PSAPs, secondary PSAPs, and other emergency services call centres and should include differences in call taking functionality such as triage and dispatch as appropriate.
2. List the individual PSAPs that operate in Canada and are currently connected to 9-1-1 networks. Your response should be submitted using the attached spreadsheet.
3. Do you expect the number of secondary PSAPs in Canada to significantly increase or decrease in the future and, if so, why?
4. Refer to paragraph 16) c. of your application, in which it was indicated that:

   …we are introducing the same issue seen with the Text with 9-1-1 implementation over the past four years (i.e., lack of an end-to-end platform delivery that has resulted in frustrations and delays. For NG9-1-1, this could result in never realizing a complete implementation of NG9-1-1 across Canada.

   Considering this statement, with regards to the connection of secondary PSAPs during the implementation and operation of the existing Text with 9-1-1 service, expand upon implementation lessons learned that would positively or negatively affect the adoption of NG9-1-1 services by PSAPs in your operating territory.

5. If the Applicant’s request is granted by the Commission, are there other Commission policy changes that would be required, for example in CRTC TRP 2017-182 or in other Commission decisions?

Appendix 3

List of Interveners to the CRTC Notice of Consultation 1011-NOC2016-116

Date modified:

2017-12-21