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Telecom - Staff Letter addressed to Philippe Gauvin (Bell Canada)

Ottawa, 29 November 2024

Our reference: 8665-C12-201507008

BY EMAIL

Philippe Gauvin
Assistant General Counsel
Bell Canada
160 Elgin Street
Ottawa, ON, K2P 2C4
bell.regulatory@bell.ca

Subject: Follow-up to Bell Canada’s 9-1-1 Outage Report filed for the 2023 Reporting Period

  1. This letter is in relation to the 2023 9-1-1 outage report submitted by Bell Canada (Bell) as a 9-1-1 network provider, pursuant to Telecom Regulatory Policy 2016-165 (TRP 2016-165) and Telecom Regulatory Policy CRTC 2017-182 (TRP 2017-182), collectively known as the Reliability and Resiliency Policy for 9-1-1 networks. The 9-1-1 networks providers who are responsible for filing the annual 9-1-1 outage reports consist of: Bell Canada (Bell), Northwestel Inc., Saskatchewan Telecommunications, TELUS Communications Inc., and City West Telephone Corporation.
  2. In TRP 2016-165, 9-1-1 network providers were directed that they must take all reasonable measures to ensure that their 9-1-1 networks are reliable and resilient to the maximum extent feasible (Reliability and Resiliency obligation). In TRP 2016-165 and TRP 2017-182, 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. In its report for 2023, Bell reported a 9-1-1 network outage that affected the entirety of New Brunswick, Nova Scotia, and Prince Edward Island on 31 January 2023 (the 31 January 2023 outage). The issue occurred due to network changes with respect to implementation of 10-digit dialing required for support of the 9-8-8 service on the Atlantic 9-1-1 Tandems. Both the Primary and Secondary Atlantic 9-1-1 Tandems were rendered unable to process 9-1-1 calls originated in the Maritimes. As a result, 9-1-1 callers in the region received a fast busy signal, resulting in a significant number of calls not being delivered to the Public Safety Answering Points (PSAPs).
  4. The industry best practices for 9-1-1 network providers, as described in paragraph 31 of TRP 2016-165,  include the 9-1-1 network design principles of critical component backups configured in a geo-redundant fashion, diverse interconnections from originating networks to the 9-1-1 networks (including backup solutions), location (or site) diversity, transport network diversity and 9-1-1 network being available 99.999% of the time.
  5. Staff seeks additional information from Bell regarding the factors that led or may have contributed to the 31 January 2023 outage, and the steps Bell has or will take to prevent similar outages from reoccurring. As such, staff requests that Bell answer the following questions no later than 8 January 2025.
    • Q1. Provide more detail in relation to the 31 January 2023 outage:
      1. What was the specific length of time from the detection of the issue to implementation of the solution? What was the solution and how did it fix the issue?
      2. Describe the procedure taken by Bell in the implementation of 10-digit dialing. Were any special considerations applied for 9-1-1 tandems? Did Bell directly approve of the process chosen for the implementation of 10-digit dialing?
      3. Was a risk assessment performed prior to implementing the 10-digit dialing? If so, what did it conclude? If not, why not?
      4. Was it possible to implement the network changes in a manner that would not simultaneously impact both 9-1-1 tandems serving the Maritimes? If so, why wasn’t this procedure used?
      5. Was a Post Incidence Review conducted by Bell? If so please provide the review and its results, if not, why not?
      6. Why were the mitigation efforts implemented by Bell in response to the outage not in place prior to the incident?
    • Comment on whether Bell’s process of simultaneously applying network changesFootnote1 to both the Primary and Secondary Atlantic 9-1-1 tandems was consistent with the industry best practices described in paragraph 31 of TRP 2016-165.
    • Q2. Provide more detail in relation to Bell’s remediation response to the 31 January 2023 outage:
      1. What new mechanisms were implemented by Bell enabling earlier detection of 9-1-1 call failures?
      2. What improvements were made by Bell to processes triggering human intervention and the activation of post-event mitigations?
    • Q3. Please provide any additional information to assist staff in completing its assessment of Bell’s compliance with its Reliability and Resiliency obligations prior to implementing the changes in its 9-1-1 network that caused the 31 January 2023 outage.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, recipients may designate certain information as confidential though must provide a detailed explanation on 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 recipients designate information as confidential, recipients 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.

In light of the public interest in 9-1-1 reliability and resiliency, Commission staff expects Bell to disclose information on the public record to the maximum extent possible.

Sincerely,

Original signed by

Michel Murray
Director, Dispute Resolution & Regulatory Implementation
Telecommunications Sector

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

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