Telecom - Staff Letter addressed to Chris Kellett (CRTC CISC - Emergency Services Working Group) and Richard Polishak (CRTC CISC – Network Working Group)

Ottawa, 22 February 2023

Our reference: 8621-C12-01/08

BY EMAIL

Chris Kellett
Chair
CRTC CISC - Emergency Services Working Group
chris.kellett@eswg9-1-1.ca

Richard Polishak
Chair
CRTC CISC – Network Working Group
Richard.Polishak@telus.com

Subject: Requesting recommendations from CRTC Interconnection Steering Committee (CISC) regarding network resiliency, outage mitigations and notification

This letter is to request a report with recommendations from CISC, for measures to improve network resiliency and reduce the impacts of outages in relation to 9-1-1 and public alerting, by 15 September 2023.

On 22 February 2023, the Commission launched a Notice of Consultation,Footnote1 that laid out its action plan to improve network resiliency and reliability for all carriers which included an action item to request assistance from CISC. 

The Minister of Innovation, Science and Industry tasked the Canadian Security Telecommunications Advisory Committee (CSTAC) with developing a Memorandum of Understanding (MoU) for major wireless service providers to provide emergency roaming, mutual assistance and communications to the public and governmental authorities during a critical network failure resulting from an impactful emergency. On 7 September 2022, the Minister issued a statement that the formal agreement had been reached by these companiesFootnote2

Further, the Minister requested CSTAC to produce a report outlining recommendations to improve network resiliencyFootnote3.

In TRP 2016-165Footnote4, the Commission assessed the reliability and resiliency of 9-1-1 networks in Canada and overall, found them to be reliable and resilient, as evidenced by the very few 9-1-1 networkFootnote5 outages which impacted the delivery of 9-1-1 calls to Public Safety Answering Points (PSAPs).

Canadians rely more than ever on telecommunications services, including access to 9-1-1Footnote6 and public alerting. For public alerting, this access involves wireless originating networks, whereas for 9-1-1, the access involves both wireline and wireless originating networks, as well as 9-1-1 networksFootnote7 and their interconnections to the originating networks. 

While the 9-1-1 networks have been found to be reliable and resilient, the recent major outages present an opportunity to review all relevant networks to improve overall resiliency.

In light of the foregoing, CISC is requested to provide the Commission a report with recommendations in relation to:  

  1. Mitigating strategies to reduce impacts of future originating and 9-1-1 network outages, as applicable, in relation to the provision of 9-1-1 and public alerting services;
  2. Solutions and measures, at the device and/or network levels, to increase access to 9-1-1 services during outages, for example:
    1. Whether 9-1-1 calls could be delivered to PSAPs during an originating network outage and if so, how; 
    2. What improvements could be implemented to the process in which a wireless 9-1-1 call from a handset connected to its subscribed network is handed over to another wireless network as an unregistered handset, when there is an outage in the subscribers’ wireless networkFootnote8;
    3. How will 9-1-1 calls be processed by WSPs when a subscriber places a call under emergency roamingFootnote9 and what information will be made available to PSAPs;
    4. How to inform Canadians about how to connect to 9-1-1 during outages, including potential consumer education messages; and 
    5. How to increase overall reliability and resiliency for 9-1-1 services.
  3. Solutions and measures, at the device and/or network levels, to increase access to wireless public alerts during outages,Footnote10 for example:
    1. Whether public alerts could be delivered via an alternative network, e.g., Wi-Fi, during a mobile wireless originating network outage, and if so, how;
    2. How to handle public alerts effectively during emergency roaming; and
    3. How to increase overall reliability and resiliency, including when Emergency Management Officers are submitting public alert information to the National Alert Aggregation and Dissemination system, and its network connections to the Emergency Management Officers, Mobile Wireless Carriers and other last mile distributors.
  4. The prioritization of access to 9-1-1 and public alerting during network recovery / service restoration;
  5. The expansion and updates to the 9-1-1/NG9-1-1 outage notification process to impacted parties e.g. PSAPs and Canadians, to include originating network outages that impact subscribers’ access to 9-1-1;
  6. The establishment of a notification process to impacted parties e.g., Emergency Management Offices and Canadians, for outages that impact the subscribers’ receipt of public alerts;
  7. The development of a communication plan with advice to impacted parties (e.g., PSAPs, EMOs and Canadians) on how to access 9-1-1 and receive public alerts, ahead of an outage and during; and
  8. Any other mitigating strategies, solutions or measures that would increase the overall reliability and resiliency in relation to 9-1-1 and public alerting.

Yours Sincerely,

Original signed by

Fiona Gilfillan
Executive Director
Telecommunications Sector

c.c.:   Michel Murray, CRTC, michel.murray@crtc.gc.ca
Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca
Mylène Germain, CRTC, mylene.germain@crtc.gc.ca
James Ndirangu, CRTC, james.ndirangu@crtc.gc.ca
Simon Levasseur, CRTC, simon.levasseur@crtc.gc.ca
Martin Proulx, ISED, martin.proulx@ised-isde.gc.ca
Andre Arbour, ISED, andre.arbour@ised-isde.gc.ca

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