Telecom - Staff Letter addressed to the Distribution List

Ottawa, 20 June 2024

Our reference: 8665-C12-201507008

BY EMAIL

Distribution List

Subject: Follow-up to Outage Reports filed for the 2015-2023 Reporting Periods

1. This letter is in relation to the 9-1-1 outage reports submitted by 9-1-1 network providers,^Footnote1 pursuant to Telecom Regulatory Policy 2016-165 (TRP 2016-165) and Telecom Regulatory Policy CRTC 2017-182 (TRP 2017-182).
2. In those decisions, 9-1-1 network providers were directed to file annual reports detailing for each 9-1-1 outage, the date, duration, and cause of the outage; the affected area; the remedial action taken; as well as the number of affected calls. 9-1-1 network providers were also directed to file an abridged version of this annual report, including aggregated information for the public record.
3. When filing information with the Commission, parties are permitted to file information in confidence in accordance with the Telecommunications Act, though are expected to disclose the information which does not necessitate confidential treatment on the public record. As the information was not submitted during a proceeding, its disclosure is governed by section 39(5)(a) of the Telecommunications Act, which allows disclosure if it is relevant to a Commission matter and in the public interest.
4. In order to increase transparency and the public’s understanding of matters that affect them, and to address certain inconsistencies in which information 9-1-1 network providers disclose and file in confidence since 2015, Commission staff requests that 9-1-1 network providers with 9-1-1 reporting obligations respond to this request for information by 11 July 2024 or else provide justification for their inability to do so. Such justifications must include a robust explanation of the specific harm from public disclosure or why the information is unavailable. References to past practices or general confidentiality claims will not suffice.

Aggregated information on 9-1-1 call delivery from all 9-1-1 network providers

5. Per paragraph 95 of TRP 2016-165, 9-1-1 network providers must include aggregated 9-1-1 network outage information in their abridged reports. While most providers have submitted total annual call numbers and calls delivered to PSAPs, standardizing how this information is filed would benefit the public record.

5.1 CityWest included total number of calls transiting its networks in both its abridged and confidential 2017 reports onward.

5.2 Sasktel submitted a confidential attachment detailing the total number of calls transiting its 9-1-1 network for each reporting year in its 2023 report.

5.3 Bell submitted in confidence both the total number of 9-1-1 calls transiting its and Northwestel’s networks, and the number of 9-1-1 calls not delivered to PSAPs, for the entire reporting period.^Footnote2

5.4 TELUS publicly disclosed the number of calls not delivered to PSAPs from 2015-2017 but has generally filed all information related to 9-1-1 outages in confidence since 2018.^Footnote3

6. Commission staff requests all 9-1-1 network providers to:

Q1. Provide for the public record for each report year the total number of 9-1-1 calls that transited its 9-1-1 network, the total number of 9-1-1 calls not delivered to PSAPs, and the percentage of 9-1-1 calls delivered to PSAPs, as per the table below.^Footnote4 Further, staff requests 9-1-1 network providers to include information contained in columns A, B, and C of this table in both the abridged and confidential reports going forward. If they do not intend to do so, explain why.

Q2. Comment on what additional or complementary information, if any, could be publicly disclosed by 9-1-1 network providers in the reports to increase the transparency of 9-1-1 network reliability and resiliency in Canada.

Request for increased disclosure from TELUS in abridged reports

7. Staff has noted discrepancies in qualitative disclosure among 9-1-1 network providers. The abridged public version of a report should convey to the public a general understanding of the nature of an outage, omitting specific details that may be exploited by bad actors. To clarify this, staff expects the abridged versions of the reports to include:

7.1 The general description of the cause of an outage;

7.2 The 9-1-1 network provider’s general response to an outage;

7.3 The general type of equipment or asset impacted by an outage; and

7.4 The date, duration, and province of an outage.

8. While CityWest and Sasktel have not reported any full service impacting 9-1-1 network outages to date, they should bear in mind this direction in the event of a fully service outage in the future.
9. Reports submitted by Bell to date have had minimal differences between the confidential and abridged versions, and have typically conveyed the information outlined in paragraph 12. Staff notes a significant increase in qualitative detail in Bell’s 2023 report, and encourages that future reports follow this methodology.
10. TELUS disclosed partial outage descriptions publicly in its reports submitted between 2015 and 2017 but has filed all details related to 9-1-1 outages in confidence from 2018 onward. Staff is of the view that this limits public visibility into the network's reliability, contrary to TRP 2016-165's direction and its past reports. As such TELUS is asked to:

Q3. Explain the discrepancy in the public disclosure of information in its reports filed from 2018-2023 versus 2015-2017.  

Q4. Refile the abridged versions of its reports for 2018 to 2023 such that the level of public disclosure is consistent with the reports filed in 2015-2017, and reports submitted by other network providers. As such, the abridged versions of the reports should include the four information items listed at paragraph 12.

Request for additional qualitative description from TELUS in past reports

11. Referring to the confidential version of TELUS’ 2022 annual outage report, in relation to the 9-1-1 outage described on pages 4 and 5:

Q5. When did TELUS last conduct a pathway diversity audit within the area that was affected by the outage? Could an audit, or an increased diversity of network traffic, have prevented or mitigated this outage?

Q6. Describe the frequency of network diversity audits, what factors influence the initiation of an audit, and the results of the last audit.

Request for additional qualitative description from Bell in past reports

12. Bell sparingly submits information related to 9-1-1 outages in confidence, however reports prior to 2023 relied on technical spreadsheets to convey outage information. While accurate, Commission staff is of the view that plain language explanations would be better suited for informing the public. As well, Bell should expand on the mitigating strategies taken to avoid similar outages in the future.
13. Therefore, Bell is requested to:

Q7. Provide more detail in relation to the 9-1-1 outage in Ontario on 1 December 2022, and how it compares to the 2021 outage that was the subject of a previous staff RFI, with specific timeframes as appropriate, including:

1. When did the network card begin affecting 9-1-1 call traffic?
2. When was the issue detected?
3. When did Bell begin busying out lines after the problem was detected?
4. When did normal 9-1-1 traffic resume?
5. What redundancy measures were in place to respond to this type of 9-1-1 network outage?
6. Was there any type of automatic fail-over mechanism in place, or that could have been implemented, to respond to this type of outage?
7. Are there other measures that can be taken to reduce the time for manual fail-over measures to take effect?
8. When did Bell last conduct a pathway diversity audit of the affected area? Could an audit or increased diversity of network traffic have prevented or mitigated this outage?
9. Describe the frequency of network diversity audits, what factors influence the initiation of an audit and the results of the last audit.
10. What network monitoring tools were in place at the time of this outage? Was an outage of this nature anticipated in light of the outage that occurred in Ontario on 30 August 2021?
11. What information was provided to the PSAP after the issue was resolved? Were PSAPs able to follow up on the missed calls via missed call logs or other means?
12. Please explain in further detail the specific monitoring tools implemented in response to this outage, and how they differ from those deployed in response to the outage in Ontario on 30 August 2021.
13. Please explain in further detail what has been done since this outage occurred, and what Bell intends to do, to prevent this type of issue in the future?

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

c.c.:   Étienne Robelin, CRTC, Etienne.Robelin@crtc.gc.ca
Alex Pittman, CRTC, Alexander.Pittman@crtc.gc.ca

Distribution List:

Bell Canada: bell.regulatory@bell.ca
TELUS Communications Inc.: regulatory.affairs@telus.com
SaskTel: document.control@sasktel.com
CityWest: Joelle.Barfoot@cwct.ca
Northwestel: regulatoryaffairs@nwtel.ca

Date modified:

2024-06-20