Search

Telecom - Staff Letter addressed to Dan Harren (Centre for Addiction and Mental Health)

Gatineau, 18 June 2025

Our reference: 1011-NOC2025-0020

BY EMAIL

Dan Harren
Director
Centre for Addiction and Mental Health
1001 Queen Street West
Toronto, ON, Canada M6J 1H4
dan.harren@camh.ca

Subject: Improving the routing of 9-8-8 calls and texts, Telecom Notice of Consultation CRTC 2025-20, Request for information – 18 June 2025

This letter sets out a request for information related to the proceeding initiated by Telecom Notice of Consultation CRTC 2025-20, in which the Commission asked for comments on how to improve the routing of calls and texts to 9-8-8.

To help develop a fulsome record and assist the Commission in its assessment of the areas identified within Telecom Notice of Consultation CRTC 2025-20, the Centre for Addiction and Mental Health (CAMH) is to file responses to the questions included in the appendix below by 9 July 2025.

Parties may file replies with the Commission no later than 16 July 2025 limited to comments on CAMH’s response to this request for information.

Confidential information

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, parties may designate certain information as confidential.

A party designating information as confidential 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, a party designating information as confidential 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.

A copy of this letter will be placed on the public record of this proceeding.

Yours sincerely,

Original signed by

Lisanne Legros
Director, Telecommunications Networks Policy
Telecommunications Sector

c.c.: Josiane Lord, CRTC, josiane.lord@crtc.gc.ca
Filsan Gure, CRTC, Filsan.Gure@crtc.gc.ca
Sarah McMaster, CRTC, Sarah.McMaster@crtc.gc.ca
Cameron Warriner, CRTC, cameron.warriner@crtc.gc.ca
Loïc Yves Abena Fouda, CRTC, LoicYves.AbenaFouda@crtc.gc.ca
Bella Chu, CRTC, Bella.Chu@crtc.gc.ca
Bell Canada: bell.regulatory@bell.ca
Bragg Communications Inc. (cob Eastlink): regulatory.matters@corp.eastlink.ca
Canada Deaf Grassroots Movement: canadadeafgrassrootsmovement@gmail.com
Canadian Administrator of VRS (CAV), Inc.: Paula@cav-acs.ca
Canadian Telecommunications Association: ugrant@canadatelecoms.ca
Deaf Well-Being Program: regulatory@deafwireless.ca
Deaf Wireless Canada Committee: regulatory@deafwireless.ca
Eversa: abeauchamp@eversa.co
Northern Communication Services, Inc.: erich.baumgartner@northern911.com
Public Interest Advocacy Centre: tdawood@piac.ca
Quebecor Media Inc.: melanie.cardin@quebecor.com
Rogers Communications Canada Inc.: regulatory@rci.rogers.com
Saskatchewan Telecommunications (SaskTel): document.control@sasktel.com
Tbaytel: laura.foulds@tbaytel.com
TELUS Communications Inc. : jeffrey.smith@telus.com
Voice on the Net Coalition: grichards@dickinson-wright.com

Attach. (1) Appendix

Appendix: Questions

  1. Several telecommunication service providers (TSPs) commented that the Centre for Addiction and Mental Health (CAMH) has not provided evidence or specific examples to support its claim that some calls to 9-8-8 may not be routed properly or that the current 9-8-8 service may not have adequate resiliency. Provide the following information reflecting the time since the service became operational in Canada on 30 November 2023:

    1. the number of calls (separated by wireline and wireless, if applicable, and including those from blocked numbers) and the number of texts that have not been routed to the closest response centre to the caller’s location under the existing 1-8XX routing mechanism, and the percentage that these numbers represent of the total number of calls and texts to 9-8-8; and
    2. the number of outages that have occurred on the 9-8-8 network affecting either voice calls or text messages, including (i) the duration of each outage; (ii) how each outage was identified; (iii) the cause of each outage; and (iv) how the outage was resolved.

  2. Several parties requested that the proceeding be placed on hold so that routing proposals could be collaboratively determined by members of the industry. TELUS Communications Inc. (TELUS) specifically suggested that this be tasked to the CRTC Interconnection Steering Committee (CISC) Network Working Group (Reply of TELUS, paragraph 5). If the Commission were to direct a CISC working group to propose a solution to improve the routing of 9-8-8,

    1. identify what specific issues regarding the routing of 9-8-8 require resolution.
    2. comment on whether improvements are needed for the routing for text, VoIP, or VRS, or whether the solution should focus on calls to 9-8-8, noting that CAMH’s proposal does not include any changes to the current routing for text, VoIP, or VRS.
    3. comment on whether improvements are needed for wireline calls or whether the solution should focus only on improving the routing of wireless calls to 9-8-8, considering that several parties proposed routing solutions that focus only on improving the routing of wireless calls to 9-8-8, noting that wireline calls are already routed appropriately based on the area code of the caller.

  3. In response to some parties’ concerns about routing to response centres under CAMH’s proposal, CAMH clarified in paragraph 10 of its reply that

    “the service provider will instead route the call to a DID associated to the location where the call enters the service provider’s network. That DID will route the call to CAMH who will then pass it on to the appropriate agent at the appropriate response centre closest to the caller.”
    1. Has CAMH identified the geographic areas associated with each proposed direct inward dialing (DID) number? If so, provide detailed maps showing the geographic areas.
    2. How frequently does CAMH add or remove response centres and/or update the geographic area covered by a 9-8-8 response centre? Should a routing solution be able to support possible future additions or removal of response centres and/or allow for changes to the geographic areas?

  4. Some concerns were raised by Rogers Communications Canada Inc. (Rogers) regarding callers who may prefer to be connected to a response centre that is able to respond in their first language. Rogers also raised concerns with respect to culturally relevant responders providing support to First Nations, Inuit, and Métis callers (Intervention of Rogers, paragraph 2).

    1. Describe the current user experience when initiating a call to 9-8-8.
    2. Explain whether all callers have access to services in both English and French, regardless of their location. Include whether this is expected to change should the routing of 9-8-8 calls be modified.
  5. The Canada Deaf Grassroots Movement and the Deaf Wireless Canada Committee raised several service-related concerns regarding accessibility, particularly regarding improvements that could be made to the 9-8-8 service, which fall under the responsibility of CAMH. Confirm whether CAMH has noted these concerns and whether it has reached out or intends to reach out to these organizations to address their concerns.
Date modified: