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Telecom - Staff Letter addressed to Trey Forgety (Apple Inc.)

Ottawa, 1 March 2023

Our reference: 8621-C12-01/08

BY EMAIL

Trey Forgety
Emergency Systems Strategist
Apple Inc.
One Apple Park Way
Cupertino, CA 95014
tforgety@apple.com

Subject: Request for Information regarding Apple Inc.’s Emergency SOS via satellite and Crash Detection services

Dear Trey Forgety,

On 19 October 2022, members of the CISC Emergency Services Working Group (ESWG) received a presentation from Apple Inc. (Apple) regarding Emergency SOS via satellite and Crash Detection services. Whereas the crash detection service had already been launched with the release of various new Apple devices in September 2022, Apple launched the Emergency SOS via satellite service in Canada and the United States on 15 November 2022. Commission staff recognizes that by enabling Canadians to contact emergency services in instances in which they may be unable to use traditional means, these new services can benefit Canadians in emergency situations.

Having reviewed the presentation and materials provided by Apple to the ESWG, staff understands that there are variations between Canadian and US deployments of the Emergency SOS via satellite service. Further, staff has been made aware through news reports regarding certain issues with the Crash Detection service which have resulted in a number of reported false positives.

In order to better understand the operation and provision of Apple’s Emergency SOS via satellite service in Canada as well as to gain better insight into Crash Detection issues, staff requests that Apple provide comprehensive answers to the questions set out in the attachment, including rationale and any supporting information, by 31 March 2023.

This letter and any subsequent correspondence may be publically accessible. As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, Apple may designate certain information as confidential though 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, should Apple designate information as confidential, Apple 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.

Where a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date.

The Commission requires all documents to be submitted electronically by using the secured service “My CRTC Account” Partner Log In or GCKey and filing the “Telecom Cover Page” located on that web page.

Yours Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

cc: Etienne Robelin, Manager, Emergency Services Policy, CRTC (etienne.robelin@crtc.gc.ca)
James Ndirangu, Manager, Networks Technology, CRTC (james.ndirangu@crtc.gc.ca)

Attach. (1)

Attachment 1 Request for Information

The following documents are referenced in the various sections below:

  1. Emergency SOS via Satellite – Operations Guide for PSAPs, September 2022;
  2. Webinar Video_Emergency SOS via satellite & Crash Detection.mov;
  3. Emergency SOS via Satellite Introduction.mov;
  4. Enhanced Emergency Data Tech Paper for Public Safety 09-2020.pdf, September 2020;
  5. E_Final_Emergency SOS via satellite webinar.pdf;
  6. Use Emergency SOS via satellite on your iPhone 14 (webpage); and
  7. E_Final_Crash Detection_Executive Overview.pdf.

SECTION A. HANDLING SATELLITE TEXTS

In Ref A, it is stated that “Emergency SOS via satellite uses existing equipment, interfaces, and processes for Text-to-911. No additional software, hardware, integrations, peripherals or downloads are needed.” Further, Ref B states that the user-input questionnaire is “designed for interoperability with the most common protocol-based call-taking and dispatch systems used in the United States, Canada, and around the world.” Ref B also indicates that the flow of a text goes from iPhone > Satellite > Text Control Centre (TCC) > Emergency Services.

Given that Text-to-911 and TCCs are not in use in Canada – texting with PSAPs is available through the Text with 9-1-1 (T9-1-1) service which requires the PSAP operator to initiate a texting sessions operator upon receipt of a voice call from a registered mobile device,Footnote1 CRTC staff understand that “direct-to-PSAP” satellite texting is not currently available in Canada. Given this, please answer the following:

Q1. Are there plans to implement “direct-to-PSAP” Emergency SOS via satellite texting in Canada?

Q2. Ref C indicates that users will “automatically be connected to the right emergency services provider.” How would “direct-to-PSAP” Emergency SOS via satellite texts be routed to the appropriate PSAP in Canada?

Q3. What would be the expected dispatcher workflow in Canada for the handling of satellite texts that arrive directly at the PSAP?

Q4. Would any part of the direct-to-PSAP satellite text session interact or interconnect with the 9-1-1 networks (Enhanced and/or Next-Generation)?

SECTION B. HANDLING EMERGENCY RELAY CALLS

Ref A indicated that “For emergency texts from users in the United States, calls from the emergency relay centre will be automatically routed to the PSAP that serves the user’s location based on the location estimate that accompanies that user’s first emergency text” and “For emergency texts originated by users outside the United States, emergency relay telecommunicators must first contact a third-party routing provider, and describe the user’s location and emergency type.” In light of this, CRTC staff understands that for all satellite texts originating in Canada, a third-party routing provider must be used in order to route the relay centre’s call to the appropriate PSAP.  

Q1. Identify the third-party routing provider(s) Apple uses in Canada to determine the most appropriate PSAP.

Q2. Are there plans to make automatic routing available in Canada? If so, would the process be the same as in place in the United States?

Q3. Does manual routing in Canada leverage operator services such as Zero-Dialed Emergency Call Routing Service (0-ECRS)Footnote2?

Q4. What quality of service standards are in place with regards to call answer and call transfer times to ensure the most rapid response to the user’s emergency possible?

Ref F indicates that “At launch, this service supports American English, American Spanish, and Canadian French.”

Q5. What mechanisms have been put in place to ensure that the user is able to communicate effectively with the relay centre operator in the Canadian official language of the user’s choice, i.e. the language in which the satellite texts are received at the relay centre?

Q6. What mechanisms have been put into place to ensure that communication between the relay centre operator and the PSAP operator is conducted in a mutually convenient language?

SECTION C. GENERAL

The following are general questions with regards to the implementation of the service in Canada.

Q1. Explain why Apple does not consider the Emergency SoS via satellite service as a telecommunications service, the provision of which in Canada could require Apple, among other things, to register with the Commission as a telecommunications service provider.

Q2. Ref A presents separate workflows for a) PSAPs handling satellite texts and b) PSAPs handling emergency relay calls. Further, Ref B states “Once the Initial Data Transfer (IDT) is sent, iPhone opens the messages app so the user can have a two-way conversation with a local dispatcher…if they’re located in a jurisdiction that accepts text messages already, or with a…relay telecommunicator if they’re in a jurisdiction that is still voice-only.”

How does the Emergency SOS via satellite service determine whether the satellite text can be transmitted directly to a PSAP or if it requires interaction with an emergency relay centre?

Q3. What interactions, if any, has Apple had with 9-1-1 governing authorities and/or PSAPs in Canada? What has been the feedback?

Q4. How are Emergency SOS via satellite requests handled in areas in which the Provincial or Territorial government has not established 9-1-1 service?

Q5. Has any testing been done to confirm functionality in Canada? If so, what have been the results? If not, are there plans to do so?

Q6. Ref A states “A high-accuracy, high-integrity location estimate is gathered and sent in the initial message.” Further, it recommends PSAP operators to “Trust the location and phone number provided in the initial data transfer (IDT) unless the provided data implies that these may be unreliable (e.g., a location uncertainty greater than 100m).”

What is the target reliability of the location provided with the Emergency SOS viasatellite initial data transfer?

Q7. Ref D indicates that Hybridized Emergency Location (HELO) testing has been conducted with the Cellular Telephone Industries Association – The Wireless Association (CITA) in San Francisco and Atlanta with the following results:

Morphology Yield %Footnote3 % calls with Error
≤ 50m		 Avg. Error (meters)
Dense Urban 89.1 85.2 32.7
Urban 96.7 87.9 30.7
Suburban 97.6 93.8 22.3
Rural 99.9 90.4 22.3

Has any testing of the Emergency SOS via satellite service been conducted in Canada? If so, what were the results?

Q8. Ref A states that “Once iPhone determines that no supported terrestrial network is available for an emergency call, it will automatically offer the option to connect via satellite.” What are the limits with regards to satellite capacity in the event of a mass outage (e.g. natural disaster) that affects access to terrestrial networks on a large scale?

Q9. Is the Emergency SOS via satellite service compatible with the NENA i3 standards for Next generation 9-1-1 (NG9-1-1)?

Q10. Are there plans to integrate the Emergency SOS via satellite service with the NG9-1-1 system in Canada? What discussions, if any, have been had with Canadian NG9-1-1 network providers to this effect?

Q11. What are the plans, if any, for the Emergency SOS via satellite to be compatible with NG9-1-1 text messaging based in Real Time Text (RTT)?

Q12. Ref C indicates that Emergency SOS via satellite is available on iPhone 14 and iPhone 14 Pro and iOS 16.1 or later. Are there any plans to bring this service to earlier versions of the iPhone and iOS and what are the expected timelines?

Ref F states that “Emergency SOS via satellite is free for two years after the activation of iPhone 14 or iPhone 14 Pro.” 

Q13. Confirm that this means that every user who activates an iPhone 14 will have access to two years of free Emergency SOS via satellite service regardless of when the iPhone was actually activated.

Q14. Will this two-year period of free Emergency SOS via satellite service be extended to future iPhone models, i.e., will each new iPhone benefit from two years of free service from the moment it is activated?

Q15. Describe the costing model (i.e. rates and fees) for use of Emergency SOS via satellite service in Canada for users who opt to use the service after the two-year free period.

Q16. Will Apple notify users once the two-year free period is over and that charges will begin to apply? If so, when and through what means?

Q17. How will Apple collect the rates and fees from users who opt to use the service, e.g. through direct billing to the user, via the user’s mobile service contract, via other means?

SECTION D. CRASH DETECTION

Commission staff has been made aware of issues with the Apple’s Crash Detection service, including the service completing calls to public safety answering points (PSAPs) when no emergency exists (false positives). Ref G states that “When iPhone or Apple Watch detects a severe crash, it will check in with the user through prominent visual screens, loud whoops, and aggressive haptic cues. The user can easily call emergency services using an emergency call slider, or they can cancel.” Given this:

Q1. Explain why Apple does not consider the Crash Detection service as a telecommunications service, the provision of which in Canada could require Apple, among other things, to register with the Commission as a telecommunications service provider.

Q2. Explain what is causing false positive crash detection-initiated calls to reach the PSAPs when no such emergency exists.

Q3. Describe what Apple is doing to minimize and mitigate the number of false positive crash detection calls reaching PSAPs.

End of attachment 1

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