Search

Telecom - Staff Letter addressed to the Distribution list

Ottawa, 17 April 2024

Our reference: 1011-NOC2023-0156

BY EMAIL

Distribution list

Subject: Follow-up to Telecom Notice of Consultation 2023-156, Enabling direct 9-1-1 and 9-8-8 calls from multi-line telephone systems

In Telecom Notice of Consultation 2023-156 (the Notice), the Commission initiated a proceeding to assess the extent to which, if at all, it should establish legally enforceable regulatory measures to address issues encountered in accessing 9-1-1 and 9-8-8 from multi-line telephone systems (MLTS). In order to ensure that the Commission has the factual record necessary to make a determination, Commission staff is requesting more information from parties who participated in the Notice.

Location information

In response to the Notice, many parties acknowledged the importance of providing dispatchable location information to Public Safety Answering Points (PSAPs) when a 9-1-1 call is dialed from an MLTS.

Further, many parties suggested that the CRTC Interconnection Steering Committee (CISC) Emergency Services Working Group (ESWG) be requested to explore the development of a solution that enables the provisioning of dispatchable location information of an MLTS endpoint under Next Generation 9-1-1 (NG9-1-1) emergency network.

Under the E9-1-1 network, certain 9-1-1 network providers offer services such as Private Switch-Automatic Location Information (PS-ALI) to their subscribers to make MLTS endpoint location information available to the 9-1-1 system and PSAPs. Given the intent to decommission the Enhanced 9-1-1 (E9-1-1) network and the current lack of an NG9-1-1-equivalent to PS-ALI solution, staff considers that prior to exploring the technical and operational aspects of any potential solution, it is necessary to collect further information to assess its policy aspects.

In light of the above, staff requests that parties to the Notice provide their views on the following, including all relevant details, rationale and any supporting information:

  1. Does the NENA i3 standard define an NG9-1-1-equivalent to PS-ALI?  If not, would it be appropriate for CISC ESWG to develop a Canadian national standard for an NG9-1-1-equivalent to PS-ALI based on NG9-1-1 components, similar to the introduction of Location Information Server (LIS) / Additional Data Repository (ADR) as an NG9-1-1-equivalent to the E9-1-1 Automatic Location Information (ALI)/Automatic Number Identification (ANI)?
  2. In Telecom Regulatory Policy CRTC 2019-66, the Commission set out the roles and responsibilities with respect to LIS / ADR functionalities.
    1. Please comment on the appropriateness of the following potential framework for the NG9-1-1-equivalent to PS-ALI, whereby:
      1. The responsibility for the provision of the NG9-1-1-equivalent PS-ALI resides with the telecommunications service providers, including resellers,Footnote1 with MLTS (MLTS TSPs);
      2. The incumbent local exchange carriers (ILECs) are mandated to provide a hosted NG9-1-1-equivalent PS-ALI solution;
      3. The MLTS TSPs have the option of self-provisioning or subscribing to the hosted solution; and
      4. The responsibility for updating and maintaining NG9-1-1-equivalent PS-ALI resides with MLTS TSPs for their respective subscribers/users, regardless of whether the NG9-1-1-equivalent PS-ALI functionalities are provided through the hosted solutions.
    2. For MLTS TSPs, what conditions should be met in order for them to provision location data into the hosted NG9-1-1-equivalent PS-ali solution?
  1. Many parties submitted that certain legacy MLTS systems might not be capable of being programmed and/or upgraded to meet new regulatory requirements. Based on such, please answer the following questions:
    1. For these legacy MLTS systems, please describe the technical limitations, if any, for the following functions:
      1. Direct dialing for 9-1-1 and 9-8-8 calls;
      2. Direct routing of 9-1-1 calls to appropriate PSAPs and direct routing of 9-8-8 calls to mental health and suicide prevention call centres;
      3. The provision of location information suitable for dispatching emergency responders for 9-1-1 calls;
      4. Direct callback number for 9-1-1 calls; and
      5. Awareness and notification to be issued to on-site personnel in parallel without interrupting the call path for 9-1-1 calls.
    2. If applicable, based on your best estimate, what percentage do these legacy MLTS systems represent from all your MLTS systems in Canada? Are there any plans to replace and/or upgrade them? If so, when?

Additionally, Commission staff also requests Bell Canada (Bell) and TELUS Communications Inc. (TELUS) provide their answers to the following questions regarding their current PS-ALI service solutions offered to their MLTS subscribers for E9-1-1:

  1. Is there a plan to discontinue such offering in the future?
  2. If so, when, and what impact would its withdrawal potentially have on its NG9-1-1 equivalency solution under NG9-1-1 network?
  3. What mitigation strategies would you propose to address these potential impacts? For example, could the PS-ALI database records be migrated to the NG9-1-1 equivalent solution?
  4. Given that apart from the general tariffs applied for the E9-1-1 networks, Bell and TELUS currently recover the costs associated with their E9-1-1 PS-ALI solutions through separate tariff applications, i.e. Special Facilities Tariff and Location Switched Access Services Tariff respectively:
    1. What are the advantages and disadvantages of filing separate tariffs to recover the costs associated with the hosted NG9-1-1 equivalent PS-ALI solution (the costs) per the proposed framework found in question 2 in this letter?
    2. Alternatively, could the costs be recovered through Bell and TELUS’ NG9-1-1 wholesale and retail tariffs? What are the advantages and disadvantages of such alternative method?
    3. If the costs were recovered through Bell and TELUS’ NG9-1-1 wholesale and retail tariffs, approximately what percentage of Bell and TELUS’ proposed tariffed rates would be driven by these costs respectively?

Procedure

Only parties that have filed interventions within the context of the Notice may file a response only in relation to new matters raised in these requests for information. The deadline for filing responses to the questions within this request for information is 16 May 2024.

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.

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.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.:  Étienne Robelin, CRTC, etienne.robelin@crtc.gc.ca

Date modified: