Telecom - Staff Letter addressed to the Distribution List

Ottawa, 1 May 2024

Reference: 8662-C126-202305797

BY EMAIL

Distribution list

Subject: Part 1 Applications regarding Pre-Production Testing in Next Generation 9-1-1 Environment – Request for Information

Dear recipients,

Commission staff is currently considering the above-noted Part 1 applications filed by various entities representing Public Safety Answering Points (PSAPs), which have been merged into a single proceeding as per the procedural directions issued by the Commission on 13 October 2023.

In both applications, the applicants requested that the Next Generation 9-1-1 (NG9-1-1) network providers be mandated to establish an end-to-end NG9-1-1 testing environment, to support the reliability of NG9-1-1 services by enabling collaborative interoperability testing of future NG9-1-1 network changes prior to their rollout. In the applicants’ view, any NG9-1-1 network changes unilaterally implemented by the network providers, even if developed in compliance with the National Emergency Number Association (NENA) i3 architecture standard (the NENA i3 Standard), could jeopardize the cross-domain interoperability of the complex systems interconnected by the NG9-1-1 networks, which in turn could cause degradation or failure in the delivery of NG9-1-1 calls to PSAPs. In this regard, the applicants also requested that a national quality assurance program be established to standardize the testing and rollout processes of future NG9-1-1 network changes.

To complete the record of the present proceeding, Commission staff requests that the applicable parties respond to the questions directed at them, including detailed rationale, any supporting information, and relevant details, by 15 May 2024.

Section 1 – Questions for all parties to the merged proceeding.

1. If an end-to-end NG9-1-1 testing environment were to be established, please provide your views on what types of NG9-1-1 network changes would warrant collaborative interoperability testing be undertaken therein, along with detailed justifications (e.g., pre-launch testing of new NG9-1-1 features, changes to the Network-to-Network Interface and/or User-to-Network Interface specifications, routine software updates, etc.).
2. In reference to the joint contribution ESCO0745 made by Bell Canada, Saskatchewan Telecommunications, and TELUS Communications Inc. (TELUS) (collectively the NG9-1-1 Network Providers) to the CRTC Interconnection Steering Committee’s Emergency Services Working Group (the ESCO0745 Proposal), please provide your views on the following:
1. Within the PSAP domain, the NG9-1-1 network interacts directly with session border controllers (SBC). As SBC vendors may be different than those of call handling solutions (CHS), would it be appropriate to extend the scope of the ESCO0745 Proposal to include SBC vendors?
2. Would it be reasonable and appropriate for the Commission to mandate the NG9-1-1 Network Providers to provide access to their existing Next Generation Core Services (NGCS) labs to any originating network providers (ONPs) as well as SBC and CHS vendors for the PSAPs within their respective serving territories that may wish to conduct cross-domain interoperability testing as described in Section 4 of the ESCO0745 Proposal (the Interoperability Testing)?
3. Would it be reasonable and appropriate for the Commission to mandate the participation of ONPs in the Interoperability Testing? If so, considering that some small-scale ONPs may lack the necessary resources to do so, should the application of such mandate be conditional, and what should those conditions be (e.g., annual revenue threshold, subscriber number threshold, carriers vs. resellers, etc.)?  
4. Should all SBC and CHS vendors be required to participate in the Interoperability Testing? If so, considering that these vendors are outside of the Commission’s jurisdiction, how should such requirement be implemented and enforced (e.g., NG9-1-1 service agreement between the NG9-1-1 Network Providers and local 9-1-1 governing authorities, procurement agreement between PSAPs and their vendors, etc.)?
5. In keeping with the principles in Telecom Regulatory Policy (TRP) 2017-182^Footnote1 and TRP 2019-66,^Footnote2 should SBC and CHS vendors be responsible for the costs to transit their test traffic to the NGCS labs for the purpose of the Interoperability Testing?
3. It is staff’s understanding that any PSAP systems downstream of SBC and CHS (e.g., computer-aided dispatch systems, call loggers, etc.) do not interact directly with the NG9-1-1 networks. As such, if the Interoperability Testing is conducted between ONPs, the NG9-1-1 Network Providers, as well as SBC and CHS vendors at the NGCS labs, can PSAPs adequately test, within their own domain, their downstream systems (e.g., by way of test calls delivered over the production NG9-1-1 networks or otherwise)?

Section 2 – Questions for NG9-1-1 Network Providers

4. To the best of your knowledge, which NG9-1-1 SBC vendors have been retained, or are being considered, by PSAPs within your respective serving territories? 
5. To the best of your knowledge, which NG9-1-1 CHS vendors have been retained, or are being considered, by PSAPs within your respective serving territories?
6. Can your existing NGCS lab accommodate the Interoperability Testing by all ONPs as well as SBC and CHS vendors for the PSAPs within your respective serving territories (the Participants)?
1. If so, please provide:
• a brief qualitative overview of the incremental capital and operating expenditures, if any, that would be incurred to your NGCS lab for enabling and supporting the Interoperability Testing by the Participants, excluding those related to the transiting of test traffic to your NGCS lab (i.e., what key changes or upgrades would need to be made to your lab and what types of resources would be required on an ongoing basis);
• an estimated order of magnitude of the total incremental expenditures, if any, described in 6(a)(i);
• the approximate percentage increase to your NG9-1-1 tariff, if any, should the amount estimated in 6(a)(ii) be recovered through your NG9-1-1 tariff;
• your views on whether it would be appropriate to recover the amount estimated in 6(a)(ii) through your NG9-1-1 tariff, considering your response to 6(a)(iii) and the benefits of the Interoperability Testing to all stakeholders of NG9-1-1, including the Canadian public.
2. If not, please provide
   • an estimated order of magnitude of the costs to either expand the capacity of your existing NGCS lab or, if necessary, build an additional NGCS lab with a view to accommodate all the Participants; and
   • your view on whether such an investment would be justified considering the potential costs and benefits.
7. If the ESCO0745 Proposal is implemented on an optional and commercial basis, in respect of ONPs and CHS vendors only, as originally envisioned, please describe whether and how your responses to 6(a)(i) and 6(a)(ii) would be affected.
8. The ESCO0745 Proposal mentions that its implementation is contingent on sufficient interest from CHS vendors under a commercial service delivery:
1. What is the minimum number of SBC and/or CHS vendors required that would enable you to recover the incremental costs on a commercial basis?
2. If applicable, what is the minimum number of ONPs required that would enable you to recover the incremental costs on a commercial basis?
3. What are the consequences of the minimum number set out in 8(a) and/or 8(b) not being met (e.g., could insufficient interest from vendors prevent the service being offered to ONPs or vice versa, or not at all? Etc.)?

Section 3 – Questions for E-Comm 9-1-1 (E-Comm) and TELUS Communications Inc. (TELUS)

The following questions pertain to comments made on the record of a separate Part 1 proceeding regarding the extension of the decommissioning date of the Enhanced 9-1-1 networks (8662-C402-202306935). Specifically, E-Comm and TELUS provided information regarding an incident where E-Comm’s NG9-1-1 onboarding testing had allegedly negatively affected another PSAP’s operation inadvertently due to an issue with TELUS’ NG9-1-1 network (the Incident). As indicated in the Commission letter dated 30 April 2024, information surrounding the Incident is more germane to the present proceeding. Accordingly, E-Comm and TELUS are requested to respond to the questions applicable to each by 15 May 2024, serving a copy of your response on the other party. The two parties may then file one reply to each other’s response by 22 May 2024. ^Footnote3

Section 3.a. – Questions for E-Comm

9. Please provide a full account of the Incident as it unfolded for you, including the following elements:
1. the date on which the testing that resulted in the Incident was executed;
2. the objective of the testing that resulted in the Incident and its expected outcome;
3. whether any communication took place between you and TELUS prior to the execution of the testing that resulted in the Incident, particularly in relation to its planning;
4. the identity of the PSAP that was inadvertently affected by the Incident and how you became aware of the PSAP in question;
5. once you became aware of the Incident, what communication did you have with TELUS? How was the Incident resolved, and by when? Has any involved party implemented any corrective measures as a result to prevent this type of incident from occurring in the future? and
6. verifiable evidence, if available, in support of your claim that the Incident was caused by TELUS’ NG9-1-1 network.
10. Who is your CHS vendor, and did it directly participate in the testing that resulted in the Incident?
11. At the start of the testing that resulted in the Incident, was your test CHS configured in conformity with TELUS’ User to Network Interface (UNI) specifications?
12. Have you and/or your CHS vendor conducted a formal Post-Incident Review (PIR), whether or not in collaboration with TELUS, to ascertain the cause of the Incident?
• If so, please attach the PIR report to your response.
• If not, please provide reasons why a formal PIR has not been conducted.
13. In your view, in what ways could the outcome of the testing that resulted in the Incident have been different had it been conducted over a NG9-1-1 testing environment as opposed to the production environment?
14. Please provide any other additional information pertaining to the Incident that you deem relevant for the Commission to form a complete understanding of the situation. 

Section 3.b. – Questions for TELUS

15. Please provide a full account of the Incident as it unfolded for you, including the following elements:
1. what role, if any, did you play in the planning and execution of the testing that resulted in the Incident;
2. the identity, location, function (e.g., PSAP, safety net call centre), and owner/operator of the entity that was allegedly inadvertently affected by the Incident;
3. once you became aware of the Incident, what communication did you have with E-Comm? How was the Incident resolved, and by when? Has any involved party implemented any corrective measures as a result to prevent this type of incident from occurring in the future? and
4. verifiable evidence, if available, in support of your claim that the Incident was caused by noncompliance of E-Comm’s test CHS with your UNI specifications.
16. Have you conducted a formal PIR, whether or not in collaboration with E-Comm and/or its CHS vendor, to ascertain the cause of the misdirected test calls?
• If so, please attach the PIR report to your response.
• If not, please provide reasons why a formal PIR has not been conducted.
17. Please provide any other additional information pertaining to the Incident that you deem relevant for the Commission to form a complete understanding of the situation.

This letter and any subsequent submissions will be placed on the CRTC’s website. 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 CRTC 2010-961, parties may designate certain information as confidential but 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, should parties designate information as confidential, they 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.

Note that, in accordance with its normal practices, the Commission may disclose or require the disclosure of information designated as confidential if it determines that its disclosure is in the public interest, i.e., where the specific direct harm does not outweigh the public interest in disclosure.

Where a document is to be filed by a specific date, the document must be 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.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution and Regulatory Implementation
Telecommunications Sector

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

Parties to the Part 1 Proceeding - Distribution list

Date modified:

2024-05-01