ARCHIVED - Telecom Commission Letter Addressed to the Distribution List

Ottawa, 17 August 2018

Our reference: 1011-NOC2018-0105

BY E-MAIL

To: Distribution List

Re: Request for information related to Next-generation 9-1-1 (NG9-1-1) network design efficiencies

Dear Madam/Sir:

In Telecom Notice of Consultation CRTC 2018-105, Next-generation 9-1-1 network design efficiencies, dated 26 March 2018, the Commission initiated a proceeding to examine matters related to Next-Generation 9-1-1 (NG9-1-1) network design efficiencies, including roles and responsibilities related to the provision of location information servers and customer information databases, NG9-1-1 network components that could be shared, and efficient interconnection arrangements.

In order to assist the Commission in its consideration of the issues set out in the Notice of Consultation, information is being requested from all large incumbent local exchange carriers (ILECs) and small ILECs, as well as from other telecommunication service providers who provide 9-1-1 services (TSPs) and have intervened in this proceeding, either directly or through an association (collectively, the TSP intervenors). To support a common understanding, background information is provided in Appendix 1. The questions are then set out in Appendix 2. The responses to these questions must be filed via My CRTC Account by 17 September 2018.  Parties may file reply comments by 1 October 2018. ^Footnote1

It is Commission staff’s understanding that the location (e.g. city/town) of the existing 9-1-1 points of interconnection (POIs), as well as the proposed NG9-1-1 POIs, are not publicly disclosed by the 9-1-1 network operators for security reasons.  Notwithstanding the sensitivity of this information, Commission staff is of the view that knowledge of the location of these POIs could greatly assist parties in providing their responses. 

As such, it is requested that this information be appropriately shared with TSP intervenors upon request.

Responses are to be submitted in a single document in order to facilitate accessibility and administrative processing.  Parties may choose to coordinate, organize, and file, their responses in conjunction with other parties who share their positions.  These responses will be published on the Commission’s website under the file number identified above.

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 as to 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 any questions related to these requests arise, please contact Mylène Germain by email at mylene.germain@crtc.gc.ca.

Sincerely,

Original signed by

Philippe Kent
Director, Competition and Emergency Services Policy
Telecommunications Sector

c.c.:  Mylène Germain, CRTC, 819-635-4538, mylene.germain@crtc.gc.ca;
James Ndirangu, CRTC 819-997-3670, james.ndirangu@crtc.gc.ca.

Attach.

Distribution List

cedwards@ccsaonline.ca; Regulatory@sjrb.ca; regulatory@cnoc.ca; regulatory.matters@corp.eastlink.ca; jonathan.holmes@itpa.ca; bell.regulatory@bell.ca; patrick.desy@quebecor.com; rob.olenick@tbaytel.com; simon.desrochers@cogeco.com; rwi_gr@rci.rogers.com

Appendix 1: Background information

When Canadians request 9-1-1 emergency assistance, in order for their request to reach the Public Safety Answering Point (PSAP) which serves the area where the call originates, a number of networks must be interconnected, at various POIs.

The networks on which all 9-1-1 emergency requests originate are known as the originating networks, and are operated by TSPs^Footnote2 who provide 9-1-1 services.  These TSPs, including ILECs and small ILECs, will have the obligation to provide their end users with access to NG9-1-1 network(s) in their operating territories (herein referred to as the NG9-1-1 retail obligation).  This access will be provided by transiting the TSP’s NG9-1-1 traffic to NG9-1-1 POIs where the TSP’s originating network is interconnected with the NG9-1-1 network(s), which is in turn connected to the PSAP(s) serving the originating network’s footprint.  

As set out TRP 2017-182, and amended in TD 2018-188, the Commission defined the boundaries of the NG9-1-1 network as beginning at and including the POIs between the originating networks and the NG9-1-1 networks, and ending at the demarcation points between the NG9-1-1 networks and the primary and secondary PSAPs.  The main purpose of the NG9-1-1 network is to route the 9-1-1 emergency requests from the TSP’s originating network to the appropriate PSAP, that is, the PSAP which serves the area from which the emergency request originates. 

In TRP 2017-182, the Commission mandated ILECs, including small ILECs, to provide NG9-1-1 networks in their serving territories, in order to offer TSPs who operate within their incumbent territory wholesale access to their NG9-1-1 networks wherever provincial, territorial, and/or municipal governments have established PSAPs (herein referred to as the NG9-1-1 wholesale obligation). All ILECs, regardless of whether they outsource some or all of their NG9-1-1 network functionality, are considered to be NG9-1-1 network providers.

Further, in TRP 2017-182, the Commission determined that NG9-1-1 networks were to be interconnected to form a national network of networks.  In TD 2018-217, the Commission also approved recommendations from the CRTC Interconnection Steering Committee (CISC) relating to these interconnections, where each NG9-1-1 network (ESInet) is connected to every other ESInet, (herein referred to as the as ESInet-to-ESInet interconnection obligation), using geo-redundant POIs with a physical separation of at least 100 km. 

ILECs can meet their obligations to provide an NG9-1-1 network either directly, by building their own NG9-1-1 network and POIs (self-provisioning), or indirectly, by outsourcing NG9-1-1 functionality to another ILEC (outsourcing).  

Appendix 2: Questions for TSP intervenors

In answering the following questions, justify your response with supporting evidence and rationale.

To large and small ILECs

1. Submit the number and location (e.g. city/town) of all current 9-1-1 POIs. For each POI, indicate which are used to interconnect with TSPs’ originating networks, and which are used to interconnect with other ILECs. In the case of POIs that are used to interconnect with other small or large ILECs, indicate the name of the ILEC(s).
2. Submit the annual cost to transit 9-1-1 traffic (i.e. 9-1-1 voice trunks) from the small ILECs’ territory to the current 9-1-1 POIs, on a per small ILEC basis.
3. In applying the NG9-1-1 regulatory framework in conjunction with the large ILEC’s proposed interconnection framework, small ILECs would be required to:
1. provide their end users access to their NG9-1-1 network in order to route 9-1-1 emergency requests to the appropriate PSAP, using a minimum of two geo-redundant NG9-1-1 POIs^Footnote3 designated to interconnect their originating network with their NG9-1-1 network;
2. provide TSPs who operate within their territory with wholesale access to their NG9-1-1 network and using a minimum of two geo-redundant NG9-1-1 POIs designated for the TSP’s originating network to interconnect with their NG9-1-1 network, in order to route 9-1-1 emergency requests to the appropriate PSAP;
3. determine whether additional POIs are to be provided and determine the location of the these POIs;
4. connect their NG9-1-1 ESInets with all the other ESInets in a geo-redundant fashion, using NG9-1-1 POIs designated for this interconnection; and
5. assume the cost to transit their retail and wholesale NG9-1-1 traffic to the NG9-1-1 POIs.

As part of their outsourcing arrangement with a large ILEC, a small ILEC may opt to designate its NG9-1-1 POIs as their neighboring large ILEC’s NG9-1-1 POIs for the above-mentioned interconnections.

The large ILECs submitted that POIs represent a significant portion of the upfront and ongoing costs for NG9-1-1 networks and that significantly reducing the number of POIs will increase their network efficiency thereby reducing NG9-1-1 costs, for themselves and for the interconnecting parties. Conversely, small ILECs submitted that because the proposed geo-redundant NG9-1-1 POIs would, in most cases, be located further away than their current POIs, their cost to transit their 9-1-1 traffic to these POIs would increase, and their network efficiency would decrease. In addition, the small ILECs submitted that they have a smaller retail and wholesale base from which to recover the increased NG9-1-1 transit costs, which would results in higher rates for their retail and wholesale customers. Further, the small ILECs’ NG9-1-1 networks must be interconnected with the neighboring large ILEC’s NG9-1-1 network in order to meet their (i) retail and wholesale obligations, given that most small ILECs’ end users are served by PSAPs located outside of their territory and therefore connected to the large ILEC’s NG9-1-1 network, and (ii) ESInet-to ESI-net interconnection obligations. For these reasons, the small ILECs submitted that it is appropriate to maintain a shared-cost transit agreement, with the neighboring large ILEC, as is the case in Enhanced 9-1-1. 

1. Submit the estimated annual cost for small ILECs to transit their NG9-1-1 traffic (i.e. NG9-1-1 i3-compliant IP trunks) from their territory to the proposed NG9-1-1 POIs, on a per small ILEC basis.
2. Should the Commission see fit to balance network efficiencies and costs between small and large ILECs, and if a small ILEC was to interconnect with its neighboring large ILEC at the proposed NG9-1-1 POIs, comment on the appropriateness of using a shared-cost transit model.  In this model, the cost for the facilities used to transit the NG9-1-1 traffic to the proposed NG9-1-1 POIs would be shared, where the small ILEC would be responsible for the cost to transit their NG9-1-1 traffic to the border of their serving territory or a mutually agreed upon point, and their neighboring large ILECs would be responsible for the cost to transit the traffic from this point to their proposed NG9-1-1 POIs.
3. Assuming that the model identified in (b) was adopted, should all small ILECs be eligible or should only certain small ILECs qualify for cost sharing? If the latter, what criteria should be used to determine whether a small ILEC qualifies (e.g. based on telecommunications operating revenues, based on subscriber counts, based on transit distance to NG9-1-1 POIs, based on costs, etc.). If so, what should those threshold values be?  
4. Assuming that the model identified in (b) was adopted, comment on whether some form of transition regime is required to deal with situations where a small ILEC no longer meets the criteria proposed in c) above and, if so, how that transition regime should be structured.
5. Assuming that the model identified in (b) was adopted, comment on whether the boundary to the small ILEC’s territory, a mutually agreed point, or another delineation should be used.

6. Assuming that the model identified in (b) was adopted, submit the estimated annual cost for which the small and large ILECs would be responsible, respectively, for the transit of the small ILEC’s NG9-1-1 traffic (i.e. NG9-1-1 i3-compliant IP trunks) from their territory to the proposed NG9-1-1 POIs, on a per small ILEC basis.

To TSPs

4. Submit the annual cost to transit your 9-1-1 traffic (i.e. 9-1-1 voice trunks) from your territory to the existing 9-1-1 POIs, on a per large ILEC basis.

5. Submit the estimated annual cost to transit your NG9-1-1 traffic (i.e. NG9-1-1 i3-compliant IP trunks) from your territory to the proposed NG9-1-1 POIs, for each large ILEC.

To large ILECs and TSPs

6. In their joint intervention to this proceeding, the large ILECs^Footnote4 proposed an interconnection framework between the TSPs’ originating networks and the NG9-1-1 networks, whereby:
1. NG9-1-1 network providers provide a minimum of two geo-redundant NG9-1-1 POIs, determine whether additional POIs are to be provided and determine the location of the these POIs within their serving territory;
2. geo-redundant POIs are defined as having a physical separation of at least 100 km;
3. TSPs interconnect with each NG9-1-1 network that they must interconnect with at a minimum of two geo-redundant NG9-1-1 POIs using diverse paths to reach the POIs;
4. NG9-1-1 traffic is delivered in a localized fashion;^Footnote5 and
5. TSPs are responsible for the cost to transit their NG9-1-1 traffic to the POIs, as is the case for E9-1-1.

The large ILECs submitted that these POIs represent a significant portion of the upfront and ongoing costs for NG9-1-1 networks and that significantly reducing the number of POIs will increase their network efficiency thereby reducing NG9-1-1 costs for themselves and the interconnecting parties. Conversely, some TSPs submitted that because there are fewer geo-redundant NG9-1-1 POIs to choose from, and because these POIs would, in most cases, be located further away than their current POIs, that their cost to transit their NG9-1-1 traffic to these POIs will increase, which decreases their network’s efficiency.

1. Should the Commission see fit to balance network efficiencies and costs between NG9-1-1 network providers and smaller TSPs, comment on the appropriateness of using a shared-cost transit model. In this model, the cost for the facilities used to transit the NG9-1-1 traffic to the proposed NG9-1-1 POIs would be shared, where TSPs would be responsible for the cost to transit their NG9-1-1 traffic to the border of their territory or a mutually agreed upon point, and the large ILEC would be responsible for the cost to transit the traffic from this point to their proposed NG9-1-1 POI(s).
2. Assuming that the model identified in (a) was adopted, should all TSPs be eligible or should only certain TSPs qualify for cost sharing? If the latter, what criteria should be used to determine whether a TSP qualifies (e.g. based on telecommunications operating revenues, based on subscriber counts, based on transit distance to NG9-1-1 POIs, based on costs, etc.). If so what should those threshold values be?  
3. Assuming that the model identified in (a) was adopted, comment on whether some form of transition regime is required to deal with situations where a TSP no longer meets the criteria proposed in (b) above and, if so how that transition regime should be structured.
4. Assuming that the model identified in (a) was adopted, comment on how to define a TSP’s boundary as TSPs’ serving territories may not be contiguous and may evolve over time.  If the serving territory boundary is not a practical delineation, propose other solutions.

5. Assuming that the model identified in (a) was adopted, submit the estimated annual cost for which the eligible TSPs and the large ILECs would be responsible, respectively, for the transit of the TSP’s NG9-1-1 traffic (i.e. NG9-1-1 i3-compliant IP trunks) from their territory to the proposed NG9-1-1 POIs, on a per large ILEC basis.

To TSP intervenors

7. In order to balance NG9-1-1 network efficiencies and cost effectiveness for TSPs and small and large ILECs, another solution could be requiring the large ILECs to establish additional NG9-1-1 POIs for the interconnection of TSPs and small ILECs.
1. Comment on whether it would be appropriate to establish POIs, in addition to those proposed by the large ILECs, for interconnection with either TSPs or small ILECs, as an alternative to the shared-cost transit model contemplated in the questions 3 and 6 above;

2. Propose the number and location (e.g. city/town) of additional POIs that would likely balance the costs from large ILECs, TSPs and small ILECs, as an alternative to the shared cost approach. Please provide supporting evidence and rationale for each POI proposed.

To large ILECs

8. Submit the estimated costs for a typical NG9-1-1 POI and for any additional NG9-1-1 POI(s) which you propose in 7(b). 

9. In your reply to the parties’ responses, submit the estimated cost for each additional NG9-1-1 POI proposed by parties in 7.b.

To small ILECs

10. Small ILECs have indicated that CityWest and TBaytel have PSAPs within their territory.  In TD 2018-188, the Commission defined a secondary PSAP as being a PSAP to which NG9-1-1 calls are transferred from a primary PSAP and which is directly interconnected to an NG9-1-1 network allowing for the receipt and display of NG9-1-1 call data.  In light of this definition, indicate whether there are any secondary PSAPs within each of the small ILECs’ incumbent territory, and if so, provide a list them and indicate in which small ILECs’ incumbent territory they are located. 

Date modified:

2018-08-17