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Telecom - Staff Letter addressed to Ryan Anstey (CRTC Interconnection Steering Committee)

Ottawa, 31 May 2024

Reference(s): 8000-C12-202306407

BY EMAIL

Ryan Anstey
CRTC Interconnection Steering Committee
Emergency Services Working Group
eswg911@wrps.on.ca

Subject: Intermediary 9-1-1 call centres

Dear Ryan Anstey,

I am writing to request the CRTC Interconnection Steering Committee’s (CISC) Emergency Services Working Group (ESWG) provide recommendations to ensure that 9-1-1 calls routed to intermediary call centres are handled in the caller’s preferred official language.

As you know, in the vast majority of cases, 9-1-1 calls are directly connected to provincial, territorial or municipal 9-1-1 call centres, also known as public safety answering points (PSAP). These PSAPs are the responsibility of the provincial, territorial, and municipal governments.

In very limited circumstances where provincial, territorial or municipal governments have not set up a PSAP, or where calls are made using voice over internet protocol (VoIP) services where the caller’s location is unknown, telecommunications service providers (TSPs) have created, or contracted with, intermediary call centres. These call centres confirm the 9-1-1 caller’s location and forward the call to the appropriate PSAP.

The CRTC is aware of incidents in which 9-1-1 calls from francophone residents of Quebec were routed to an intermediary and answered in English. We are concerned by these events. Canadians need access to 9-1-1 services in the official language of their choice. We are working to help find solutions that fall within our mandate.

While we are encouraged by the initiatives already taken by the industry,Footnote1 this issue warrants deeper exploration. The ESWG’s members are technological and operational experts on issues related to 9-1-1. As such, we are asking the ESWG to help identify potential solutions.

The solutions proposed by the ESWG should take into consideration the CRTC’s mandate as an independent quasi-judicial tribunal in regulating TSPs, with no regulatory oversight of intermediary call centres or PSAPs.

The ESWG should also take into consideration the roles and responsibilities of all industry players involved in the initiation, routing, response, and transfer of 9-1-1 calls answered by intermediaries (e.g., end-users, TSPs,Footnote2 intermediaries, etc.), as well as the existing or new administrative, technical, and operational solutions each party can implement or support to ensure that 9-1-1 calls answered by intermediaries are handled in the caller’s preferred official language.

The ESWG’s report should:

  1. Provide the advantages and disadvantages of each solution, as well as implementation timelines, responsible party or parties, and monitoring strategies necessary to ensure that the solution is effective.
  2. Assess regional differences across Canada in use of official languages and the impact of these differences on the effectiveness of each solution.
  3. Discuss whether mandating quality-of-service standards for 9-1-1 calls answered by intermediaries, similar to standards in place for PSAPs, can improve service in the caller’s preferred official language.
  4. Discuss whether and how TSPs should record and use customer official language preferences to ensure calls answered by intermediaries are handled in the customer’s preferred official language.
  5. Discuss whether specific TSP- and/or customer-facing communications are required to ensure the customer’s official language preference is identified, recorded, and operationalized when 9-1-1 calls are routed to an intermediary. If so, provide the form of communication, the information to be included in the communication, and the party responsible for issuing the communication.

During this work, we expect regular information exchange with CRTC staff and the public. This includes informal progress reports, as well as updates posted to the CRTC’s website in accordance with CISC processes.Footnote3These updates should start no later than 2 July 2024. We recognise that the ESWG’s members are volunteers who participate in the working group while balancing other commitments. CRTC staff discussed a deadline for a final report with members of the ESWG. Based on these discussions, staff requests that ESWG file its report with the CRTC no later than 28 February 2025. Nonetheless, ESWG should bring forward, at any point, and without hesitation, recommendations from its experts that can assist the CRTC in addressing this issue.

We ask that the ESWG engage with official language minority community (OLMC) members and representatives in its discussions and development of potential solutions. CRTC staff will also encourage participation by OLMC representatives.

Thank you in advance for your work. Given the importance of ensuring that Canadians can receive 9-1-1 services in the official language of their choice from intermediary call centres, I trust that the ESWG will treat this request as a priority.

If you have any questions regarding this request, please do not hesitate to contact Étienne Robelin at etienne.robelin@crtc.gc.ca.

Yours 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

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