Search

Telecom - Staff Letter addressed to Ryan Anstey (Emergency Services Working Group)

Ottawa, 29 November 2024

Our reference: 8665-C12-201507008

BY EMAIL

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

Subject: Request for Information regarding the Introduction of Advanced Mobile Location Functionality for Wireless Service Providers

  1. On 15 December 2022, the Emergency Services Working Group (ESWG) submitted a report (ESRE0100) regarding the implementation of handset-based location in Canada.
  2. The Commission approved the report in Telecom Decision 2023-235 (TD 2023-235), including the adoption of the Emergency Location Service (ELS) aggregation model whereby Bell Canada (Bell) and TELUS Communications Inc. (TCI) act as national aggregators, including in Saskatchewan Telecommunications’ (SaskTel) territory.
  3. To support ELS, the Commission also directed facilities-based wireless service providers (WSPs) to reconfigure their existing next-generation 9-1-1 (NG9-1-1) interconnections to Bell and/or TCI, and new facilities-based WSPs to establish interconnection to Bell and/or TCI.
  4. On 28 March 2024 and 18 April 2024 respectively, TCI and Bell filedFootnote1 tariff notices (TN) to incorporate the provision of ELS into their tariffs. The Commission approved these tariffs on an interim basis in Telecom Order 2024-97.
  5. In a staff letter issued to Bell and TCI on 16 August 2024, Commission staff requested, among other things, confirmation from the companies that i) ELS was available for facilities-based WSPs across Canada; and ii) they are providing ELS for facilities-based WSPs in SaskTel’s territory.
  6. In its intervention to the staff letter, Rogers Communications Inc. (Rogers) expressed concern with the difference in ELS rates proposed by Bell and TCI. In its reply, Bell stated that “WSPs have the option of receiving advanced mobile location (AML) Service [from Bell] and ELS from Telus.  However, to be clear, there is no requirement that WSPs must utilize both our [Bell’s] Service and Telus’ ELS service.   Therefore, to the extent that Rogers and Quebecor Media Inc. (QMI) are dissatisfied with any aspect of our AML Service or Telus’ ELS service, including the respective rates and charges, they are free to use the service of the provider which they find more suitable.”
  7. However, it is Commission staff’s understanding that facilities-based WSPs must interconnect with both national aggregators to ensure reliability and redundancy nationally, and are not free to only use the service of the provider they find more suitable, as submitted by Bell.
  8. Consequently, it has come to staff’s attention that there may be some misunderstanding with regard to the ELS interconnection framework. Specifically, staff refers to the use of “and/or” statements in paragraphs 50.1 and 50. 3, and the term “applicable WSPs” in paragraph 50.6 of TD 2023-235 and ESRE0100 before it.

    50. With regard to ELS, the Commission directs Bell Canada and TCI as the aggregators for ELS, and all facilities-based WSPs, to take steps in preparation for the implementation of ELS as set out below:

    1. Facilities-based WSPs are to reconfigure their existing NG9-1-1 interconnections to Bell Canada and/or TCI using the updated Network-to-Network Interface (NNI) to support ELS by 16 August 2023. New facilities-based WSPs must establish interconnection to Bell Canada and/or TCI after inception of the NNI.
    1. WSPs are to undertake pre-production testing with Bell Canada and/or TCI between 21 August 2023 and 20 November 2023.
    1. Bell Canada and TCI are to deliver the ELS location using Hypertext transfer protocol secure (HTTPS) to the applicable WSPs.
  9. Staff is seeking clarification from the ESWG, as the originators of the initial recommendations in the ESWG report ESRE0100. As such, staff requests that the ESWG answer the following questions no later than 15 January 2025.
    • Q1. What are the conditions in which facilities-based WSPs would reconfigure their existing NG9-1-1 interconnections to Bell Canada and TELUS?
    • Q2. What are the conditions in which new facilities-based WSPs must establish interconnection to Bell Canada and TELUS after inception of the NNI?
    • Q3. What are the conditions in which facilities-based WSPs would reconfigure their existing NG9-1-1 interconnections to Bell Canada or TELUS?
    • Q4. What are the conditions in which new facilities-based WSPs must establish interconnection to Bell Canada or TELUS after inception of the NNI?
    • Q5. What factors are considered when determining to which WSPs Bell and TELUS shall deliver the ELS location using HTTPS?
    • Q6. Please provide any additional information to assist staff in the clarification of the initial recommendations from the ESWG report ESRE0100 regarding interconnection to the national aggregators.

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

Date modified: