Telecom - Staff Letter addressed to Chris Kellett (CRTC CISC - Emergency Services Working Group) and Richard Polishak (CRTC CISC – Network Working Group)
Ottawa, 23 June 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: Amendments to the request for recommendations from Canadian Radio-television and Telecommunications Commission (CRTC) Interconnection Steering Committee (CISC) regarding network resiliency and outage mitigations and notification
This letter amends the CRTC staff letter dated 22 February 2023, requesting CISC for a report with recommendations related to 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 CRTC launched Notice of Consultation 2023-39 (NoC 2023-39) Footnote1 to seek comments on mandatory notification and reporting about major telecommunications service outages. As an interim step, the CRTC required all Canadian carriers to notify the CRTC within two hours of a major service outage. NoC 2023-39 also laid out the CRTC’s action plan to improve network resiliency and reliability for all carriers.
Among the policy matters to be determined in the NoC 2023-39 proceeding, is whether all Canadian carriers should be required, as a condition of providing telecommunications services pursuant to section 24 of the Telecommunications Act, to report major telecommunications service outages (including major outages affecting only 9-1-1 networks or public alerting) to the CRTC, Innovation, Science and Economic Development Canada (ISED), and relevant authorities.
It appears that there is a potential overlap between the policy matters that are currently before the CRTC for determination and CRTC staff’s request to CISC to provide recommendations on implementing outage notification for originating network providers, and for the public alerting service. In particular, CISC was requested to include recommendations on the following items #5 and #6:
- 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, and
- 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.
Staff acknowledges that policy matters before the CRTC are not within the scope of CISC’s mandate, which is to assist in technical and administrative matters necessary for the implementation of CRTC decisions on policy issues.
Upon review, CRTC staff agrees that it is premature for CISC to examine implementation issues regarding the two items identified above, prior to the CRTC having rendered its decision on the policy issues related to mandatory notification.
In light of the above, staff amends its 22 February 2023 request to CISC by removing items 5 and 6, pending the CRTC’s determinations ensuing from the NoC 2023-39, which will among other things guide stakeholders on the policies around 9-1-1 and public alerting outage notification. CISC continues to be a valuable forum to bring the various stakeholders together to discuss how to implement and operationalize the CRTC’s policies.
As such, CRTC staff modifies its original request to CISC to amend the scope of NTTF044 by removing items 5 and 6.
Sincerely,
Original signed by
Leila Wright
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
- Date modified: