Telecom - Commission Letter addressed to the Distribution List (Parties to NOC 2020-326)
Ottawa, 10 December 2020
Our reference: 1011-NOC2020-0326
RE: Follow-up to Telecom Notice of Consultation 2020-326, Establishment of new deadlines for Canada’s transition to next-generation 9-1-1
In Telecom Notice of Consultation 2020-326 (the Notice), the Commission initiated a proceeding to establish new deadlines for Canada’s transition to next-generation 9-1-1 (NG9-1-1). In order to ensure that the Commission has the factual record necessary to make a determination, Commission staff is requesting more information from NG9-1-1 network providers and telecommunications service providers (TSPs).
Default Routing Capacity
In response to the Notice, TELUS Communications Inc. (TELUS) as well as Bell Canada and Bell Mobility Inc. (Bell) filed interventions in which they indicated that their ability to file accurate NG9-1-1 wholesale and retail tariffs is contingent on the Commission making a determination on the appropriate default routing Footnote1 call answer capacity. In this regard, these companies noted that while the Commission had determined that NG9-1-1 network providers and TSPs were required to have arrangements in place for default 9-1-1 call routing with a third-party call centre, it did not address what standards should apply to such default call routing. Footnote2
Both TELUS and Bell proposed to provision their respective default call handling solutions to handle up to 5% of all NG9-1-1 calls within their territory at any given time. In its intervention, TELUS submitted that it determined the 5% figure after factoring the current 2% rate of calls received without location information and adding a buffer of an additional 3% for new, unforeseen location failures associated with NG9-1-1 routing functions. Bell submitted that its figure is based on the input of subject matter experts.
Each NG9-1-1 network provider, by 21 December 2020, is to file with the Commission responses to the following requests for information:
- Provide or confirm your views as to the appropriate default call routing capacity (i.e. the volume of total NG9-1-1 calls
Footnote3that your default call routing solution must be able to handle), including all relevant formulas, facts, and assumptions employed to determine this capacity, and in doing so clarify whether the proposed default call routing capacity:
- corresponds to the estimated amount of NG9-1-1 calls that will require default call routing under normal circumstances; or
- whether the proposed capacity is higher than the estimated total volume of NG9-1-1 calls that will require default call routing under normal circumstances and, if so, what is the percentage of total NG9-1-1 calls that you estimate will require default call routing under normal circumstances.
- If, in answer to question 1 above, the NG9-1-1 network provider estimates the actual amount of NG9-1-1 calls requiring default routing under normal circumstances to equate to its proposed default call routing capacity, comment on why it is appropriate to provision your default call routing call solution to handle this amount and not provision in a measure of excess capacity, given the important public safety function played by 9-1-1 networks and services.
- Provide your views on what would be an appropriate measure of excess capacity (i.e. capacity in excess to the estimated amount of NG9-1-1 calls that will require default call routing under normal circumstances) and why.
- Provide comparative preliminary cost impact analysis for default call routing solutions provisioned for 2.5%, 5%, and 10% call volume capacities.
- Provide your views, with justification, as to whether it is appropriate to require a higher capacity for default call routing in the first few years of the implementation of NG9-1-1 services in light of the possibility that unforeseen failures may be more prevalent during such time, and,
- If this is the case:
- What that higher threshold should be and why;
- What time period should this higher threshold apply to;
- If this is the case:
- Provide complete details on the measures planned to be taken in the event that, under normal circumstances, the amount of calls requiring default routing ends up being higher than the amount currently estimated and/or the volume captured by any established default call routing threshold.
- Provide complete details on the reliability and resiliency measures planned relative to the Location Information Servers (LIS) in your NG9-1-1 network.
- Provide an estimate, supported by relevant formulas, facts, and assumptions, of the likelihood of
- an NG9-1-1 network outage resulting in a volume of NG9-1-1 calls requiring default call routing that exceeds the volume of calls that could be handled under your proposed default call routing threshold, and the strategies in place to respond to such scenarios; and
- an NG9-1-1 network outage resulting in 100% of NG9-1-1 calls needing to be default routed and the strategies in place to respond to such scenarios.
TSPs who are parties to NOC 2020-326, by 21 December 2020, are each requested to
- Provide your plans for the LIS functionality, that is, whether you will self-provision or make use of the NG9-1-1 network providers' hosted LIS functionality.
- If you plan on self-provisioning your own LIS, answer each RFI 1 through 8 above, making the necessary amendments in order to reflect your position.
- Regardless of your LIS strategy, provide complete details on additional potential situations in which default routing would be required but that are not directly relating to the proper functioning of the LIS to be used by your network.
In Telecom Regulatory Policy 2017-182, the Commission directed Bell Canada (Bell) and TELUS Communications Company (TELUS) to start NG9-1-1 Voice implementation trials with certain Public Safety Answering Points (PSAPs) and TSPs in their respective operating territories in 2018 and at the latest by the end of February 2019.
In response to the Notice, TELUS and Bell filed interventions in which they indicated that they would be in a position to have their NG9-1-1 networks ready to support NG9-1-1 Voice by 30 March 2021.
In CRTC Interconnection Steering Committee Emergency Services Working Group (CISC ESWG) Status Report – NG9-1-1 Voice Trial Logistics, 11 December 2019 (ESRE0091; the Report), the CISC ESWG highlighted the requirement for a normalization period between the conclusion of the NG9-1-1 trials and the launch of NG9-1-1 Voice services, during which the NG9-1-1 network providers and interconnected parties perform activities to transition from a testing environment employing test NG9-1-1 traffic to a production environment with live NG9-1-1 traffic. In the Report, Bell and TELUS proposed a duration of 30 days for this normalization period upon conclusion of the trials.
Given the request for this 30-day normalization period and Bell and TELUS’s assertion that they will be in a position to have their networks ready to support NG9-1-1 Voice by 30 March 2021, Bell and TELUS, by 21 December 2021, are each requested to:
- Confirm that it is in a position to complete its NG9-1-1 trial, as mandated, accounting for the 30-day normalization period they requested in order for their networks to be considered ready to support NG9-1-1 Voice. If not, propose mitigating strategies and/or alternative timelines along with complete justification.
Only parties that have filed interventions within the context of the Notice may file a reply only in relation to new matters raised in these requests for information. The deadline for filing replies is 15 January 2021.
Where a document is to be filed or served by a specific date, the document must be received, not merely sent, by that date. Additionally, all submissions to the Commission must be filed via My CRTC Account; must refer to the file number noted above; and, must be addressed to the Secretary General. Footnote4
As set out in section 39 of the Telecommunications Act and in Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Broadcasting and Telecom Information Bulletin 2010-961, as amended by Broadcasting and Telecom Information Bulletin 2010-961-1, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation of 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.
Original signed by
Director, Dispute Resolution & Regulatory Implementations
c.c.: Étienne Robelin, CRTC, firstname.lastname@example.org
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