ARCHIVED - Transcript, Hearing January 16, 2017

Volume: 1
Location: Gatineau, Quebec
Date: January 16, 2017
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Attendees and Location

Held at:

Outaouais Room
Conference Centre
140 Promenade du Portage
Gatineau, Québec

Attendees:

• Chairman: Jean-Pierre Blais
  
• Vice-Chairperson, Telecommunications: Peter Menzies
  
• Commissioners: Christopher MacDonald, Stephen Simpson, Linda Vennard
  
• Legal Advisors: Eric Bowles, Alexander Ly
  
• Secretary: Jade Roy
  
• Hearing Managers: Renée Doiron, Kim Wardle
  

Transcript

Gatineau, Québec

--- Upon commencing on Monday, January 16, 2017 at 9:03 a.m.

1 THE CHAIRMAN: Order, please. A l’ordre, s’il vous plaît.

2 Bonjour, mesdames et messieurs, et bienvenue à cette audience publique. Good morning, ladies and gentlemen, and welcome to this public hearing.

3 Avant de commencer, je tiens à reconnaître que nous sommes réunis aujourd’hui sur le territoire traditionnel des Premières Nations. Je remercie le peuple Algonquin et rends hommage à ses aînés.

4 Comme vous le savez, l’accès aux services d’urgence 9-1-1 joue un rôle de premier plan lors de situations d’urgence. La sécurité de tous les Canadiens en dépend.

5 L’audience qui débute ce matin a lieu dans le cadre du processus pour établir un cadre règlementaire pour les services 9-1-1 de prochaine génération au Canada.

6 Broadband is transforming our world every day. All areas and facets of society, from health to education to agriculture, among others, benefit from new tools and new and efficient ways of doing things. Emergency services can also benefit from these developments.

7 What are next-generation 9-1-1 services? Simply put, technological advances could allow citizens in need of emergency assistance to send text messages, photos, videos and other data to 9-1-1 operators, in addition to making 9-1-1 voice phone calls.

8 For example, they could stream video from an incident site, send photos of damages from an accident scene or a fleeing suspect, or even transmit personal medical information, all of which could be of great benefit to emergency response services.

9 La prestation de services 9-1-1 au Canada est un enjeu complexe qui requiert une coordination entre diverses parties, y compris les fournisseurs de services de télécommunication, les fournisseurs de réseaux 9-1-1, les centres d'appels 9-1-1, ainsi que les divers paliers de gouvernement.

10 Le CRTC a pour rôle d'exercer une surveillance réglementaire des réseaux et des fournisseurs de services de télécommunication et des réseaux 9-1-1 spécialisés. Au fil des ans, le CRTC a adopté de nombreuses mesures réglementaires afin que les réseaux de télécommunication procurent un accès fiable et efficace aux services 9-1-1 au Canada.

11 This proceeding is needed to take into account the evolving public safety needs of Canadians, among other things. Next-generation 9-1-1 could allow Canadians to access new and innovative services and capacities.

12 During this hearing, the CRTC will be considering the following key issues. First, the role and responsibilities of telecommunications service providers; second, how the costs incurred by telecommunications service providers for these new services should be recovered; and third, the transition steps and timing for the next-generation 9-1-1 services; fourth, the evolution of 9-1-1 networks and services to take advantage of technological advancements, while taking into consideration the evolving needs and habits of Canadians.

13 And finally, while 9-1-1 call centers do not fall within the CRTC’s jurisdiction, our decision will take into account their migration plans for the next-generation 9-1-1 services they expect to support.

14 Over the next few days, we will discuss these issues with all the intervenors and examine their positions.

15 Now, I’d like to make a few introductions before we begin. The panel for this hearing this morning consists of Peter Menzies, Vice-Chairman, Telecommunications; Stephen Simpson, Regional Commissioner for British Columbia and the Yukon; Linda Vennard, Regional Commissioner for Alberta and the Northwest Territories; Christopher MacDonald, Regional Commissioner for the Atlantic Provinces and Nunavut; and myself, Jean-Pierre Blais, Chairman of the CRTC. I will be presiding over this hearing.

16 L’équipe du Conseil qui nous assiste comprend de Renée Doiron et Kim Wardle, gestionnaires de l’audience; Eric Bowles et Alexander Ly, conseillers juridiques; et Jade Roy, secrétaire de l’audience.

17 J’invite maintenant madame Roy à expliquer la procédure que nous suivrons.

18 Alors, Madame la secrétaire?

19 Mme ROY: Bon matin et bienvenue à tous.

20 Before we start, I would like to go over a few housekeeping matters to ensure the proper conduct of the hearing.

21 When you are in the hearing room, we would ask that you please turn off your smart phones as they are an unwelcome distraction and they cause interference on the internal communication systems used by our translators. We would appreciate your cooperation in this regard throughout the hearing.

22 Interpretation services will be available throughout the duration of the hearing.

23 We would like to remind participants that during their oral presentation, they should provide for a reasonable delay for the interpretation while respecting their allocated presentation time.

24 Veuillez noter que les documents seront disponibles sur Twitter sur le compte du Conseil à @CRTCaudiences au pluriel, en utilisant le mot-clic “#CRTC”.

25 There is a verbatim transcript of this hearing being taken by the court reporter sitting at the table to my right. Please note that a transcript of each day will be posted on the Commission’s website the following business day.

26 Just a reminder that pursuant to Section 41 of the Rules of Practice and Procedures, you must not submit evidence at the hearing unless it supports statements already on the public record. If you wish to introduce new evidence as an exception to this rule, you must ask permission of the Panel of the hearing before you do so.

27 Please also note that if parties undertake to file information with the Commission in response to questioning by the Panel, these undertakings will be confirmed on the record throughout the transcript of the hearing. If necessary, parties may speak with Commission legal counsel at a break following their presentation to confirm the undertakings.

28 And now we will begin with the presentation by NG9-1-1 Coalition of the Willing. Please introduce yourself and your colleagues and you have 20 minutes for your presentation.

PRESENTATION

29 MS. PELLETIER: Merci. Bonjour. Good morning, Commissioners and Commission staff.

30 We are pleased to be here today to start off this hearing week in support of the CRTC’s Notice for Consultation on the establishment of a regulatory framework on next-generation 9-1-1 in Canada.

31 My name is Diane Pelletier. I am the Director of the New Brunswick 9-1-1 Bureau at the Department of Justice and Public Safety. I’m a long-time member of the CRTC’s Emergency Services Working Group and I have served as the Chair of the next-generation 9-1-1 Coalition since its creation in 2013.

32 With me is my colleague Mr. Chris Kellett, who represents the Alberta E9-1-1 Advisory Association, of which he has been a member for 22 years.

33 He is also the current chair of the CRTC's Emergency Services Working Group and is a member of the next-generation 9-1-1 coalition.

34 Today we are here representing the next-generation 9-1-1 coalition interests, and our presentation reflects our members' collective views and desired outcomes from these proceedings.

35 We will now begin with our presentation.

36 So the focus of our presentation today is who we are, what we do. We want to talk about the major focus of the Coalition, which is our Vision 2020, our strategy, next-generation coordinating entity, and a consistent funding model for the future, the creation of a national 9-1-1 coordinating entity. Chris will give a little bit more in-depth presentation on that. And we want to align expectations and delivering the future and the opportunities and challenges with next-generation 9-1-1. We do believe that we have to seize the opportunity of this development, moving forward.

37 So the next-generation 9-1-1, responding to evolving NG9-1-1 issues and concerns, a group of 9-1-1 experts from across Canada met in Ottawa in June 2013. The goal was to create a framework for the governance and coordination of NG9-1-1 developments relevant for all jurisdictions and stakeholders. A sub-committee of provincial, territorial, and municipal 9-1-1 experts volunteered to lead the work of NG9-1-1 governance, coordination, and financial issues. This group was named the NG9-1-1 Coalition of the Willing and we affectionately call ourselves the Coalition.

38 The members, it's -- our membership is an open forum for 9-1-1 experts representing authorities from provincial, municipal, territorial 9-1-1 authorities. So our participants, right now, we have 10 provinces and territories represented, 12 municipal members from across Canada, plus representation from the RCMP, the NENA -- the Numbering -- Emergency Numbering Association -- APCO Association, and CITIG, which you will hear from later this morning, which represents the views of the police, fire and ambulance -- EMS chiefs of Canada.

39 The purpose -- when we created our terms of reference, we created a purpose, so it's to provide expert national forum for discussion and informal coordination. We are a group of volunteers, and we wanted to assist the provinces, the territories, and decision-makers, and other stakeholders. The Coalition does not replace appropriate federal, provincial, territorial, or municipal authorities. It is working to develop consensus among 9-1-1 stakeholders and advises on the potential path forward for NG9-1-1.

40 The major areas of concern, as I mentioned, are the Vision 2020 -- what can -- where can we get to in -- by 2020; national coordination, and the funding.

41 So the strategy that we developed and presented as part of our submission, as part of these consultations, this strategy has been developed as the impetus to start the dialogue at all levels of government to collectively focus our attention on NG9-1-1 coordination, funding, and standards Canada-wide deployment. It was developed from the same type of strategy document being used in Australia and New Zealand. We are not unique in Canada. Every jurisdiction in the world is tackling this, and it matches directly with the national vision put forward in the U.S. by the U.S. base NG9-1-1 NOW Coalition.

42 So I will now give the microphone to my colleague, Chris, who will elaborate on the need for greater coordination and our funding model ideas.

43 MR. KELLETT: Thanks very much, Diane.

44 So moving on to the national coordination entity, I think in order to understand where we're at today, it's good to look a little bit at the past. And 9-1-1 over the past 35 years has developed across Canada, first starting out from the perspective of small iterations in large cities and later on, in the nineties, as we moved forward with the system, we upgraded to provincial level 9-1-1, and today we're looking at 9-1-1 being available across Canada in terms of enhanced 9-1-1. So we get extra information when the call comes in in terms of the phone number and location information.

45 We still have basic 9-1-1 in Newfoundland and newly introduced last year up in the Yukon as well, throughout the Yukon. It was in Whitehorse before that.

46 So because of the way it's developed. Essentially, we've got a bottom-up approach. The responsibility is owned at a municipal, then up to a regional, then up to a provincial level, depending on what part of the country you're in.

47 And it's fair to say that there is coordination that goes on, in some respects, in terms of the work we do through the CRTC Emergency Service Working Group, but we certainly do not have a nationally recognized coordinating entity to advise and guide all aspects of what's coming next. And from that perspective, it really highlights the disjointed nature of where things are at today, but it also highlights an opportunity, and I -- that's why the Coalition is so involved in this particular process.

48 So it's -- we feel it's vital to establish a national coordinating body to guide and coordinate a consistent delivery of the new next-generation 9-1-1 system and services across Canada.

49 We strongly support the intervenors who have proposed the creation of a national coordinating entity similar to the Canadian Local Number Portability Consortium, which is under the control of the CRTC and would be instrumental for guiding and coordination, oversight, and funding challenges.

50 We do have a recommendation, however, that the structure and function should be more similar to the Canadian number administrator rather than the consortium, and that it should have included a defined end date. In other words, this isn't the creation of an entity that's going to be here forever. It should be in during the transition period and end-dated once that transition is complete.

51 The reason we're suggesting the Canadian Numbering Administrator approach to it is because they report to the same steering committee as this steering committee, and the working groups work hand-in-glove together and in order to ensure consistency with all of the things that are coming next that not only impact 9-1-1 but they impact the other working groups as well. We think that would be the appropriate place to have a new body report.

52 The other thing I wanted to talk about today is a consistent future funding model. Can you -- thanks.

53 The current state of 9-1-1 funding across Canada, simply put, is confusing for all stakeholders, lacks transparency, and must be fixed so funds collected can be directly applied to future and next-generation 9-1-1 capital and operating costs.

54 Today, CRTC-approved tariffs and targeted provincial legislation work quite well. You're going to get an opportunity tomorrow to listen to what Alberta has done with the Emergency 9-1-1 Act, the Emergency 9-1-1 levy regulation. I can tell you it's the first time in Canada that that type of approach has been taken where the funds are collected and then remitted through a grant program that is administered by a small but agile group with the Alberta Emergency Management Agency.

55 And Andrew Renfree, when he presents tomorrow, will provide you a lot of detail, and it’s really worth understanding and considering moving forward.

56 Now, I know that doesn’t sit within the CRTC mandate. We’re not working for the CRTC to get into the legislative business, but it provides a framework opportunity that a coordinating entity could assist greatly with in terms of setting a legislative template that could be utilized going forward.

57 So a new national coordinating entity must facilitate the creation of model legislation, which could cover oversight and funding to assist the provinces and territories as needed to ensure the consistent delivery of next-generation 9-1-1 across Canada.

58 So aligning expectations and delivering the future. It’s fair to say that what is perceived in terms of 9-1-1 today a lot of it is related to what people see on TV. So they think when you dial 9-1-1 there’s pinpoint accuracy, and that we can follow you around and we know exactly where you are and what your emergency is.

59 That reality is a little stretched, but it’s fair to say that the people that work in the business every day do pull off some amazing feats in terms of locating people and getting them the help they need.

60 So the delivery of a sustainable emergency communication response service that meets community expectations related to the rapidly changing technology is not possible with our current operating environment. It’s fair to say it’s probably akin to the whole analog to digital conversion that took place with television. We’re at the same precipice with 9-1-1.

61 NG9-1-1 has strong technical support from the CRTC through the emergency services 9-1-1 working group, but we need the oversight leadership from the CRTC to facilitate the consistent delivery of future NG9-1-1 services so we can align with community expectations today and into the future.

62 So this is the opportunity. The evolving NG9-1-1 system provides a unique opportunity to transition the current enhanced 9-1-1 system in basic -- in a few places. And it’s been developed over the last 35-plus years to a world-class system for all, creating assistance with consistent technical and operational standards.

63 The challenge. If we have a lack of coordination to facilitate the timely standards-based development -- or deployment I should say -- backed by a model legislation template which includes the funding that everybody’s been talking about -- it will mean we will fail to deliver on this opportunity.

64 So in closing, as far as this opportunity goes, we’d like to thank the Commission for putting this up to a public hearing, putting out the notice of consultation. The amount of interest that’s been paid to 9-1-1 here, especially over the last several years has been very encouraging. And it’s great to see we have an opportunity here to move forward together, and to make this something that we can be proud of across Canada.

65 THE CHAIRMAN: Thank you for your presentation. Certainly happy to see new faces in our public hearing room. I know you’ve been active in CRTC proceedings, but it’s a rare occasion that we get to talk about 9-1-1 issues in an oral setting.

66 I’m going to have a series of questions. Try as I could to create some sort of narrative in my story in the questions, I think it’s almost impossible. It’s a lot of individual points. So you’ll see that I’ll be jumping from one subject to the next, but we’ll follow along.

67 And in a sense, you know, the sorts of questions I’ll be asking about -- and I’d ask you to think in those terms -- is that we’re very much at the threshold questions. It’s a bit like building a house. We’re definitely building foundations, planning for the mainframe and the structure of the house and the kind of heating and energy you will have. We’re not quite at choosing the colour of paint for the rooms quite yet. But they are very significant issues that will guide us over the next 10 years.

68 So my first area of inquiry deals with governance and responsibility. And you’ve certainly raised the notion that there needs to be coordination, but some parties in the proceeding have gone a little further than I think what you’re proposing in actually putting forward this notion of a national consortium of NG9-1-1 network providers or regional NG9-1-1 network providers rather than the current process whereby it’s the incumbent -- ILECs for the most part -- that provide the telecommunication networks.

69 And I’d like to hear you on why you think that’s a good or a bad idea to go towards a coalition approach as opposed to through the auspices -- the status quo of NG9-1-1 delivered through ILECs, incumbent local exchange carriers, and traditional providers.

70 MR. KELLETT: Certainly. The idea at this point, if you look at how 9-1-1 is deployed through four ILECs across the country today, it works very well. What’s coming next though in terms of an IP highway, so an emergency service highway that transmits all the data, is an opportunity in terms of both information sharing and the ability to utilize a system across Canada without paying for it four different times. You pay for it once.

71 So that’s the primary reason to look at the economies of scale related to a single national system. It doesn’t change the underlying structure of how the services get delivered for the last mile, but at a network level it provides an opportunity to pay for it once, put in a system that of course has redundancies, but essentially does not require that you recreate it four times in four different places across the country.

72 So that’s the reason we’re looking at proposing one system. And the national -- there’s nothing wrong with the idea of -- the question has come up in terms of should it be an ILEC, could it be some other entity? Our answer on that is quite simple. We want an entity that’s controlled through the CRTC. That limits the choices pretty considerably.

73 And we also want to work with the trusted partners that we have today. And we are looking forward to seeing through this process who may step up to the plate in terms of providing that opportunity for a national emergency service IP network and moving us forward collectively together.

74 THE CHAIRMAN: As we are trying, I think, to have an orderly transition, are you of the view that going through -- setting aside the jurisdictional matter -- it’s interesting but perhaps not the best place in a hearing to be discussing, you know, jurisdiction and the best way to reach out. We’re trying to get benefits to Canadians in the end. Let’s focus on the outcomes.

75 Are you less concerned by using the sort of status quo delivery method as being a more efficient way of assuring just that, the orderly transition, because we’re dealing with something we know already how it works, as opposed to creating this new national consortium? Are you concerned that that is perhaps adding complexity to what ought to otherwise be a orderly transition?

76 MR. KELLETT: Absolutely. And if you look at it from the perspective of what could happen -- so today we have trusted partners we’ve worked with for 30-plus years that we know that have the last mile interconnection. And really what we’re talking about is at a network level just changing the ability to essentially coordinate a new entity to deliver both technically and operationally a new service.

77 And as you point out, you can look at it from a jurisdiction perspective and have all sorts of discussions. We’re looking at it at a much more practical situation from the perspective that if you go out and put out a request for proposal and want to essentially have somebody provide this particular service, then essentially we’re moving away from an opportunity potentially to work with people we know and trust to something we don’t know and for that to happen on the 9-1-1 system in Canada for all of the providers it would be a huge step backwards from our perspective.

78 THE CHAIRMAN: And when you say however -– I mean you mention the issue of cost and transparency of costs, granted it’s a change, but some argue in the proceeding that going through a third party, a national consortium delivery, would create the opportunity for doing an RFG.

79 And therefore, by its very nature, if one follows the theory of public tendering, that you’ll have the best cost efficient entity delivering the service and on top of that it would be relatively transparent.

80 What do you say to those that make that argument in favour of a national consortium?

81 MR. KELLETT: I would say that if you look at today’s tariff process and the costing that gets filed that equals to pennies on the dollar in terms of the existing 9-1-1 system, and that there’s a cap profit margin in terms of that, and it has to be filed annually, it’s very transparent in terms of the process already.

82 An RFP process is a business proposition and there is no way to control the profit margin that a third-party entity would come forward with and over time those costs would increase.

83 There’s lots of proven examples of that taking place with different technological advancements.

84 So from our perspective we’re looking at it saying why change what’s working today and it’s very -– the one part of funding that is transparent is how much the Telcos get paid to provide 9-1-1 in the four -– or in the four entities that support it across the country. Go ahead, Diane.

85 MS. PELLETIER: Can I add something?

86 From my perspective, I think the adding –- it’s already a complex system and adding more complexity by bringing in those that don’t know the 9-1-1 environment and what we hope to achieve would not necessarily be doing a service to Canadians in trying to -– this is not just the internet and, you know, the internet of things.

87 We know we need to move there, but we need to do it in a fashion that provides us with the opportunity to evolve the system, because we’re going to need to have a transition period. So you’re not going to be all of a sudden, you’re in one system and then you’re in another system.

88 So that -– I’m not saying that it’s not something that you can go out to RFP for, but it’s -– it would introduce in my view more complexity to something that is already complex for citizens and for the PSAPs and for the authorities that are trying to manage a 9-1-1 system for the reasons that it exists and it’s to support emergency response so ---

89 THE CHAIRMAN: So then just a fair position to take is testing the position of others against your own, what do you say to those that say the current status quo reflects a reality that existed 40 plus years ago when the foundations of the existing 9-1-1 system were put in place, where obviously we used the auspices of the ILECS because we were a more monopoly less competitive marketplace and now we are going -- and the Commission, the government, public policy, generally favours a more competitive marketplace in telecommunications, and in a sense relying on the ILECS is -– seems to be a bit out of step with that new reality of public policy that has evolved over forty years.

90 MS. PELLETIER: Perhaps but the experience that I’ve had over the 10 plus years that I’ve been attending the ESWG and -– or the Emergency Services Working Group and working together, I think we’ve all come to the understanding that 9-1-1 is non-competitive when it comes to 9-1-1 services to the citizens of my province or any jurisdiction in Canada, across Canada, is you’re doing the right thing for the right reasons.

91 And the -– there could be some participants that are not aware of that and the bottom line becomes the profit margin and in a 9-1-1 environment I think that that’s a dangerous -– there’s -– that’s a dangerous way to go so ---

92 THE CHAIRMAN: That by its very nature 9-1-1 is not a competitive service and therefore we shouldn’t take the rest of our regulatory regime into consideration, which is based on competition? Is that in a sense what you’re saying?

93 MS. PELLETIER: Well in -– I’m not really trying to say that it’s not within the realm of competition, but it has to be -– it can’t be all about the -– who can do it in the most economical fashion.

94 It has to kind of take into consideration the impacts to the downstream agencies, to the public safety answering points, to the responders and then to the citizens in the end.

95 MR. KELLETT: I can draw a parallel if you’d like?

96 The -– what we’ve seen -– and we follow quite closely what happens down in the U.S., they’ll go out for emergency service IP -– RFP. They’ll get back a bid that essentially has 10 different suppliers with a coordinating supplier and from the perspective of implementation issues it’s a nightmare.

97 Quite plain and simple there is -– the whole idea -– and I’ll put it simple, is one neck to choke -- is really one throat to choke is really important from the perspective that this needs to be as straightforward as possible, with people that know the business.

98 And moving forward I recognize that yes the change from a competition perspective to a more open system is one that is a move that’s had a lot of good value and back in ’97 when a lot of things were deregulated there are some aspects of the marketplace that it’s made it quite good.

99 But this is one particular area where we think it’s important to rely on the people that can do things and I’ll use an example.

100 Bell rolled out in a year and a half and took six provinces and made them IP capable because we decided that it was an important thing that had to happen for text with 9-1-1.

101 You would not -– if you went through an RFP process to get that done we’d be still talking about who’s going to get the contract. It was done in a year and a half.

102 So the ability to be agile, working with partners who know what they’re doing and can deliver and can be regulated in terms of those costs back through a regulating body is as transparent and as straightforward as you can get.

103 THE CHAIRMAN: So in a sense obviously, you’re favouring the status quo, because the networks provided by the ILECS in a stewardship, historic stewardship, in your view is the better road to go?

104 And would you agree with me then therefore the burden, from your perspective, would be on those that are advocating change to go to a consortium model to establish why that is a better model?

105 In other words, they have the burden of proving change from the status quo, in this particular instance.

106 MR. KELLETT: Short answer, yes.

107 THE CHAIRMAN: Okay.

108 And not dissimilar to the approach we took, by the way, in community channel policy, obviously in broadcasting, where we left community channel stewardship in the hands of the traditional incumbents rather than change as some had advocated, because they just didn’t convince us that we needed to change that direction as well.

109 Also on network designs and this is related, as you know, in the proceeding there is sort of two perspectives being advocated. One would be for a national NG 9-1-1 network, single provider nationally.

110 And then there’s this notion that the juxtaposition that has more regional NG9-1-1 networks, which together would form a national network.

111 Do you have views on that? Again, you mention the need for coordination and I’m wondering whether your view would be that it should go so far as having more fundamental national coordination in terms of a single 9-1-1 network as opposed to regional ones going forward.

112 MS. PELLETIER: Well, the whole notion of the emergency services network is based on the premise of networks of networks. So not being a technical person but being around the tables enough, I would offer that whether you have one -- and this is what the technical folks would say -- whether you have one or you have a combination of many networks that all interconnect together, if there’s a national entity that kind of guides the roll-out of these different networks and how you connect to it and when you can on-board to the network, if you will -- for lack of a better term -- and you have to meet certain standards and criteria and then you can be part of the NG9-1-1 network.

113 So we would argue that a national entity would be able to help guide that. So whether there would be one national network or a combination of multiple networks that all interconnect together and under one standard, it could work.

114 THE CHAIRMAN: It seems to me, though, and I’d love have your views on this, from the cost-benefit perspective for a PSAP, on the one hand I would assume that PSAPs rely a lot on local presence, local knowledge. But a national network may actually have economies of scales because some of the back-off is functions and some of the -- you know, the shared resources could get the benefit of economies of scale.

115 So I’d like to have your perspective on a cost-efficiency, cost-benefit efficiency for emergency responding, from a PSAPs perspective, under those two models, regional versus national.

116 MR. KELLETT: So at this point what we’d put on the record is we believe a national system is not only possible but preferable. And the simple reason is we’ve already got provincial-level systems and if you look at what’s happening today, one provider looks after six provinces and then there’s a couple of provinces on their own in terms of stand-alones and then the last provider looks after two provinces.

117 So it’s not a far stretch and there’s a good possibility, at this point -- well, Saskatchewan I can use as an example -- they look after the voice side, but the data side of 9-1-1 is looked after by Bell. So they contract with Bell to do that. So Bell looks after six provinces and we know what’s going on with Manitoba and there’s a possibility that there’s more coming in terms of what Bell may be looking after.

118 So we’re really very, very close to having a national system already. And I think the best way to move this forward is not to make a decision that it has to be a national or a regional system. It’s to put it -- send it back to the technical -- through the ESWG, and go forward with trials and figure out -- put the system in the place, prove the technology, and then let the roll-out happen based on national coordination with the goal of getting to a national one system. Because, as we pointed out earlier, there’s major cost savings in terms of doing it that way.

119 THE CHAIRMAN: And is it your view that that as sort of an iterative process towards a national network would deal with issues of redundancy risks, security risks of putting all our eggs, in a sense, in one national basket?

120 MR. KELLETT: Correct. And cyber security is something that is front and centre for lots of different entities out there today. This is no different. We were very careful, even when we did the work on TEXT with 9-1-1, to create a system that was not directly accessible from an IP internet perspective.

121 So that kind of attention to detail -- every additional point of interconnection introduces a chance for failure and for vulnerability. So the less -- if you have one system and you have the right folks looking after it and the proper attention paid to cyber security, I think that’s easier to handle than four different transitions or whatever else is proposed going forward. We think it’s easier to secure one system than many.

122 THE CHAIRMAN: It’s a bit counterintuitive, though, with the design of web architecture where at the origin it was meant to continue to deliver packets, even though part of the system was down. And so I’m trying to figure out if -- what are you saying? If we move iteratively to a national network, isn’t there not a great risk that the whole system can go down as opposed to having regionally redundant systems that can perhaps support each other in, you know, larger catastrophes?

123 MR. KELLETT: So from the perspective of creating a single system in a single point of failure, 9-1-1 by its very nature has been designed from day one to have a lot of built-in redundancies. Next-generation 9-1-1 has to be exactly the same.

124 So how you accomplish that is a matter to figure out technically. But I would not disagree with you that setting up a single entity has its vulnerabilities in terms of one system to hack. But the flip-side to that is, from a redundancy perspective, there’s lots of redundancy you can build into a network across Canada, based on the underlying infrastructure, that would look after PSAPs in an appropriate fashion, probably better than we do today.

125 Today the biggest enemy of a PSAP is a back-hoe. And it’s taken out many PSAPs across this country. And if you look at going forward the way we do interconnection in the PSAPs, we’re even looking at that to say, “What can we do to eliminate the single point of failure that exists by taking out the one access point that comes into building?”

126 So this has been thought up from the ground up.

127 THE CHAIRMAN: And your view on managing the risk of trying to create something that’s too big is, “Don’t try to create something that’s too big from the day one; just do it through an iterative process”?

128 MR. KELLETT: Correct.

129 THE CHAIRMAN: Even though it might take even longer to do so and there may be redundancy -- costly redundancies, I meant, by having the legacy system and the next-generation 9-1-1 system cohabitating for longer than otherwise than if you had a driven system towards a national network?

130 MS. PELLETIER: That’s what I would recommend.

131 MR. KELLETT: Yeah, go ahead.

132 MR. PELLETIER: Okay. That’s why we’re recommending that the CRTC establish kind of an end date so this is not something that going on to perpetuity and ties legacy to transition to all NG9-1-1 forever and ever. We need to have some sort of an end date so that similar to the end date for TEXT with 9-1-1 and Phase II -- you know, it’s -- the only way we feel that it can be done properly is through a transition period, trials. And then once the trials have proved themselves, then it’s probably easier to kind of set a timeframe because PSAPs will understand what is necessary and it will allow municipal, provincial, and territorial authorities to decide how they want to set themselves up in an NG9-1-1 environment.

133 THE CHAIRMAN: So an iterative process with a road sign at the end that says, “The road is ended here and we have to transfer over”?

134 MR. KELLETT: Absolutely. One of the things we think is really important -- and we don’t think it’s coming out of this proceeding this time -- is once you do a trial, once you say, “Okay, here’s the 10 things you need to do at a PSAP in order to on-board onto a national system,” then you set a date similar to what happened with Bell where they ended the support for the old X.25 system and they transitioned five provinces over a year and a half period of time and shut down the old system. And they’re now on the new system.

135 THE CHAIRMAN: Right. So it’s still a little early to set the actual end date at this point?

136 MR. KELLETT: Correct.

137 THE CHAIRMAN: Even that has to be an intermediary process, I guess?

138 MR. KELLETT: Well, it's -- goes back to, I think, what the difficulty is when you deal with this. This really needs to go to the next step, and we understand how to get there, from a technical perspective. And I have a pretty good idea on timing as well. What we don’t have is the handle on the national coordination in the piece in terms of funding, and a singular body to go to where PSAPs could essentially have a single source of information, in terms of where to go to and how to handle everything, not just -- they can come to the emergency service working group -- and often do -- to get the technical support they need to understand here's the 10 things they need to do.

139 And we've -- like, we've proven it over and over with Phase 1 wireless, Phase 2 wireless, TEXT with 9-1-1 for the deaf, hard of hearing, speech impaired. I mean, those were all processes in call location update. They're all processes you got put into place as improvements to the existing system.

140 Think of this as a major improvement, but no different from the perspective that we're just trying to improve the system and at the same time, move it to a more consistent model of delivery across the country on all fronts. That's the opportunity we talk about.

141 And it looks like it's pretty daunting in terms of transition and timing, it's -- I think with a live trial and the report that comes out of that, we can set some very specific timing in there to assist everybody in terms of understanding how to get there and when we'll get there.

142 THE CHAIRMAN: Right. I'm -- you know, in your presentation, you referred to the transition to digital over-the-air television. Having been involved in that in another life, it strikes me that until you actually set the deadline, it doesn’t become very real, and people drag their feet. Is there a risk in this situation that we face the same issue, and if yes, although you may not want to advance a date for the end date, when would be the time to make a decision as to when the end date ought to be?

143 MR. KELLETT: So we already did set the end date. It's called Vision 2020, and from the perspective of when, I think we can have a concrete trial up and running in 2018, and by the end of 2018, we can have a proposed end date. And to be fair, if it's 2020, that's going to be a little fast for three-year budget cycles for some of the governmental entities, so it may be pushed out to 2021. But I don’t see it going much beyond that, based on where we're at today in Canada.

144 THE CHAIRMAN: Okay. Now, under the current system, there are some entities that are permitted to connect with the current 9-1-1 system; essentially, wireless service providers, competitive local exchange providers, PSAPs. And how do you see that -- and I guess they're trusted entities that historically we've seen as reliable and trusted enough to be interconnected.

145 So how do you see that going forward to -- again, is it an iterative process or do you think we should be more clear as to the types of parties that can or cannot interconnect?

146 MR. KELLETT: The NENA i3 architecture, as you know, was approved by the Commission last year. Within that model is a host of -- a laundry list of different providers. So I'll use telematics, medical is a big one, it's -- and then you’ve got things from an infrastructure perspective, building plans, you’ve got stuff from a fire department perspective, from an emergency management perspective, that all come into it.

147 Once you build the highway, the ESInet, then essentially, the information that gets available is pulled information. Rather than having it stored at the network level and retrievable directly as a source, you'll do that for location validation and other functions like that. But source data that changes over time -- and I'll use an example.

148 If a consumer wants to put all of their medical information to make sure it's available, then it's -- that does not have to go on to the 9-1-1 network. It doesn’t have to be delivered with the call. We just have to know it's available. So simply assigning the -- understanding that that information is available based on the phone number and having it retrievable by the entity that has authority to retrieve it, is how it seem -- will be managed going forward, which is quite different than today, because all the information -- and we use ANI/ALI as an example. So all of that information sits up at the 9-1-1 network level and is updated on a regular basis and it's transited with the call.

149 In the future, we're looking at the information in terms of a dispatchable address actually coming from the originating network rather than being stored, so it's real time; instead of having to go retrieve it from an archive database, we retrieve it in real time.

150 Same thing for that information. If we've got telematics information from a crash notification from a vehicle, that information becomes available and it's simply pulled as part of the process, but not necessarily by 9-1-1. Maybe by the secondary PSAPs; police, fire, or EMS dispatch in their -- in terms of responding or out of a command site where they need to pull it, but it becomes available off the same information highway.

151 You don’t want to store it all at that level because you then become responsible for the disclosure and all of the costs associated. So you can transit the information over that highway and the people that use it become responsible for it because they've used it. It's quite straightforward, in terms of -- and then you don’t have to regulate, well this provider X, Y and Z have ability to be on there and store information, but everybody else doesn’t.

152 It will be a lot simpler, in terms of transiting the information. The source data is owned by the source owner and it only becomes transited over the ESInet and becomes only the responsibility of the people that use it and that's it.

153 THE CHAIRMAN: So in a sense, when we're reflecting on interconnection, you're suggesting in the future we shouldn't think of a full bi-directional flow of information but actually think that some interconnection is a push or pull and only that?

154 MR. KELLETT: Correct. So the -- all we need today in order to get to an emergency from a 9-1-1 perspective is the location and some indication of the emergency. There's -- when we talk about pictures being available, we talk about video, that matters and it could be very important information for responding units in terms of what resources to send, but that information, again gets pulled. It does not get stored or have to be part of the -- what you keep at the 9-1-1 network level.

155 THE CHAIRMAN: The core level?

156 MR. KELLETT: Yeah.

157 THE CHAIRMAN: Let me ask, are there untrusted entities -- put it the other way -- that we should be concerned about that they shouldn't be involved in this and they shouldn't be able to get involved? I mean, it's -- because -- I mean, I get your point. You don’t want to close it off because the architecture you're proposing is that there's core information and then there's nice-to-have information, but that gets dealt with at a secondary level.

158 But there will still be people wanting, perhaps, to interconnect. And I'm not talking about nefarious people with bad intentions, but there will be people with allegedly good intentions.

159 MR. KELLETT: So if you use an example today, alarm companies, for instance, would be a perfect example of an entity that would want to be directly involved. Telematics is looking to set up a standard, and the whole idea, in terms of them being involved is to be able to provide the information in-line versus having to provide it verbally over the phone and do a whole translation process.

160 So going forward, is there a partner -- and those are trusted partners today, and that introduces the opportunity for efficiency that we don’t have today with those two particular processes.

161 The only entities that are of a big concern and will be of a big concern going forward will be the ones that are spoofing or swatting type incidents. And being able to look at the source of where things are coming from, and does it make sense in terms of the information.

162 It’s fair to say those happen today over the voice network through individuals that aren’t trusted and cause a lot of havoc when they decide to carry out those sort of nefarious things. If you introduce a digital world and the opportunity to basically create new ways to do spoofing and swatting, those are things untrusted sources we’re going to have to pay pretty close attention to.

163 But there’s not a provider out there today that I would say you put on the list and say, “Well, let’s make sure entity ‘X’ doesn’t have the ability to transit information.” Part of the highway is the trusted part of a highway and then -- I won’t call it “untrusted” but less -- information that can’t be verified is the best way to put it.

164 And we’ll have to develop mechanisms especially when it comes to location, where the call is coming from, that that information is coming from a valid source and it is trusted. And that is quite simply easier said than done.

165 THE CHAIRMAN: Right. But there will be big data that some people will want to have access to because it will have commercial value, and I could see other orders of government seeing a revenue opportunity by providing that access to information.

166 MS. PELLETIER: Well, I would say that it goes back to the need for national guidance and coordination, where some of those elements can be brought to that table, and studied and reviewed so that we can make recommendations on those types of entities that would want to have that information.

167 But right now I agree with Chris. There’s no provider out there, there’s no -- that’s not working with the whole group to make 9-1-1 the best that it can be. Yeah, we’re going to have new people around the people but they will have to sort of follow the same rules and guidelines that this is for 9-1-1 and for emergency response.

168 THE CHAIRMAN: Right. And the CRTC, in your vision, still continues to have some sort of oversight on that when people can’t agree; is that correct?

169 MS. PELLETIER: Definitely.

170 THE CHAIRMAN: And with respect to this who is trusted or not, are there international examples we should be looking at to seek inspiration? Or are we pretty much ahead of the game on this?

171 MS. PELLETIER: We’re probably all about at the same level. I mean, we follow a lot of the -- you know, we follow behind the States in a lot of cases, but in a lot of cases we’re ahead of the curve from -- we’ve learned from what they’ve done that is kind of working or not working.

172 And we do believe that we have a more national focus with our 9-1-1 system; like, we are very cohesive and coordinated in our efforts. We just don’t have that -- we’re volunteers. We’re at the table because we think that there’s a great opportunity here to make it a national 9-1-1 next-generation 9-1-1, and I don’t know that there’s any other entities out there in other countries that are any further ahead, or we’re all about the same.

173 THE CHAIRMAN: Or specifically about defining criteria as who is trustworthy enough to be part of the interconnection.

174 MS. PELLETIER: I would say so. And if we use the example of the States, and what we hear from some of our colleagues is they have to deal with all of the different service providers kind of on an individual basis. They don’t have that one throat to choke, as we kind of affectionately refer to it around the table, and it causes a lot of delays in trying to determine where’s this call coming from, who do I have to talk to?

175 And it paints a picture that if you’re one service provider you offer this service, but if you happen to have somebody else’s services you can’t access Text-to-9-1-1. So the whole notion that Text-to-9-1-1 exists really doesn’t because it’s not standard across the country.

176 Where in Canada we’ve done texts with 9-1-1 for the deaf and hard of hearing, and it is available standard across the country. So we are a little bit ahead of the curve in my view and in our collective views, I think ---

177 THE CHAIRMAN: Okay.

178 MS. PELLETIER: --- where that’s concerned.

179 And having the CRTC leading that, really the CRTC is the only body in the national realm that is looking at 9-1-1 as a ---

180 THE CHAIRMAN: Right. But in the same token our fear is that we end up having to own things that aren’t really ours to own because nobody else is doing that.

181 MS. PELLETIER: True.

182 THE CHAIRMAN: And we may not be equipped nor have the jurisdiction to do so.

183 MR. KELLETT: Yeah. And I understand completely from the perspective of what it feels like versus what it -- or what it may look like. I think the reality is that not much changes if we do this is an orderly fashion.

184 All we’re talking about in terms of a coordinating entity is the ability to have -- or the equivalent down in the U.S. is there’s a body called 911.gov and they’re the coordinating body that was put into place. The problem they have is they’re not attached to the FCC. They were created as an entity with good intentions but not a lot of ability to deliver.

185 If you look at the two entities -- and we’re unique in terms of having this -- with the CRTC emergency service working group and the members and what gets delivered, that in itself is a very unique model. When we talk to our U.S. counterparts they just simply say we’re very lucky.

186 THE CHAIRMAN: Right. And so ---

187 MR. KELLETT: And that’s not by accident.

188 THE CHAIRMAN: Right. So collaboration, cooperation all good. But at one point when push comes to shove you need somebody to make certain decisions.

189 MR. KELLETT: There’s that. And there’s also the aspect -- to go back to your point in terms of you don’t necessarily want to own it. We don’t want you to own it either. We do want your help in terms of creating a coordinating body for a period of time during transition so we get it done right.

190 But make no mistake, this is owned by municipalities, regions, and provincial governments. And at the end of the day there’s a lot of work that -- a coordinating entity is going to have a heck of an uphill battle, but a doable battle, in terms of getting everybody onto the same hymn sheet. But you can’t get there if you don’t have the starting script, and this is the starting script.

191 MS. PELLETIER: Yeah. And I think it will also help the CRTC in being able to make that deadline, you know, put a line in the hard sand maybe. Because it is technology and it is -- and my experience with a lot of projects is you take a year, well, you better put two years because there’s always something that’s going to come up.

192 But having the coordinating body sort of reporting on the progress that is being made on an operational level and a transitional level would definitely help in terms of a transition conclusion date, I guess.

193 THE CHAIRMAN: That’s a good reminder, especially since we sit in the building of the department responsible for the Phoenix pay system.

194 So currently under the system with respect to reliability and resiliency, which after we looked at it seems to be a success -- we’ve managed to do that. But we’ve created standards around that for the network component of the 9-1-1 system through a very general requirement that, you know, the carriers take reasonable measures to ensure resiliency and reliability.

195 When we move forward do you think that that general obligation continues to be sufficient?

196 MR. KELLETT: We do have a task with the emergency service working group right now looking at the whole issue in terms of service notifications. And we’ll be coming back with a report on that.

197 Through that process it’s fair to say that we recognize that as you transition to a new system, the opportunity for things to break more often is going to occur.

198 There’s examples out of the FCC in the U.S. where they’ve gone -- CenturyLink would be a perfect example -- and laid significant fines in terms of network providers that failed and took out many States, in terms of the availability of 9-1-1, for many hours or maybe days in some cases.

199 So would a mechanism or enforcement mechanism be necessary going forward? I believe the underlying rules are in place already, from the perspective that, like you said, there’s general rules. There may be a requirement to look at an ability for a governing body to take on what the FCC has in terms of fining. That’s really a regulatory decision that is left really to you in terms of it.

200 I’m going to suggest that as far as -- if we do this properly in Canada with the single national entity being controlled with a body that is actually overseen by the CRTC, then the need for -- or the likelihood of the same sorts of things happening that happened in the U.S. is mitigated a great deal.

201 THE CHAIRMAN: But there is -- I mean, right now, as I said, we have a general requirement to take reasonable measures. I suspect it would be very hard to take -- nor I’m not even sure it would be the appropriate thing to do because it’s not the nature of this thing, to take -- administer a monetary penalty approach to that sort of issue.

202 The real debate I think I’m trying to get to is that reasonable measures is sort of a broad aspirational obligation; it’s not a detailed specific standard that could theoretically be put in place. And I guess I’m asking whether you think that that is wise to go forward in a different more prescriptive way in terms of the standards going forward.

203 Does that occur later or not at all? And obviously we would have to focus -- were we to go down this hypothetically, standard making -- on the network component as opposed to standards for the PSAPs.

204 So I’m trying to get your sense of can we continue to ensure the outcomes necessary for Canadians, without necessarily going beyond the current standard in the way it’s defined now about a reasonable effort, to ensure that we have reliable and resilient networks?

205 MS. PELLETIER: Well, through service-level agreements that we already have in place with the ILECs right now, those standards could be applied in terms of resiliency, and redundancy, and service levels that we are expecting of the providers. And they could be in tandem with what the CRTC regulates in terms of the network connectivity.

206 So we would have expectations from a provincial or municipal PSAP or we would have certain expectations that the system won’t be down for -- and that there would be redundancies built in.

207 And so I think that that can be managed through -- but again where the coordinating body would help build some of those templates for the types of things that we need to look for or be cognizant of and what’s within the realm of possibility and what can we live with or not live with and apply those into service-level agreements with the ---

208 THE CHAIRMAN: But you’re not of the view, or maybe you are, that those operational standards that are very important on a day-to-day basis -- are you of the view that they need to be translated into some black and white regulatory rule in order to be achieved?

209 I’m not necessarily advocating for that; I’m just ---

210 MS. PELLETIER: Yeah.

211 THE CHAIRMAN: --- asking you from ---

212 MS. PELLETIER: And again, it could go either way. But I think that from my experience the service-level agreements that we have right now with Bell Aliant, i.e. Bell, you know, there are those standards that are put in place and you know, we have the redundancies built it. So I don’t know that it would need to be black and white into a regulation under the CRTC. But it might have a little bit more -- especially since we’re going into a new environment with new challenges, maybe, that we’re not experiencing right now with the current environment, that might be a possibility.

213 THE CHAIRMAN: But at the same token it may be the area where we know the least about what the standard ought to be?

214 MR. KELLETT: You’re correct. And let’s use an example. Over the last 35 years in the system in Canada, the CRTC went out and did a little bit of work on reliability and came up with where you’re at today. Before you arrived on the scene we’ve had five times the reliability and we’ve had very, very few system failures in Canada and in comparison to the U.S. virtually none, in comparison.

215 So the reason that ---

216 THE CHAIRMAN: And why -- just ---

217 MR. KELLETT: The reason that is -- there’s a reason for that, though. There’s 6,000 PSAPs down there. There’s just over 100 in Canada in terms of primary. So logistically it’s a much more daunting -- it’s much more disjointed. So when we say we looked down there and we see, “Okay, well, they don’t even know how their information transits and the different places it goes through.”

218 So that in itself, from a network design perspective, is a big problem. You need to know exactly -- today we know exactly how 9-1-1 is routed. Tomorrow, for next-generation 9-1-1, we have to know exactly how 9-1-1 is routed: over what facilities, what are the points of failure, et cetera, et cetera.

219 So what comes forward in terms of the design of an emergency service, a national emergency service with redundancies, will be something that we collectively move forward together on and agree on. And that’s the work we’re doing at ESWG right now.

220 So it’s not something where you need to make decisions in terms of how that happens. You’ve already got it in place. The expectation is it will have the same level of reliability.

221 Do you have to go further? I think it’s the typical thing, “We’ll see how it goes.” And if things start to go off the rails and we think it’s necessary to put those sorts of protections in place, it’s almost going to be reactionary. But I think that’s probably more appropriate than trying to build the whole framework up front.

222 THE CHAIRMAN: Right. Do you foresee more challenges with respect to reliability and resilience with new forms of data inputs such as texting and video? Or we just don’t know yet?

223 MR. KELLETT: The short answer is there is more opportunity for things to break but there’s more ways to fix it real-time than there is under the existing. So really if you look at what I talked about earlier, the backhoe example, that’s what exists today. What we’re looking for going forward is the ability to come in on landline but also potentially come in wireless so that if you lose your -- if a backhoe takes out the landline you’re still up and operational with the wireless connection for the last mile.

224 So the same -- I think this, because it’s just the way resiliency works in terms of the internet in general, it’s probably -- well, it is much more resilient in terms of, well, if you lose a server here, there’s five other servers that will pick up the load and you’re not even going to notice it. So it is something that needs to be considered, but I don’t really think it needs to be considered at a regulatory level.

225 THE CHAIRMAN: Okay. With respect to costs and funding, would you agree with the idea that the longer it takes the costlier it will be and that therefore there is a need to create a deadline at some point. We don’t know when that will be but there will be a need. Would you agree with that?

226 MS. PELLETIER: Yeah, most likely there would be. You know, if we can do it faster, but the realities within provincial and municipal authorities is what is going to be that cost and what can they realistically achieve in a budget cycle unless there’s some ---

227 THE CHAIRMAN: Fair enough.

228 MS. PELLETIER: --- funding mechanism that can ---

229 THE CHAIRMAN: There’s a practicality of actually doing the funding. I understand that.

230 MS. PELLETIER: Exactly.

231 THE CHAIRMAN: Right.

232 MS. PELLETIER: And where is the funding coming from? Like, how are we going to transition without having -- I can say if it’s put on the backs of a municipality or a province it’s not going to happen as fast as if there is a transition funding mechanism of some kind, and an ongoing funding model that is sustainable and equitable so that we can roll out something across the country in a timely fashion.

233 THE CHAIRMAN: Right. The reality, regardless of the speed at which it occurs -- and we’ve seen it even in the existing 9-1-1 system -- that not everybody’s come up to expectations the population might have across the territory. I mean, we’ve seen the debate in Yukon and Newfoundland.

234 The reality is that we’ll likely have for a period of time gateways allowing interconnection by legacy system to the growing next-generation 9-1-1 network. Do you think it would be a good idea to create incentives for those PSAPs that aren’t transitioning quite as fast and using gateways to perhaps bear a higher cost burden to sort of focus the mind on the need to move on and get ready?

235 MR. KELLETT: Yes.

236 THE CHAIRMAN: And when would that sort of focusing of the mind becoming critical?

237 MR. KELLETT: From a timing perspective, if you go back to what was suggested earlier, by 2018 we trial, by 2020 we look at rolling out, by 2021 we set a deadline so to speak. And the way look at it from a primary, today we have -- at this level we look after primary PSAPs.

238 In the future, I’m not concerned with the majority of primaries getting to where we need to fairly quickly because we work with them on a regular basis. Secondaries are going to be a bigger concern. So part of what we’re looking at is just because you can do something do you necessarily have to do it?

239 So there are certain secondary PSAPs out there -- and I don’t want to pick on Fire but I will pick on them for a second. Fire PSAPs tend to be much more fundamental in terms of their approach; simple, straightforward. And do we need to add the level of complexity and ability that we’re talking about for them to do their job? The short answer is probably not.

240 But that’s a decision we can make from a deployment perspective, and make recommendations back in terms of who needs to go and when. But there needs to be -- it goes back to what I said earlier. If you say there’s 10 things you need to do to get on that information highway, the way you get them on the information highway is simple. You simply say that as of such and such a date in 2021 the old system, the gateways, will no longer be supported.

241 So you’ve either done those 10 things and you’ve moved on to the new system, or you’ve gone to a different -- and got the services from a provider that’s already there. And so there will be some consolidation that takes place out of this process not by design but out of circumstance.

242 THE CHAIRMAN: And for secondary PSAPs, is there a cost incentive that ought to be in place as well just to be clear?

243 MR. KELLETT: The cost incentive for them I think it’s exactly the same because they have -- in order to be able to essentially do their business going forward, they’re going to have to be able to accomplish the 10 things to get them onto the new highway. There’s lots even going on today where departments like small single-entity municipal departments are joining up with regional entities.

244 That’s happening across -- well, it’s happening across B.C. right now and it’s happening in other places in Canada, specifically with Fire dispatch. And that’s all because they see what’s coming.

245 THE CHAIRMAN: Right.

246 MR. KELLETT: And it’s not just 9-1-1. They’ve got the whole thing to deal with in terms of land mobile radio. And what you see with the FirstNet project down in the States as far as putting in a national radio network, down the road radio network, 9-1-1 network, information highways they’re all going to be transmitting the information over the same. And, well, you’ll have a device that’s got an application on it for radio, an application on it for 9-1-1, an application on it for emergency management operations, et cetera, et cetera. And it’s just the -- so the silos that we have today are going to slowly but surely disappear.

247 THE CHAIRMAN: Right. Moving on now to building awareness around this for the population, the general population.

248 It’s something we struggled with when we did TEXT 9-1-1 for disabled communities because we were afraid that people would misunderstand that. But we also know anecdotally that there are people that currently TEXT 9-1-1 thinking that obviously -- because that’s how they communicate with their friends and families, they just assume that the PSAPs are doing the same.

249 So if we expand it beyond voice communication, and I guess we’ve already started, in your view, who should be responsible for coordinating awareness, when should we start doing that, and what should the public education look like going forward?

250 MR. KELLETT: That we see as a part of the role of the national coordinating entity. And understanding that -- I’ll use an example today. Mapping is quite important to 9-1-1, and there is very little coordination that takes place in terms of that yet if you go look at what’s taking place across Canada in terms of mapping -- and especially from an emergency perspective -- they’re keen to get on board with what’s coming next.

251 And we’re in a pretty fortunate situation in Canada that there’s one entity that looks after 90 percent of mapping in the country. So it’s one -- and they’re chomping at the bit to be involved in terms of what we’re doing here. So it’s fair to say that that’s one aspect of understanding that needs to take place in terms of municipal, regional, provincial responsibility. The hard part is the public. And that’s where we see the national coordinating entity being essential, along with a roadmap. So once you set the roadmap and you make it public, and this is what you’re following and this is what you can expect in terms of the service delivery and the timing of service delivery, that becomes the mechanism for education.

252 You used Text with 9-1-1 as an example. The reason we waited to the end to do the national media campaign on December the 1^st was because we wanted to kind of catch up so the availability was there before we had a bunch of people looking for it. This is a little bit different from the perspective that once you put the backbone in place -- assuming it goes into place in the fashion that we hope it will -- then the onboarding process can be done in a pretty quick timeframe with some very clear indications in terms of what’s going to happen when and what the impact is for the calling public.

253 THE CHAIRMAN: Setting aside false news, post-truth notions, the fact is different regions of the country will likely in practicality be advancing at different pace. And yet, many people are getting their information through platforms that go beyond those geographic boundaries, whether it’s Facebook or even national radio and television networks. So are you suggesting that the awareness only occurs when there’s a critical mass across the country that are operating in this world?

254 MR. KELLETT: I don’t see a reason to go different than we did with Text-to- 9-1-1 for the deaf, hard of hearing, speech-impaired.

255 As you point out, that does not mean there’s not going to be all sorts of examples of differentials pointed out. My fear is not, quite frankly, with the less populous provinces; quite frankly, I think they’ll be ahead of the curve. And you could see areas like Newfoundland that have basic right now; the proposal is to move them as quickly as possible to next-generation 9-1-1.

256 THE CHAIRMAN: Yeah.

257 MR. KELLETT: So I -- the concern at this point is the more populous -- I’ll just say it; Ontario and B.C. are a big concern. They don’t have legislation; they don’t have, at a provincial level, any sort of leadership in terms of moving this forward in a coordinated fashion. And whereas, I can suggest to you, in every other province the mechanisms are there already, they may not be well established but the core pieces are there to move this forward once we have the information to share.

258 So my concern is in the much more populous provinces than it is in the less -- the ones that look like they would be further behind, I think -- when we look at a trial, we’ll probably look at sometime -- someplace in the Maritimes.

259 THE CHAIRMAN: Right.

260 MS. PELLETIER: I’ll just add something. I think that it -- we do require a strong communications plan going forward, as things evolve or decisions get made. And the national coordinating-body would probably have sort of a sub-working group that would work on the communications, and what needs to come out and when.

261 And the reality is that yes, you will probably have regions that are NG9-1-1-capable; but, to the general public, what does that necessarily mean? Does it change the way that they do business?

262 As our vision, sort of -- our objective would be that, you know, 9-1-1 can communicate with anyone from anywhere, any device, any time. That’s our sort of nirvana, if you will, but how do you communicate that to the public is going to be one of our biggest challenges, and for the CRTC as well, to make sure that it’s well-understood and comprehensive in terms of where certain -- where you can Text-to-9-1-1 and where you might be able to send videos.

263 And that’s why having a national onboarding plan and who’s going to be ready and -- the better -- it’ll be best if we can get it done together as opposed to the piecemeal approach but we’ll have to manage that through strong communication ties.

264 THE CHAIRMAN: And the complexity includes the texting vehicles, right, because there’s a lot of different ways to text, from SMS to Real-Time Text to applications that provide texting-like functionalities?

265 MS. PELLETIER: And those we don’t like.

266 THE CHAIRMAN: You don’t. Okay, well, that was going to be my question. So -- all right, so is -- and it’s not just a communication issue; it’s also a going-forward. So what is your view as to the different types of means to text? Which ones should be allowed; which ones should not be? To what extent is what is being used, and popular, relevant to the PSAPs world to have another mission, and that’s to actually, you know, save lives?

267 MS. PELLETIER: Well -- and I think at our table we’ve kind of discussed the idea of even developing the 9-1-1 app that would kind of consume that, and then send it to the PSAP because the last thing you want is for a consumer to have to -- “Oh, I need to call 9-1-1; I need to use SMS or RTT or” -- and that’s work that the emergency services working group will kind of dabble with the technical folks.

268 But we need to have a mechanism that it doesn’t matter what you use or how you use it, there’s that interface, or that box in the middle, that mashes it up and sends it to the appropriate PSAP with the right information. And that’s what the end-goal would be in such an environment as next-generation 9-1-1 provides us with the opportunity to develop a network that can ---

269 THE CHAIRMAN: But you don’t like WhatsApp and Facebook?

270 MS. PELLETIER: Well, some of the experiences that I’ve heard through PSAPs is it’s like finding a needle in a haystack and it’s a false sense of security that is being provided to the consumer that they think, “Oh, yeah, I’ll get to 9-1-1,” only to find out that their call or their text was processed completely differently.

271 And then you have a police agency or an ambulance trying to find somebody that we have no way of tracing, or it takes a whole day for that service provider to give you any kind of information on that particular phone or that particular device.

272 MR. KELLETT: So a little further on that, Text-to-911, in reality, it’s becoming rolled-out right now across the U.S. ---

273 THE CHAIRMAN: M’hm.

274 MR. KELLETT: --- in a very disparate, confusing fashion from a citizen-perspective, in terms of where it’s available, and when, and how.

275 The good news is -- and this is from a 9-1-1 perspective -- it rarely gets used. And the reason is somebody that will text a friend that’s sitting right beside them, when they have an emergency, they want to hear the voice from the other end of the line so they know help is coming.

276 Texting, from -- and this is proven over and over down in the U.S. in terms of the places that have put it up and had it up running for a long time. It’s -- texting is appropriate in situations where people can’t talk because it’s dangerous. Texting is appropriate if they’re hiding somewhere, if you have some sort of school incident.

277 But generally speaking, if somebody’s got an emergency, they are calling; they want to talk to somebody on the other end of the line and provide the information and know that help is coming.

278 So will that -- I think there’s other things, like video-calling, that’s coming. There’s all sorts of different mechanisms in terms of information being provided. Should we set a limit on it? The simple answer is you design the system that when the digits 9-1-1 go into an SMS or, later on, into Real-Time Text so that it interacts with the PSAP in a fashion that works from end to end. And that’s a technical and operational thing that we can provide some good advice on in terms of it.

279 Should you be able to get a hold of 9-1-1 by yelling for “Help! Help!” on Facebook? From a social-media perspective, we don’t have that problem today. If somebody yells, “Help! Help!” we get the 9-1-1 calls. So even though Facebook’s not connected to 9-1-1, we get the call anyhow.

280 THE CHAIRMAN: Because somebody’s relaying that ---

281 MR. KELLETT: Somebody’s watching it and they’re calling.

282 THE CHAIRMAN: Yeah.

283 MR. KELLETT: Right? Third-party calls in terms of those types of emergencies have happened many, many time and they’ll continue to happen.

284 THE CHAIRMAN: Right. But you’re -- the PSAPs lack some information, however, when that occurs, about location and so forth, so one would think that you would want to have a messaging system that’s reliable and effective.

285 MR. KELLETT: Absolutely. And the -- what’s on record and what’s been asked is, “What about a 9-1-1 app that we put out nationally?”

286 THE CHAIRMAN: Has anybody done that elsewhere in the world?

287 MR. KELLETT: It’s being worked on -- yes. The short answer is yes. It’s -- a couple of places in Europe have it. It’s a little different -- the reasoning they have it over there is they don’t have Phase 2 Wireless where they send XY coordinates. So they have apps that they’ve introduced over there in a couple of countries that are emergency-apps. The other place that’s really seriously looking at it is Australia and New Zealand.

288 THE CHAIRMAN: Okay. But nobody’s fully operational on it, yeah.

289 MR. KELLETT: The only place that’s fully operational that I’m aware of right now is Denmark.

290 THE CHAIRMAN: Right, a smaller population and, as you say, different information, single-language as well.

291 Can we learn anything from the U.S. on they’re texting experience ---

292 MR. KELLETT: I think ---

293 THE CHAIRMAN: --- including things not to do, I guess?

294 MR. KELLETT: Yeah, I think the simple thing is that ---

295 THE CHAIRMAN: You mentioned earlier that very few people actually use it, so I guess that’s one lesson.

296 MR. KELLETT: That’s one lesson. The other lesson is the FCC was -- their role in it to start out with was primarily, we think this is a good idea. So it wasn’t until they went and drew a line in the sand and said, "By such and such a date you'll have this done," that they're -- things are moving quite quickly down there now because of that. So that's a lesson learned.

297 THE CHAIRMAN: So you're suggesting we will have to do that in Canada at one point?

298 MR. KELLETT: Absolutely.

299 THE CHAIRMAN: And do you -- but you think it's too early, I take it, to actually set that deadline today?

300 MR. KELLETT: Correct. At this point in time ---

301 THE CHAIRMAN: It's part of the interim.

302 MR. KELLETT: --- it's part of -- it's way -- I think one of the things that you'll see on the record and you're going to hear about this week that bears a lot of fruit is that we shouldn't get caught up on the specific modalities of access. We should put the mechanisms in place to facilitate that and make sure it works in the end.

303 THE CHAIRMAN: Right, whether we think that video calling or internet of things or other telemetric -- telematics, sorry -- features would or not be useful, what you're saying is build it to make sure that if it does become useful, it is not excluded in the architecture?

304 MR. KELLETT: Correct. And you yelling, "Help! Help!" to your fridge and it calling us, it could work if your fridge has a fixed location and we can get there. Just saying. It sounds ---

305 THE CHAIRMAN: Yes, it's quite ---

306 MR. KELLETT: It's a little tongue in cheek, but it isn’t ---

307 THE CHAIRMAN: Well, you're ---

308 MR. KELLETT: --- because at least we know your fridge is in your kitchen.

309 THE CHAIRMAN: Most of the time, yes. And they're hard to move about. So there is location accuracy to some degree associated with it.

310 Do PSAPs currently support RTT; do you know?

311 MR. KELLETT: No.

312 THE CHAIRMAN: They do not? None of them, nobody's at that? Is anybody exploring it?

313 MR. KELLETT: I -- from the perspective of "can they support it?" the short answer is, it's not that difficult and it's just a matter of when it becomes available from originating network to set up a trial for the places that do have the capability.

314 THE CHAIRMAN: Okay, and as you said, we're not quite sure whether video calling or texting or whatever the new capabilities will be useful or not, but we have to plan for it.

315 But all these potential uses create a lot of data and data management, so I mean, there seems to be a difference of perspectives on the public record as to who's responsible for that, the management of all that knowledge or information. I'm sure it's knowledge. It's at least data points of all kinds. So where does the responsibility lie?

316 MS. PELLETIER: Well, that's one of the questions that we hope that these proceedings will get more clarity, because that is one of the main concerns from provincial or municipal or policing agencies, whoever is managing that data.

317 THE CHAIRMAN: But right now the PSAPs are responsible for the storage and usage of that data, are they not?

318 MS. PELLETIER: But it's mainly voice and an ANI/ALI record in some instances. In some instances, it's probably just voice.

319 THE CHAIRMAN: So why, going forward, would it not be the same principle that it would apply?

320 MS. PELLETIER: Well, there's the cost of managing that. There's also the liability. There's the -- like, if it comes in -- if it's something that can be pulled when and if they need it, but stored somewheres else in a cloud somewhere where it -- unless you use it -- if they use it in their 9-1-1 emergency response or for investigatory reasons, yes, they now own it; they have -- what is it -- continuity of record for that.

321 But one of the questions or one of the concerns we've brought about in one of our discussions was, well, how do you downstream it to the secondary agency? Then does it become a record of the ambulance provider or does it become -- is it still part of the 9-1-1?

322 So all of those standards and policies and procedures have to be talked about and looked into and a decision has to be made. So that's another kind of question at the operational level that maybe the coordinating entity could look.

323 MR. KELLETT: A little further on that. Back to what I suggested earlier, the ESIP network is the highway. It should have very little data that has to be actually stored and responsible for that particular provider. The -- if you use -- the information that gets pushed to 9-1-1 becomes the responsibility of the people that process it today. That doesn’t change. The people that pull the information, the additional information, and use it for their emergency response are going to be responsible for it.

324 So the short answer is nothing changes. And yes, people have concerns that well, when video calls start and I take a video call, I'm now responsible for storage. If you're in the PSAP business and you're accepting video calls, you're responsible for storage and disclosure. I don't think we have to complicate this. This is -- this should not -- what we're doing here should not ---

325 THE CHAIRMAN: You will agree that it's a cost preoccupation, however?

326 MS. PELLETIER: Yeah.

327 MR. KELLETT: They -- we've been part of putting that forward ---

328 THE CHAIRMAN: Right.

329 MR. KELLETT: --- in terms of the costs.

330 THE CHAIRMAN: But ---

331 MR. KELLETT: But just ---

332 THE CHAIRMAN: --- policy shouldn't be driven by cost considerations, presumably ---

333 MR. KELLETT: Absolutely.

334 THE CHAIRMAN: --- as a principal factor. It should be efficiency of providing the 9-1-1 service?

335 MR. KELLETT: There's that, and there's also the usability of information. So what PSAPs have talked about in terms of answering the -- if you -- they don’t need all of this information pushed, nor do they want it all pushed and arriving. So I'll use an example.

336 An accident happens on the Queensway, and you get three phone calls and six text messages and somebody shoots video, and all of that comes into the PSAP. Well, the reality is, after the first phone call, you’ve got what you need, in terms of emergency response. And then you handle, like you always do, the volume of other additional information that comes in. "Yes, we know, we know, we know. Are you a witness?" If there is, then we take additional information. End of story.

337 Tomorrow, if all of that comes in on video, then so be it. That's the way the information comes in and you're going to have to be responsible for it.

338 The point simply was that just because you can do it doesn’t mean you should do it. So ---

339 THE CHAIRMAN: Right.

340 MR. KELLETT: --- the fact that you can send all of this information in down one pipe and we'll have it all arrived and then you need a -- for all intents and purposes a real-time analyst to look at all of this information and figure out what's relevant and what's not, we back -- we looked at that and said, "That's not a smart way to do this. That's not helpful for the primary responsibilities and what we're looking at."

341 So why go down that road? If there's information available and somebody needs it, you just need to tag the information as being available and they can retrieve it if they want it. That doesn’t change the model today in terms of who owns it and who has to pay for -- so I think we -- through these discussions and through this consultation process, I hope the net result is, people understand no, we're not suggesting in any way, shape, or form that just because you can that you push every bit of this down the pipe and make it all available on one network so some ginormous data centre or -- you know, for all big data exists out there. What purpose does it really serve in the long run?

342 THE CHAIRMAN: But would you agree with me though that if we haven't figured out the cost model appropriately, there might be a disincentive to rolling out what otherwise might be a useful data set because people don’t want to be responsible when local politicians don’t want to be responsible for the additional costs? Would that be fair, that there might be a perverse disincentive?

343 MR. KELLETT: I think you're absolutely accurate, and -- in terms of it, and that's why we spoke a little bit earlier about once you get the mechanism up and running and you decide on the key features that are important in terms of hooking up, that municipalities need to make a decision in terms of once you end the legacy system support, they're out of business or they're getting some other entity that has invested in it on board.

344 THE CHAIRMAN: And with respect to the privacy consideration associated with all this information, in your view, are the principles any different than they are now? Are the rules that we have currently sufficiently appropriate to deal -- maybe the nature of the information changes, but the rules framing when and how people access it and how would this be treated and protected, does that need to change as well?

345 MR. KELLETT: If it rolls out in the fashion that we’ve described? No. There will be some things that you need to consider at a PSAP level related to storage and disclosure.

346 THE CHAIRMAN: Right.

347 MR. KELLETT: But that’s no different than today. I’ll use a perfect example. When they had the Stanley Cup riots in Vancouver a few years ago and they just got inundated with video information, they had to develop a whole new capability in terms of receiving, analyzing, and using an investigative and from a legal perspective for disclosure.

348 So that was not planned by the Vancouver Police. It was developed out of circumstance. Now there’s lots of places across Canada that have that capability because of that particular incident.

349 I think the same applies here. There will be things that occur that lead to, at a local level, more capability and more costs. Again, if you look at this in terms of rolling it out in a fashion that is coordinated and understood and logical in terms of improving the system both in the back end and operationally, then you can eliminate a lot of the difficulties that have been raised as far as -- well, from -- I think the existing privacy works.

350 THE CHAIRMAN: And subject to some adaptation. But there will also be costs associated. You want larger storage information there. And then you get back to the if you accept it you have to accept as well the costs associated with managing the privacy associated with those data points, correct?

351 MR. KELLETT: Yes.

352 MS. PELLETIER: Yeah. And I think as Chris mentioned -- sorry. I think as Chris mentioned, that that’s not something that is unknown to the service providers, that they would have to -- anything that they accept they would have to store. And they’d be part of the same level agreement that they are right now where they have to keep it for a certain amount of time and that storage goes hand in hand.

353 And I would go back to -- I think it’s important to put the mechanisms in place for that data to be available. But also over time I think a lot of the policies and the standards that will develop through experiences that, you know, “Well, yeah, we can do it but it really hasn’t proved to be useful over the last three years,” there will be some shift in how things get managed or get adapted.

354 There’s thing like, you know, fire service want to have the floor plan. Well, that data will only be as good as the processes and the procedures behind it to manage that data. How accurate is it? How timely is it? You know, has the building been renovated and it’s not longer useful? So there’s all of those kind of operational things with big data that are going to kind of be something that all of the stakeholders will have to sort of really look into and provide the standards and the policies and procedures behind it.

355 THE CHAIRMAN: My last questions before I turn to my colleagues to see if they have questions is, in terms of the transition, your vision is very much an iterative approach with coordination driven by close CRTC oversight?

356 MS. PELLETIER: Yes.

357 THE CHAIRMAN: And that we will have to probably correct, learn, and adjust course as we go through this, but that that is the only way to get from point A to point B in what is probably a multi-year project, correct?

358 MS. PELLETIER: I would say so, yes.

359 THE CHAIRMAN: Okay, good. Okay.

360 Vice Chair Menzies?

361 COMMISSIONER MENZIER: I just wanted to follow up on that in terms of this coordinating body.

362 Well, first of all, you’re the Coalition of the Willing. Are there any unwilling that we should be aware of?

363 MR. KELLETT: As the Chair pointed out, there’s always people that look at this and will look at it from the perspective of, “We don’t want to be part of this.” And we recognize that that’s something that needs to be factored in as we move forward.

364 But that’s why we talk about the line in the sand and the ability to on-board and end support for the old systems because without that there’s going to be people that essentially say, “Well, at a local level this doesn’t make sense to us.”

365 Without a plan going, without coordinating this going forward, I think that becomes a bigger problem than if it’s coordinated properly.

366 COMMISSIONER MENZIES: Right. But the new coordinating body would have responsibility for shepherding oversight over a coordinating body. So it’s a sense of responsibility for moving things forward but no real authority to move things forward; is that correct?

367 MR. KELLETT: Yes.

368 COMMISSIONER MENZIES: Other than moral?

369 MR. KELLETT: And other than -- oftentimes when you look at this, how things happen, especially in Canada around what we’ve done with 9-1-1, we have done so in a fashion where people come along with us because we give them a roadmap and a plan and we work with them and we get there together. This is no different.

370 Now, we do not see -- first of all, you don’t have the jurisdiction. Second of all, it’s not what is being looked for in terms of coordinating. So they become the entity that is a trusted source and a help. And from a -- I’ll use the Canadian Numbering Administrator; really when you look at it in terms of its function, not a lot of people understand technically what they do, how they do it, but they know the net result is, “I’ve got a new area code” at some point, right? So they don’t have to understand any of the mechanisms, but they know who the body is that does the work in terms of when you’re getting number exhaustion taking place in certain areas.

371 COMMISSIONER MENZIES: Right.

372 MR. KELLETT: It’s the same thing for this.

373 COMMISSIONER MENZIES: No, I understand that. And thanks for clarifying because saying, “I’m from Ottawa and I’m here to help” can be received in different fashions in different places, right? So we have to be conscious of that.

374 In terms of bringing this body to an end and -- well, sort of two parts to this question. Wouldn’t there be demand for it on a going-forward basis? I mean, won’t there always be new technological developments? Won’t there always be another next generation? You know, if this is the NG9-1-1, why would it stop? And if there’s a need for it now why would the need for it end?

375 MS. PELLETIER: Well, that’s where the Emergency Services Working Group comes in. The national coordinating entity would be sort of moving the bar forward until such a time as everybody is on NG and ---

376 COMMISSIONER MENZIES: Right. So this just provides the “giddy-up” for the next few years to get that going?

377 MS. PELLETIER: Exactly.

378 COMMISSIONER MENZIES: And then steps back?

379 MS. PELLETIER: Yeah. And if ---

380 COMMISSIONER MENZIES: And the other part of that question comes in terms of funding. If we are going to set deadlines, right, for certain things -- and there’s -- I mean, you know better than I, there is a great variety of points of view, depending on which PSAP you visit, on all of these matters, right? Some would want absolutely nothing to do with Text-to-9-1-1 for instance, et cetera, et cetera; others would be very excited about it.

381 But if you’re going to set a deadline -- and all of these changes will come at considerable expense for some of these PSAPs. Isn’t there a chance some of them would respond by just sort of saying back to this body/us, “If you want it, you pay for it and you figure out a funding mechanism for it that you can flow through to us”? Which starts to get very complicated because how can we nag -- you know, how can move things forward?

382 It’s not as if everybody is flushed with cash right now, right? You know, if provinces or municipalities say, “Great idea; we’ll talk to you when we balance the budget; we’ve got other stuff we’ve got to do right now.” How do we -- because the system is kind of working right now -- how do we avoid that hornet’s nest?

383 MS. PELLETIER: Well, I think for the jurisdictions that do have the legislation and do have, kind of, the source of funding through the phone levies, we are seen as the governing body to manage the 9-1-1 environment. And it’s very much a back-and-forth between the PSAP stakeholders and what’s within the realm of possibilities. I think that the conversations will start kind of forming as we have more lines in the sand and a little bit of a framework put together where the realities of maintaining your PSAP versus consolidating, integrating, finding new ways through this highway, finding new ways to still offer the same service but in a more economical fashion, I think we might see that. I mean, that’s where I think we can go.

384 And the coordinating body would help in trying to identify what are those pitfalls or where the dragons lie within each of the jurisdictions to say this is going to be problematic here but how do we help manage or help guide the way forward?

385 Does that answer your question? Or, Chris, do you have ---

386 COMMISSIONER MENZIES: Well, not really. But I mean it was a fairly hypothetical question anyway, which is probably difficult to answer. It’s more an expression of concern because the two provinces that don’t have legislation constitute more than half the population of the country, and that gets very tricky in terms of the financing for it and the pushback we might get because some people -- it’s a financing push and pull, I guess, in terms of that.

387 Do you have any suggestions on how this body might be structured so that it had its terms of reference avoided some of those pressures?

388 MS. PELLETIER: I guess one of the things right now is the Coalition of the Willing is just that, it’s a volunteer body. And if I can use the example, it’s being done on a corner of our desks while we do our many other jobs and mandates of our day-to-day work within our own environments.

389 But I think what we’re envisioning as a national governing body is that we can focus directly on all of those questions that we’ve posed in our strategy. We’ve put some context into where we think we need to go next in terms of -- you know, one of the things we decided at our last conference call is after this hearing what do we do; do we continue?

390 And we said yes, we might as well continue. And we’ll try to kind of put some thought to a legislative framework and something that if there is a national entity that gets put together, we can provide all of the information that we have and help move the ball forward and address some of those concerns that we’re all hearing, we’re all talking about but nobody has actually been able to say, “Yes, it will be this way” and then people can move forward.

391 COMMISSIONER MENZIES: And the last point. Do you have support from all of the provinces and territories for this position? Your coalition, does it include representatives from ---

392 MS. PELLETIER: Ten (10) provinces and territories. And what was it? Ten? How many municipalities?

393 COMMISSIONER MENZIES: Ten (10) provinces, three territories?

394 MS. PELLETIER: Twelve (12) municipal members, including all of the large municipalities.

395 COMMISSIONER MENZIES: Okay, thank you.

396 MS. PELLETIER: Yeah.

397 THE CHAIRMAN: Commissioner Simpson?

398 COMMISSIONER SIMPSON: Good morning. My line of questioning has to do with something that the Chair had brought up earlier with respect to trusted and untrusted parties.

399 To start off, I think it’s fairly clear that with respect to social media and to some alternate forms of communication, these services confound the PSAP because they’re not necessarily as efficient or effective as you’d like them to be because there’s not first-hand contact with the caller.

400 But I was wondering if you could tell the Commission what your position is or experience is with respect to existing services? I’m thinking alarm monitoring companies, services like OnStar where, you know, if an airbag goes off and there isn’t a call generated by the driver you get one from an intermediate source where there is contact. Is that type of intermediation working?

401 MR. KELLETT: So to use the OnStar example, a well-established entity that’s been in place for a long time. To put it into perspective, they process about one percent of their calls through to emergency services. So they look after 99 percent of the calls themselves.

402 COMMISSIONER SIMPSON: Flat tires, that sort of thing.

403 MR. KELLETT: Exactly. So from that perspective in terms of screening calls and making sure PSAPs only get emergencies, it works very well.

404 The next piece is when they contact emergency services. That’s a bit of a cumbersome process that could be streamlined a lot with being able to send information online versus having to provide it verbally. So that’s an opportunity that we’d look at in terms of those type of companies.

405 And same thing with alarm companies. A lot of times they know there’s something going on at a particular premise and it’s not a false alarm, and being able to provide that information in real time so it just populates a screen and you can send it off right away without having to type it all in would be -- is going to be helpful as well.

406 COMMISSIONER SIMPSON: My last area to explore on this subject is with respect to disruptive technology. With technology such as Uber, it not only changed the game in terms of how contact is made between user and provider but it actually often just jumped the rails and provided a different type of provision system.

407 I was caught by E-Comm in Vancouver’s statement. I can’t really be specific as to what was said, but it was the generality was that they could see a day where their type of PSAP is not in that business because of emerging technologies.

408 So I guess the question is, as the Coalition of the Willing represents sort of, you know, first-tier PSAP representatives and as you look at next generation and emerging technology, have you had discussion amongst yourselves as to how you might manage the possibility that there becomes almost a two-tier system like the medical industry is coping with where those who can pay can buy enhanced services, and should you find yourself through telecoms or other third-party agencies wanting to provide a new type of monitoring and reporting service that you find yourself down the road dealing with a growing number of intermediations?

409 MR. KELLETT: That’s a great question. In terms of disruptive technologies, I’ll let E-Comm answer because we don’t speak on behalf of the PSAPs. You’ll have lots of good presentations coming up from them.

410 But the piece specifically on what happens in terms of possibilities going down the road, there’s a possibility that 9-1-1 as an access point may become an App in the future. And that App may be so smart it can go directly to police, directly to ambulance, directly to fire.

411 The difficulty with those -- even if that was possible, it doesn’t deal with the motor vehicle collision where there’s leaking and so you need the fire department and you need the police and you need the ambulance; so you need all three services. So one App, no matter how disruptive it is in terms of technology, is not going to solve that particular riddle in terms of multiple responses from multiple jurisdictions in a lot of cases.

412 So going down the road as we adapt, there are things that I think will make it easier for 9-1-1. There may a day when for all intents and purposes 9-1-1 is just handled for all intents and purposes as a process and that the people don’t come into play until you get to the dispatch aspect.

413 So does that put PSAPs out of business? No, because the same people that answer the call that do the dispatch are the same people that answer 9-1-1.

414 So the role may change a little bit or be redefined as you go forward. And that’s part of what you’ll hear from PSAPs, is you’ve got to stay focused on what the primary goal is.

415 Commissioner Menzies makes a good point in terms of there’s different opinions out there in terms of what needs to happen to help 9-1-1 versus help Emergency Services, and who’s going to go there and when is part of it. So there’s got to be a degree of impetus and urgency in order to get people to move to this particular system.

416 And it’s no different than the analog to digital TV. At some point you drew the line in the sand and said, “Well, sorry, analog is not going to be available anymore; that’s it.” That old system and all the trunking and all the costs go along with dedicated trunking. And the old, old technology, SS7, and all the stuff that was working, that’s gone. And it has to be. Because it can’t be supported anymore.

417 I’m going to -- plain and simple, 10 years from now you won’t be able to find anybody to work on those systems, let alone, you know, get parts for them, et cetera.

418 So this is not something that’s transitioning, because it works very, very well today. But it’s going to have to be replaced sooner than later.

419 COMMISSIONER MENZIES: In closing, then, given the acceleration that we experience with technology and given the dialogue that’s been happening with respect to transitions and implementations -- we’re talking in 10-year terms quite frequently with respect to next-gen -- but 10 years ago the iPhone didn’t exist and it’s now become the dominant feature in a lot of how technology is applied.

420 Should there be, within working groups or organizations such as yourself, an expectation that the Commission has of those groups -- given that we don’t weigh into your turf -- that there would be an active segment of those working groups that is really keeping their finger on the pulse of change so that if change occurs faster than implementation, that something can be done about it?

421 MS. PELLETIER: Yeah. Yes. The short answer would be, “Yes.” And it’s important to note that the technology is advancing at a rapid pace but it’s not designed and developed with 9-1-1 in mind. Where NG9-1-1 has an opportunity is we have an opportunity to make sure that the network and the system and the services that we want to deliver in an NG-9-1-1 environment can -- those technologies can adapt to us as opposed to vice versa where, you know, when people say, “Well, why can’t I Text-to-9-1-1?”

422 “Well, it wasn’t designed for 9-1-1 in mind. It was designed for you to talk to your friends, talk to your parents.”

423 In this environment I think it’s kind of the flip side, is we want NG9-1-1 to be able to kind of tell the technologies, “This is what you have to adapt or this is what you have to do in order to be able to offer 9-1-1 services from the various systems to your subscribers.”

424 COMMISSIONER MENZIES: Thank you. I just have to say, though, that I think it was Peter Drucker who said that, you know, plans developed in the perfect world of academia or industry are often contaminated by human beings.

425 MR. KELLETT: Reality sucks.

426 COMMISSIONER MENZIES: Thank you very much.

427 THE CHAIRMAN: Thank you for that. I think those are our questions from everyone on our side. So thank you very much for your participation so far.

428 And we’ll take a 10-minute break. So we’ll be adjourned until 11:25.

429 Donc, de retour à 11h25.

--- Upon recessing at 11:15 a.m.

--- Upon resuming at 11:27 a.m.

430 MS. ROY: Please, take your seats.

431 THE CHAIRMAN: A l’ordre s’il vous plaît. Order, please.

432 Madam la secrétaire?

433 MS. ROY: Merci.

434 We will now hear the presentation from the Canadian Interoperability Technology Interest Group, CITIG. Please introduce yourself and you have 15 minutes for your presentation.

PRESENTATION

435 MR. TORUNSKI: Good morning, Mr. Chair, Vice-Chairs, Commissioners, Commission staff, and all those here today participating in the hearing.

436 My name is Eric Torunski. I am the Executive Director of the Canadian Interoperability Technology Interest Group, known as CITIG.

437 CITIG is a not-for-profit Canadian corporation governed in partnership by the Canadian Association of Chiefs of Police, the Paramedic Chiefs of Canada, and the Canadian Association of Fire Chiefs. Today, CITIG is made up of about 2000 volunteers from the responder community, different levels of government, non-governmental organizations, associations, academia, industry, and we all work together to improvE the safety and security of first responders and the people and critical infrastructure of Canada, mainly on interoperability-related issues.

438 I’m very pleased to be here today with you and I’ll keep my comments brief and at a very high level.

439 So I’d like to start off by saying combined, in Canada, there are approximately 115,000 police officers, career firefighters and paramedics. There’s an additional 144,000 or so volunteer firefighters that service our nation. And add to that the hundreds of thousands of individuals from health care, social services, municipal departments, the Canadian forces, utilities, to name a few, that might become involved in responding to a call for service and it’s clear that the enormity of Canada’s response network is big.

440 So the vast majority of the calls for service that are directed to responder agencies, and ultimately responders, are through by the current emergency 9-1-1 emergency system. So in short, we have about a half million people responding to a subset of the estimated 12 million or so annual calls to 9-1-1. It’s truly staggering numbers.

441 Now, the move to next-generation 9-1-1 is inevitable. The change will not be easy, but change is required. And the Tri-services Chiefs Associations recognize and appreciate the efforts of the CRTC and many others in the establishment of what will become the regulatory framework for next-generation 9-1-1.

442 So I am here today specifically to endorse the approach put forward by the Coalition of the Willing that just spoke. CITIG and members of the CACP, CAFC, PCC, the Tri-services Chiefs Associations, were actively involved in the creation of the Coalition and helped in some of the excellent work that they’ve done since they formed.

443 So as put forward by the Coalition, the tri-services chiefs support Vision 2020; the creation of a National Coordination Entity; and work to facilitate a Consistent Future Funding Model.

444 Moreover, CITIG and the Chiefs Associations respectfully submit that the Commission should do what’s in its power to support, enable, and facilitate a collective, national approach to the development and introduction of NG9-1-1 capabilities across Canada. We recognize that coordinating the operational development of NG9-1-1 capabilities is not within the Commission’s mandate or responsibility. However, we urge the Commission and others who are like-minded to work with all stakeholders, including the service providers it regulates, to establish and support a national organization that could assume this responsibility.

445 So in moving forward, CITIG and the Chiefs Associations also respectfully submit that the Commission continue to consult with emergency response agencies to ensure the introduction of NG9-1-1 capabilities primarily benefit and don’t hinder responder operations. Responders will continue to be a willing participant in that process.

446 I’m sure you will agree, responders need the right tools to save lives and protect property. We believe that robust state-of-the-art public safety communications are essential to provide the public with the level of service, protection, and security it deserves and expects. The current emergency 9-1-1 system is the portal to these services, and as we move to NG9-1-1 capabilities, it is incumbent on all of us to get it right.

447 So thank you for allowing CITIG to present at this hearing. I would be pleased to answer any questions as best I can.

448 THE CHAIRMAN: Thank you for accepting our invitation to appear. I'll put you in the hands of Commissioner Vennard.

449 COMMISSIONER VENNARD: Thanks. Good morning, and thank you for coming to talk to us today. I see that your organization is made up of more than 2,000 volunteers. Do you extend across the whole country? What areas do you operate in?

450 MR. TORUNSKI: Yes, we're nationally and internationally, and when we say the 2,000 volunteers, it's those who have registered to access the practitioner's portal for interoperability information, so from coast to coast and beyond.

451 COMMISSIONER VENNARD: Okay, so that would be all the provinces as well as the territories?

452 MR. TORUNSKI: Yes, we have members in -- from every province.

453 COMMISSIONER VENNARD: Okay, so you're speaking on behalf of a lot of people. That's ---

454 MR. TORUNSKI: Yes, but primarily our governing members are the chiefs associations.

455 COMMISSIONER VENNARD: Okay. I want to just explore some areas with you today. I see that you are explicitly supporting the -- many of the ideas put forth by the Coalition of the Willing that we just heard from, and one of them -- of course, one of the main ones and one of the main -- key issues in our hearing is the idea of the -- of governance. And the Coalition and your support comes for the national 9-1-1 organization that would address standards, coordination, governance, and provide funding to the PSAPs as well.

456 Okay. Now, my first question for you is, have there been attempts made by the tri-services, being emergency responders, the fire, ambulance, and police, to lobby governments for that type of an organization?

457 MR. TORUNSKI: Well, I would answer that by saying there are a number of parallel developments going on that affect responders where we're seeing a similar need for governance and coordination. Primarily, I would say -- I would suggest that the National Public Safety Broadband Network is one. We know that there's some work needed in terms of governance and coordination and funding for the Canadian Communities Safety Information Management Strategy. Some could argue that public alerting could use a bit more nationally-coordinated efforts.

458 So we've seen a number of items that do need to be coordinated. We haven't specifically gone out and lobbied government ---

459 COMMISSIONER VENNARD: Sure.

460 MR. TORUNSKI: --- but we certainly work within the chiefs associations and our stakeholders to raise awareness about the need that needs to be addressed.

461 COMMISSIONER VENNARD: In your view, would it be possible for PSAPs and emergency responders themselves to create such an organization? So if they -- if the government is not really gaining a lot of traction, perhaps you yourselves could create such an organization.

462 MR. TORUNSKI: I believe the responder organizations and agencies would certainly be willing participants. I don’t believe we necessarily would have the bandwidth to create something ourselves.

463 COMMISSIONER VENNARD: Okay.

464 MR. TORUNSKI: Responder agencies across the nation, their budgets are -- primarily 80 percent is spent on human resources and responding, while what's left over is spent on infrastructure and equipment and trying to plan ahead. There's not much room for anything else.

465 COMMISSIONER VENNARD: Okay. And that's not the primary focus of the responding community anyway?

466 MR. TORUNSKI: Correct.

467 COMMISSIONER VENNARD: Okay, thank you for that.

468 Okay, I want to talk a little bit about some new methods of communication and where responders, emergency responders would basically fall in that. Now, we understand there's a general consensus that the first priority for transitioning to next-generation 9-1-1 should be IP voice services immediately followed by text messaging.

469 Would the responders agree with that general sort of consensus, which we -- which comes about from the submissions to our -- for our hearing?

470 MR. TORUNSKI: When it comes to the precise order of how this will be rolled out, the national associations will always defer to their members. Many of the technical experts are sitting in the audience now, and some of the gentlemen in uniform right now work directly in that line. And as the national associations sit, they will always defer to what our organizations are saying. So I would say that the consensus seems to be that's the order to follow, and again, nationally, we would endorse that.

471 COMMISSIONER VENNARD: Okay. Having said that, I would just like to talk for a few moments about some of the other things. Those would be maybe the first two areas to go into. And of course, when we're in a consultation like this, of course, we have the TSPs who are -- and the network providers that would be responsive to what's coming from the community and in a similar way as almost like a bottom up, where they would -- there's a whole variety of things that could be done, but what should be done.

472 And so therefore, the points of view of the responders is going to be very helpful for them and for us, because there's no point in doing something if it's not what's needed for the people who are actually going to be using that technology. And that's a pretty well-established principle through academia and business as well.

473 Okay, so having said that, what do you think would be sort of the next thing that would be good for -- and here, I'm thinking of things like the video -- being able to send videos and so on to first responders, because we've heard different things, and when you read through our interventions, we see that there are a number of people in organizations that are concerned about, for example, trauma possibly being experienced by PSAPs and so on by seeing things that they maybe don’t need to see in order to get their work done. Would you like to comment on that?

474 MR. TORUNSKI: Certainly. Of course, there's many, many unanswered questions.

475 COMMISSIONER VENNARD: M'hm.

476 MR. TORUNSKI: And again, as national organizations, we'll defer to those people doing the work and have the technical expertise.

477 Our main concern has been around interoperability and the lessons we've learned after deploying land mobile radio. That experience has shown us that if we didn’t pay attention to making sure information is interoperable, then we will get down into problems down the line.

478 Now, countless after-action reports in Canada -- whether it's after Lac Megantic or Stanley Cup riots or shootings in Ottawa or Montreal or wherever -- there's often two main things that emerge. One is that the responder agencies could have done a better job communicating with neighbouring jurisdictions or within other disciplines, to say, a firefighter to a police officer or police organization to an EMS organization. And the other theme that comes through over and over again is the need to better use and harness situational awareness information.

479 Now, next-generation 9-1-1 will eventually be the conduit to provide some of that situational awareness information from the public, whether it's an accident scene or -- well, most likely, if it's an accident scene or some sort of crime in progress, what is coming in from the public will be important information for responders to act on.

480 And that's where our focus has been, to make sure that the lessons learned through land mobile radio can be applied to data interoperability, which is essentially NG9-1-1, to make sure we can do this right and share information as needed, as authorized and do it properly.

481 So the order or the eventual order in which things are done or what’s important or what modes are being used, that doesn’t really matter. As long as it’s done with some foresight in making sure that information can’t be shared easily and respond to many of the issues that we’ve seen in the past.

482 COMMISSIONER VENNARD: So essentially you’re suggesting then it’s the right information to the right person at the right time.

483 And I guess what I’m -- as I was listening to the Coalition this morning and the way I’m thinking about it right now, is that if you have a national organization which is at a fairly high level, then at some point there has to be a shift to the people who are actually doing it. Otherwise you have the people here making decisions for the people there and these might not work.

484 How do you see that sort of transition happening in the transition period?

485 MR. TORUNSKI: Well, I think there’s certainly ways to make sure a national organization is grounded to the needs of both the public and responders at that level to make sure that the system really responds to the operational needs. If it’s set up properly that shouldn’t be -- it will certainly be complex but it can be done; I’m confident.

486 COMMISSIONER VENNARD: How do you see that happening? Because it seems like the higher up you go in a hierarchy, the less in touch with what’s actually needed. So it’s like there has to be different places where responsibility and obligations would shift from -- because the work shifts from one. And of course the funding would have to shift and the legislation might have to shift as well.

487 So for this reason, you know, the technology and the new modes of communication and the news kinds of information are actually really critical to what that national body and entity would look like, which is of course why I was talking about it.

488 Now, you said something interesting that, you know, PSAPs are essentially like an access point to all information that’s there. Would you see there being very much a dividing line at the level of the PSAP?

489 MR. TORUNSKI: Dividing line to divide what?

490 COMMISSIONER VENNARD: Dividing line in terms of the information and the methods of communication as well as the information. Because a first responder would need a certain kind of information and really he or she wouldn’t really know what that is. So at the risk of becoming overwhelmed by too much information, then the decision-making has to shift at some point to the person who actually needs or wants the information.

491 MR. TORUNSKI: M’hm. Yeah, that triaging piece.

492 COMMISSIONER VENNARD: Yeah, yeah.

493 MR. TORUNSKI: Yeah. I don’t personally know how that will work out, but it’s definitely ---

494 COMMISSIONER VENNARD: Yeah. Do you have a sense of what might work from the point of view of the responder?

495 MR. TORUNSKI: Well, the responder, he or herself, needs very little information -- the location, the type of incident. And there will be a number of -- the training will tell the person what they should be responding to. I’m trying to be as broad as possible.

496 COMMISSIONER VENNARD: Sure.

497 MR. TORUNSKI: The other -- when the incident is a little larger in scale then you have another layer that needs different information -- how to handle a scene, how to cordon off something, which way a plume is going, and all that situational information at that level. As the incident is larger in scale, it gets more complex and there’s many other levels of information that need to be given.

498 Of course the 9-1-1 system is one of the inputs to those different levels. So having that system be interoperable and able to share the same consistent information to various jurisdictions is incredibly important.

499 COMMISSIONER VENNARD: So in the definition of “interoperability” that appears on your website, for example, do you differentiate between, say, disaster and emergency, and a personal crisis of some kind, a car accident versus a tsunami?

500 MR. TORUNSKI: Well, we try and work with the definition of “interoperability” as broad as possible, people with the right information, right time, as authorized. It has been such an issue over the last years that is slowly getting resolved through our work and others.

501 But again, I go back to my comments earlier. We want to make sure some of the mistakes made in land radio -- land mobile radio deployment aren’t repeated in terms of data interoperability. That’s our basic message.

502 COMMISSIONER VENNARD: Okay. Would you care to go back over one or two of those lessons just to complete our records, just for -- because you’ve mentioned that a couple of times so clearly that’s something that’s an important point to you.

503 MR. TORUNSKI: Well, yeah, it’s a very complex issue that has happened in the past. And I mean, some of the reasons are incompatible or out-of-date equipment; the fragmented funding; fragmented or limited planning or coordination; spectrum issues, which shouldn’t affect NG9-1-1. But certainly a lack of governance and coordination has been probably the main reason we’ve had some interoperability challenges in a responder world.

504 COMMISSIONER VENNARD: Have you resolved them? How are they resolved or are they?

505 MR. TORUNSKI: Not completely resolved. But again, I believe Chris mentioned what you see on TV with a call going into 9-1-1, similar -- in a similar way, what you see on TV with the EMS being able to easily talk to somebody in the neighbouring jurisdiction or a fire or police colleague, that simply is not the case in many jurisdictions in Canada today.

506 But luckily, through the work of, well, CITIG, Chief Associations, Public Safety Canada with the Communications Interoperability Strategy for Canada, many provincial public safety departments or those responsible for it -- have focused on interoperability to make it more natural and more desired or easier to get to for people within a jurisdiction, certainly being able to give templates on how to build interoperability plans or some guidance. We’ve been doing a lot of that and others have as well. So the state of interoperability I can say has improved, but it’s still not where it should be.

507 COMMISSIONER VENNARD: How do we go about improving that? Is that the planning part?

508 MR. TORUNSKI: Improving interoperability or ---

509 COMMISSIONER VENNARD: Yeah, interoperability as you’ve defined it, which is not just technical but it’s also operational, legislative.

510 MR. TORUNSKI: It really does have -- well, there’s something that we use called the “interoperability continuum” which lists five lanes, whether it’s -- the technology is only one small piece of it, you know, and it’s really governance -- standard operating procedures, training. It’s really trying to move the bar forward on many different fronts.

511 COMMISSIONER VENNARD: And basically harmonizing whatever it takes to make sure that things can get done by the people that need to get them done?

512 MR. TORUNSKI: That’s right. That’s right. And then when we apply these lessons to next-generation 9-1-1, if we can ensure, at the basic level, that the data coming in is usable by a wide number of people as authorized then we’ve gone past some hurdles that we’ve seen in the past. So that’s really what our plea is.

513 COMMISSIONER VENNARD: Yeah. What are your views on things like the use of social media and so on when it comes to responders? What are the responders’ views on that? Going back to the idea of, you know, the different forms of communication, new technologies, and so on. Are they useful, not useful? Sometimes they would be. Who should make those types of decisions? What are your views on that?

514 MR. TORUNSKI: Certainly some sort of coordinating entity can get a handle on it a lot better than I could.

515 The views on that is it’s -- certainly the public has grown to expect to be able to use social media to contact emergency responders, or to get some sort of response. We’ve seen different studies that say that people believe they can do that.

516 And if -- being the father of a teenager, I can tell you that teenagers communicate much differently than other people and they expect -- it’s really a public expectation that this should be a way that they can communicate. And as responders or responder groups, we need to educate on how to properly communicate. Whether it’s through social media or whether it’s not, it doesn’t matter; it has to be considered.

517 COMMISSIONER VENNARD: Who do you think should be responsible for doing that?

518 MR. TORUNSKI: Well, collectively we have to all be responsible in some measure. I mean the agencies collecting the information have to do their part; the government has to do its part; and -- I don’t -- through a national-coordination entity we would probably be able to get a workable solution by more people, you know, by looking at best practices, what’s worked elsewhere, what could work for us, and leveraging knowledge of others.

519 All that to say, I don’t necessarily have that answer but I know how we could get it.

520 COMMISSIONER VENNARD: Okay. According to the submission of the Coalition ---

521 MR. TORUNSKI: M’hm.

522 COMMISSIONER VENNARD: --- they -- there’s an estimate there of about 30 percent increase in cost and so on with new forms of information coming in, possibly new analysts needed for it, a different kind of a structure. What would your thoughts be on that?

523 Your organization supports the submission of the Coalition so what are your thoughts on that? How do you see that -- how do you see that having to happen, or does it have to happen?

524 MR. TORUNSKI: Well, whenever you change processes there’s work involved. And indeed, as we change the way 9-1-1 calls -- or emergency responders interact with the public and how calls are coming in, there will be costs to that. I’ve seen that 30 percent figure and it might be conservative; it might not. But they’ll definitely be changes, changes -- plenty of changes in the way -- in all processes involved in this. And I don’t know exactly what it’s going to look like but I know it will be most likely costly and ---

525 COMMISSIONER VENNARD: And change, we can’t get around it, can we?

526 MR. TORUNSKI: Yeah.

527 COMMISSIONER VENNARD: Yeah. What -- just based on your thinking, and your membership, and your knowledge of the first-responder communities, and so on, what do you think would be the biggest change coming in as a result of different -- of next-generation 9-1-1? Is it the different forms of communication? Is it just an organizational -- what do you see? What do you see as being the being the big thing for you guys?

528 MR. TORUNSKI: Well, obviously the call-taker’s role is bound to change because of the different modes. There’s certainly going to be -- brings more data to work with and that brings upon storage problems, problems -- well, I should say “problems’ -- storage challenges and how to keep, categorize, and use all this data.

529 I see that as probably the two biggest things to deal with that will really require a fundamental shift on how that work is done currently.

530 COMMISSIONER VENNARD: Do you see the role of the PSAP as changing quite dramatically or do you see that there’s a need for a complementary role?

531 MR. TORUNSKI: I think the role remains the same, but some of the processes will certainly change.

532 COMMISSIONER VENNARD: Okay, and hence some of these costs and the differences in the procedures and so on?

533 MR. TORUNSKI: Yeah.

534 COMMISSIONER VENNARD: How do you see the responsibility for the data -- for data that might come up, the ownership and storage, the use if it, access to it?

535 MR. TORUNSKI: Yeah, to echo some of the -- I guess what Chris was saying earlier, the data storage will be certainly an issue in who has to be the steward of the data.

536 I don’t have a firm answer to that but I see the data coming through; there’ll be a portion that needs to be owned by the PSAPs because it’s what’s coming in; some of it has to be elsewhere and owned by somebody else, especially if it becomes evidence.

537 I don’t have -- I can’t give you a specific plan on how that is but there’s definitely many, many issues that need to be resolved.

538 COMMISSIONER VENNARD: And if that would part of that whole sort of process from somebody actually calling to it happening because somewhere along the line, if there is going to be more data and there is a desire in order to improve service and response to have access to more data, then all these different little intersectioned points are going to have to be dealt with in a lot of ways, not just operational but also in terms of governance, in terms of legislation, and so on as well.

539 MR. TORUNSKI: Yeah, privacy ---

540 COMMISSIONER VENNARD: Yeah.

541 MR. TORUNSKI: -- retention, standards ---

542 COMMISSIONER VENNARD: Yeah.

543 MR. TORUNSKI: --- there’s a lot more questions than we have answers right now.

544 COMMISSIONER VENNARD: Yeah. What about something like, for example, access to medical data, for instance? If you take -- you know, just to think of a very specific example of a paramedic who might benefit from his or her response to somebody who’s in medical distress, for example, by being able to access; do you see that as being something that should be a direction that first responders would want to focus on or ---

545 MR. TORUNSKI: Well, yeah, there’s going to be a great number of governance issues to resolve and privacy issues to resolve. Often, I can say, that when it does come down to somebody -- ultimately, to somebody’s safety, there are ways to share that data, thankfully. I’m no privacy expert but there will certainly be a -- some very tough questions in there that will need to be worked out.

546 COMMISSIONER VENNARD: Yeah. Is the first responder community talking about some of these tough questions?

547 MR. TORUNSKI: Yes.

548 COMMISSIONER VENNARD: Yes.

549 MR. TORUNSKI: Often not only are some of these issues the focus of, say, national AGMs for either the paramedics or the fire chiefs or the police chiefs, but there’s committees set up that kind of look at these issues and look at the technology coming down the line and try and figure out the impact. There’s work going on.

550 COMMISSIONER VENNARD: Yeah. What would you suggest is the stage of that work? Is it recognition of the issues and just trying to figure out what -- even what questions to be asking and looking at?

551 MR. TORUNSKI: Yes, very much so.

552 COMMISSIONER VENNARD: So far in advance of any kind of solutions because we don’t even know the technology and so on. So we’re very early in the stages of all of these different things, for sure.

553 MR. TORUNSKI: Yes.

554 COMMISSIONER VENNARD: Does the first-responder community have viewpoints -- I’m sure they do and perhaps you can just suggest what they might be on things like the automated-data car-crash notification and so on, user-generated data. I mean it’s one thing to have the same data that you’re used to having; we, in some sense, know how to handle that and get it in a new form of communication. But it’s another when it’s a new kind of data altogether. Would you say that would fall in with that 30 percent of new things that are coming?

555 MR. TORUNSKI: Yeah. If I understand your question correctly, all this data can be valuable.

556 COMMISSIONER VENNARD: M’hm.

557 MR. TORUNSKI: The work is really going to be figuring out a process to triage this data as it comes in and figure out what’s useful, what’s not, and how to act upon it -- huge question, huge dilemmas right now.

558 COMMISSIONER VENNARD: Yeah. Would you say the first-responder community is at the point of being aware of some of these issues without solutions for it?

559 MR. TORUNSKI: Yeah, there’s a -- I mentioned it earlier. There’s a growing -- I wouldn’t call it a movement but there’s growing awareness around the Canadian Community Safety Information Management Strategy, which is a higher-level piece of work going on to try and connect some of those dots on how to deal with all of these information-management issues that are -- we’re starting to face right now, whether it’s, you know, body-worn video or information that has to go from A to B through the courts. There’s ways to streamline this, there’s ways to be interoperable, there’s ways to -- there’s better ways to access information and use information from disparate systems.

560 This is being looked at. It’s something that especially on the police side that’s been growing over the last couple of years. Again, it could be further down the road but at least there’s an awareness growing.

561 COMMISSIONER VENNARD: Yeah. Now, we’re at the very early stages of all of this too so that’s why we’re poking around in some of this.

562 I’m wondering now about next-generation 9-1-1 App. Do you see that being of use to the community that you work with?

563 MR. TORUNKSI: Certainly. Anything that can bring some sort of information in that would prove useful to a responder in helping save a life or protect property they would be pleased to look at ways to try and incorporate that. Certainly.

564 COMMISSIONER VENNARD: So does that sounds like something that might be useful, in a very general sense?

565 MR. TORUNKSI: If the information that comes out of it helps responders, yes, and if it can reach the public in a way that it will facilitate them telling responders about a certain incident then certainly.

566 COMMISSIONER VENNARD: So you see that being very useful in terms of if an App were developed to develop it in collaboration with the first responder community?

567 MR. TORUNKSI: Certainly it should take into consideration the needs of the responders. You know, if responders are getting information that is not useful or can’t be acted on properly then it’s not much use.

568 COMMISSIONER VENNARD: That’s just noise in the system at that point.

569 MR. TORUNKSI: Exactly.

570 COMMISSIONER VENNARD: If it’s not useful, yeah.

571 Okay. So the information management challenges sound like they are very large and will be getting larger.

572 MR. TORUNKSI: Certainly, yeah, with next-generation 9-1-1, other parallel developments with more and more data. The influx of data coming in is growing exponentially so it’s a very real concern.

573 COMMISSIONER VENNARD: Very real concern, okay.

574 Do you see that there’s going to be huge privacy issues in the management, the data itself, the storage of it, retention, retrieval and all of that? What about privacy, is that something that is really, really high on the list or is that part of the whole thing?

575 MR. TORUNKSI: I’m sure privacy -- privacy is incredibly important. With say a national coordinating entity, some of those privacy concerns can be addressed right at the start and made sure that it becomes very important throughout the entire process. So, yes, definitely.

576 COMMISSIONER VENNARD: Okay. My final question or area for you has to do with design principles and participation and design discussions of the next-generation 9-1-1 network, and specifically accessibility groups.

577 And sometimes we learn very well from the challenges that we’ve faced already in order to move forward and master them in the future, so maybe you could just outline for us -- do your organizations experience challenges when responding to requests for assistance from persons with a disability? And how -- do you have numbers on that, does anybody keep track of that, is it anecdotal information, is that something that should be studied, measured much more than it is; thoughts on that?

578 MR. TORUNKSI: You know, anecdotally I’d say it’s obviously an important issue. I don’t have any numbers to back that up. And I would also defer to some of my colleagues who are sitting in the back who are certainly much more knowledgeable on this issue.

579 But the basic premise is that anyone in distress should be able to get access to service, emergency service when they need it. So from the national perspective, that’s I think what we would re-iterate. But I’m afraid I don’t have any solid numbers on if it’s an issue or not.

580 COMMISSIONER VENNARD: Okay. Well, thank you very much. Those are all my questions.

581 THE CHAIRMAN: Apparently those are all our questions. So thank you again for participating in the hearing.

582 I think it would be the right time to take a break so why don’t we take a break until 1:15 and continue with the rest of the hearing for today. Donc, en ajournement jusqu’à 13:15.

583 Merci.

--- Upon recessing at 12:08 a.m.

--- Upon resuming at 1:18 p.m.

584 THE CHAIRMAN : À l’ordre, s’il vous plaît.

585 Order, please.

586 Alors, Madame la Secrétaire?

587 THE SECRETARY: Thank you. We’ll now hear the presentation of Calgary 9-1-1.

588 Please introduce yourself and your colleagues, and you have 20 minutes.

PRESENTATION

589 MR. ODNEY: Merci, bonjour.

590 Good afternoon, Mr. Chair, Mr. Vice Chair, Commissioners and Commission Staff. My name is Doug Odney and I am Acting Commander of Calgary 9-1-1 in Alberta. With me is Acting Deputy Commander of Technical Services for Calgary 9-1-1, Magni Magnason.

591 We are pleased and grateful for the opportunity to sit before you on behalf of our city, our regional municipal partners, and stakeholders to speak on this important matter.

592 Calgary 9-1-1 is an integrated tri-service dispatch centre, serving police, fire and emergency medical services for The City of Calgary as well as for several surrounding municipalities. Formed in 2006, Calgary 9-1-1 brought together three separate municipal dispatch centres into one coordinated tri-service dispatch centre. Calgary 9-1-1 is the largest PSAP in Alberta and one of the largest dispatch centres in Canada, handling over one million emergency and non-emergency calls for assistance per year. Currently Calgary 9-1-1 serves as the PSAP for approximately one-third of Alberta's population.

593 We have 70 call-taking and dispatch terminals at our primary centre and 60 workstations at our fully redundant backup overflow centre. Our incumbent local exchange carrier is TELUS. Our 9-1-1service comes in through a Centrex system currently managed by the ILEC.

594 In preparation for NG9-1-1, we recently underwent an RFP to process and procure a new i3 capable IP telephone system. We are currently in negotiations with the preferred vendor, and our current schedule is to implement this next generation capable system by the second quarter of 2018.

595 We are also in the process of upgrading other systems in preparation for NG9-1-1, including the implementation of an ANI/ALI Management system plus a CAD to CAD middleware system to enable interoperability of computer-aided dispatch data to the secondary PSAPs we deal with, and to other related systems.

596 As we build our systems to prepare for NG9-l-1, we welcome this opportunity to share with the Commission our NG9-1-1 vision, and contribute to the Commission's efforts to establish a regulatory framework. This will ensure that organizations under its control will build and support the necessary infrastructure to meet the needs of PSAPs and first responders who are responsible for serving Canadians and for improving public safety. We feel that Canadians are in urgent need of an uplifted 9-1-1 system.

597 At this point, I will hand our presentation to Deputy Commander Magnason.

598 MR. MAGNASON: Thank you Commander Odney.

599 For over 30 years, 9-1-1 voice services have reliably connected citizens with responders in times of emergency; 9-1-1 is the first point of contact for distressed callers. We are the first of the first responders. Our emergency communications officers, or ECOs, collect and decipher vital information to efficiently deploy help. Originally built for landlines, the 9-1-1 network has to date largely been a voice-centric service, which is now antiquated.

600 We respectfully submit that the Commission should immediately direct the provision of an ESlnet for Canada, as soon as reasonably possible.

601 Since the early 2000s, wireless and communications technologies have evolved exponentially, with cell phones now accounting for over 70 percent of our 9-1-1 calls.

602 Citizens are using new ways to communicate, through application-based messaging, social media, and video services such as FaceTime and Skype. The pervasiveness of smartphones leaves citizens positioned to collect vast data and to instantly capture pictures and videos that they can share with each other. At this point, this type of information is not part of the 9-1-1 call or emergency call process. On occasions when it is received, the process is both cumbersome and time-consuming while we retrieve these media using work-around solutions.

603 The Canadian 9-1-1 system has not kept pace with the cultural and behavioural changes from consumers’ adoption of technology. Citizens cannot communicate with 9-1-1 the way they communicate with each other. Not only has this created a gap between the expectations of the public, and the capabilities of PSAPs and 9-1-1 networks, it has also limited PSAPs and responders from capitalizing on capabilities to better serve the public and to improve public safety.

604 This gap has limited our ability to make services more accessible for vulnerable populations and those in need. We respectfully submit that the capabilities described in NG9-1-1 are not future capabilities. They are current consumer-market capabilities that the 9-1-1 system -- from end user devices, through the originating networks, through the 9-1-1 networks managed by the ILECs, and ultimately to the PSAPs -- have simply not kept up with.

605 We must therefore capitalize on these capabilities as soon as reasonably possible. And any future system design must ensure that we not only address the capabilities we know of today, but ensures that it is agile enough to quickly respond to the new capabilities of tomorrow.

606 We believe that NG9-1-1 is not a thing or an endpoint, but rather a concept that will continue to evolve. As such, we believe the focus of building an NG9-1-1 system should be less about any particular feature -- such as texting, SMS, or receiving pictures -- and more about creating a digitally-networked platform that enables continuous adoption of emerging capabilities that makes sense for 9-1-1 and emergency responders.

607 Before I continue, I'd like to take a moment to comment on how technology is changing in general, as this directly affects our vision for NG9-1-1. We believe that technology is changing not at a linear rate, but an exponential one, and we are now in the digital age of computing.

608 Some estimates suggest that by 2020 there will be over 50 billion connected devices on the internet. This Internet of things, or IoT, includes computers, phones, tablets, other communication devices, and sensors. Many of these may bring value to 9-1-1 services and to responders, as enabled devices could communicate with 9-1-1 emergency communications officers or even with other devices. Some capabilities that were formerly the realm of the future, if not altogether science fiction, have arrived and we are now in an age of algorithms, machine learning, artificial intelligence, and self-driving cars.

609 In this new digital era we have witnessed digital disruption. Many once-stable industries such as taxi companies, hotels, and retailers, have found themselves disrupted by ride-hailing apps, crowd-sourcing accommodations, and online shopping. There is evidence that other longstanding industries such as banks and financial institutions may themselves be disrupted in the near future as emerging distributed ledger technologies evolve, and enable transactions and validation outside of these established banking institutions. Because of these technologies, the world is quickly changing, as are the behaviours of consumers and their expectations of services, as well as of government services.

610 There is no reason to believe that 9-1-1 will be immune from such disruptions. Electronics and wireless communications technologies have evolved at a far greater pace than 9-1-1 services. 9-1-1 services were built to be stable and reliable, and have to date been built around voice. As wireless has become more pervasive, 9-1-1 systems have adopted to enable location of wireless devices, but with limited accuracy.

611 As the public moves away from voice in favour of other communication technologies, 9-1-1 must redefine itself to continue to ensure it remains capable of supporting the public in the way that the public demands. 9-1-1 therefore needs to find a balance between the dependable infrastructure needed to offer continuous and reliable services, while enabling the agile development of new and emerging capabilities.

612 We find it impractical to think about enabling particular modalities such as SMS texting three to five years from now when we already know that SMS adoption is declining in favour of application-based real-time messaging. We don't know exactly what the future holds in terms of communications. We can be confident, however, that they will be built on the Internet Protocol, and thus our focus must be to build an IP-based platform that enables 9-1-1 to evolve quickly as technology changes, along with citizens expectations.

613 From its current analog networks, 9-1-1 has many opportunities to evolve into the digital era to improve public safety and emergency response for Canadians.

614 Next generation 9-1-1 is much more than a technology conversation so I'd like to highlight some examples of how new communications methods have aided in actual emergency events.

615 In the absence of being able to collect data and multi-media through 9-1-1, Calgary 9-1-1 has placed wireless-capable tablets on its operations floor to allow ECOs to collect data from citizens through email or text. We call this our “pre-NG9-1-1 solution”, which ensures that critical pieces of information are not missed due to the lack of infrastructure to capture them. We have had some successes from this implementation and I'd like to share just a couple of them with you.

616 The driver to implement our pre-NG9-1-1 solution largely came from this first example. A 9-1-1 caller witnessed people putting on masks and entering a bank. She reported seeing chains that she believed would be used to lock the doors. The call was entered for police dispatch, and after some time, a hold-up alarm is received from the bank. Minutes later, a call comes from inside the bank from a caller who states that they are being held hostage and have been put in a room away from the offenders. She states she had photos to share.

617 When this information becomes available, she is asked to email the pictures but can't figure out how to send an email and asks instead if she can text them. At the time, our center had no way of receiving those media through text so our quick-thinking ECO provides their personal cell phone number and receives the pictures. They are then shared with the Calgary Police Real Time Operations Centre which distributes them to responding officers. The information from the photos assisted police with identifying the suspects and clearing the hostages.

618 In another event, Calgary 9-1-1 was notified by Calgary Transit that a female passenger on a train platform was stabbing other passengers and cutting backpacks with a weapon. Transit had photos and videos of the assailant and were able to send us pictures from their surveillance system. These pictures were collected by 9-1-1 and distributed to police through their Real Time Operations Centre. In this case, the assailant was a female whose basic description could have matched dozens of other women in the area. But with the picture in hand, police were able to quickly locate and apprehend the assailant. Perhaps equally importantly, many innocent individuals in that area who otherwise may have matched the suspect's description were not touched or interrogated by police.

619 In another example, a citizen walking through a stairwell in a senior's residence noticed a suspicious package that had wires sticking out of it. Believing it to be a bomb, the citizen took a photo and called 9- 1-1. While we would never ask a citizen to take such a photo in this type of situation, in this case he already had it.

620 The citizen sent the photo to the ECO who again coordinated with the Police Real Time Operations Centre to send it out to the responding Tactical Team Bomb Unit. With the picture, responding members were able to identify prior to their arrival that this package was not in fact a bomb or a risk to building occupants. This information in this picture collected by 9-1-1, mitigated the difficult task of evacuating a four-storey building full of seniors. The bomb unit arrived on scene, inspected the package, and removed it without incident.

621 In the final example, a young teen was sitting near the back of a bus when a male sat down beside her and began touching her inappropriately. She was able to discretely dial 9-1-1 on her cell phone and quickly communicate that she was unable to speak. The emergency communications officer sent a text message to the caller who was able to now communicate what was occurring. She was able to provide a suspect description along with the bus information and its route.

622 A teenager texting appeared normal and the suspect was unaware that she had contacted 9-1-1. Police officers were able to meet the bus at a subsequent bus stop, move the child to safety, and apprehend the individual. This was a great example of an ECO utilizing the technology made available to them to help an individual who was in need of assistance and unable to safely communicate on the basic 9-1-1 network.

623 These are just a few examples and we have several others where the collection of non-voice data has had positive public safety outcomes. They also highlight that 9-1-1 works as part of a larger ecosystem where we share data amongst agencies to help citizens. While data collected from citizens may not be directly applicable to the ECO, the ECOs are at times uniquely positioned to collect this data.

624 PSAPs and their partner agencies, whether responding agencies, investigators, search and rescue organizations, healthcare or poison control, work closely together to provide services. This is why it is important that the capabilities of the ESInet are also available to downstream agencies such as secondary PSAPs and other partners.

625 Through an IP-enabled network there is an opportunity to improve existing services. As detailed in the written submission by E-Comm, there are challenges with the existing system around VoIP calls, Wi-Fi calls, alarm monitoring calls, and satellite calls, where critical seconds may be lost as information is transferred manually or verbally. Having a data-enabled network could allow for such information to flow automatically through the ESInet to the PSAPs, and this should be a priority for NG9-1-1.

626 Additionally, we do not support the regular use of a pre-PSAP Operator Service to assess and triage these types of calls to PSAPs, as this creates an unnecessary delay in getting accurate information to 9-1-1 and to responders. Through the ESInet, the location information and call details should be automatically routed to the correct PSAP to ensure the most efficient emergency response.

627 At this point I would like to speak directly about accessibility. Calgary 9-1-1 was the first PSAP in Alberta and second in Canada to roll out T9-1-1 for the deaf, hard of hearing and speech impaired community, or DHHSI. While the frequency that it is used is relatively low, when compared to other 9-1-1 calls, this was an important step for 9-1-1, for ensuring that this underserved community can now, like other Canadians, access emergency services when they need them.

628 We believe this came together because of a collaborative leadership effort by members of the deaf, hard of hearing, and speech impaired community, the CRTC, the ESWG, PSAPs, and telecommunications providers.

629 We feel that there are other underserved communities that could also benefit from this type of service. There are communities of people who are not DHHSI, but who run the risk of not being able to safely speak or contact 9-1-1, much like the teenager I spoke of a minute ago. In particular, we have unfortunately seen increases in domestic abuse cases in Calgary. We respectfully submit that certain individuals who are at high risk for domestic abuse should be able to register for T9-1-1 service, with a designated class of service like the DHHSI community, to alert PSAPs that this is a caller who may not be able to safely speak, and may need to communicate with 9-1-1 through text.

630 The infrastructure to support this service is already in place. Not offering this capability leaves underserved individuals with limited access to 9-1-1 services, in potentially violent and life threatening situations.

631 As we move forward we believe we need to continually leverage these next generation services in the best possible manner, to ensure access and safety for the greatest number of Canadians. This includes DHHSI Canadians, high risk domestic abuse victims, those who are both deaf and blind, and any other citizens who, for whatever disability or circumstance, cannot access 9-1-1

632 safely through regular channels. We therefore respectfully urge the CRTC, as an initial step, to consider prioritize enabling the existing T9-1-1 infrastructure to improve the safety of other vulnerable populations.

633 The next issue we would like to discuss is coordination and governance. We submit that 9-1-1 is a "wicket" problem, in the regard that no single body has the reach or authority to address the oversight, funding, and regulation for all aspects of the complex NG9-1-1 system.

634 With PSAPs and emergency services typically being municipal or provincial responsibilities, there is no single unifying body that has national oversight for PSAPs. There is no uniform mechanism for funding across the country, or for regulations to govern PSAPs at a national level. Calgary 9-1-1 fully supports the efforts of the Canadian NG9-1-1 Coalition of the Willing in forming a national coordinating body. Calgary 9-1-1 has been actively involved with the Coalition and in the development of its Vision 2020.

635 While The Coalition is an informal body, it has expert representatives from municipal and provincial governments, as well as national bodies. Through the Coalition, members of the 9-1-1 community can build consensus on the path to achieving a future state for 9-1-1. Through its Vision 2020 document, the Coalition has a set of strategic objectives for moving to NG9-1-1 by 2020. We believe this is achievable and that it should be aggressively pursued.

636 While the Coalition is not a binding regulatory body, it provides PSAPs with a mechanism to facilitate input into NG9-1-1 migration. And it provides a roadmap to initiate discussion with local funding authorities.

637 In Alberta we have been fortunate for the leadership of our Alberta Emergency Management Agency, which has established an Emergency 9-1-1 Act that has provided both a draft set of PSAP standards, as

638

639 well as a funding mechanism to help PSAPs move to NG9-1-1, through a wireless cell phone levy. This funding mechanism will complement other funding mechanisms which are also necessary for the provision of 9-1-1 and dispatch services, and will provide a regulatory framework for Alberta PSAPs in guiding their move towards NG9-1-1.

640 We believe that the work of the Alberta Emergency Management Agency can serve as a model for other provinces to follow, to both support and regulate PSAPs.

641 For telephone service providers, there is, of course, a binding regulatory body. We respectfully submit that the provision of the 9-1-1 network should continue to be provided by an ILEC, and that it continues to be under the regulatory oversight of the CRTC. This capability needs to be ubiquitous in Canada, as a public good, such that all communities have access, regardless of the of subscriber base in any particular area of the network providers.

642 While we do not have a particular opinion as to whether the new ESInet should be under the control of one or multiple entities, we do feel that the current model of ILEC controlled 9-1-1 networks works well. Whether there is a single ILEC across Canada, or the multiple ILECs as in the current model provisioning the ESInet, we would not want to see originating network providers interface directly with PSAP, as the current ILEC coordinating model is more efficient.

643

644 Whether we have a single or multiple incumbents provisioning the ESInet, we submit that a clear and national technical standards are critical for the network. To highlight this point, we note that in the provision of Incall Location Update services, one ILEC built out a new IP network, while another provided an interconnection tied to the existing Centrex system. This has created an inconsistency across Canada, as well as delays with implementing this functionality in some of the provinces. We believe we need a uniform provision of the ESInet across Canada, rather than multiple flavours of it.

645 We believe that the ESInet, as the foundation of the 9-1-1 network system, must remain under the regulatory control of the CRTC. This is too important and critical to be left to the free market. We respectfully submit that this is an urgent undertaking given the gap in capabilities of the current 9-1-1 network and citizen expectations. We believe that an ESInet should be test-ready within two years, and deployed with at least basic functionality by 2020. This basic functionality could include better location accuracy, ability to process data in-line with the system rather than through workarounds, and the ability to downstream to secondary PSAPs, responders, and other partner agencies.

646 From this basic platform, we can build additional capabilities in the future to keep pace with consumer demand. The network should have a high level of availability, path-diversity, and redundancy to ensure mission critical communications are not knocked out, when they are needed the most.

647 Whomever the provider is, we submit that they must be accountable for the availability, performance, security, and reliability of the ESInet. We believe that the provider should have the ability to recover costs fairly through a tariff or other funding mechanisms. We also believe that the provider should be accountable for the use of those funds. The provider should also be responsible to PSAPs through service level agreements that specify roles, capabilities, and performance standards for the ESInet.

648 For a period of time we acknowledge that providers will have to maintain both legacy and NG9-1-1 networks, though we do believe that the Commission should eventually limit this burden on ILECs for two reasons: one is to enable them to focus their efforts and investments on the performance, resilience, and reliability of next-generation network services. Tying up critical resources on legacy systems has the potential effect of delaying substantive achievements on next-generation networks.

649 Secondly, this will encourage PSAPs to make the changes to their own networks and infrastructure, and move away from their own legacy systems. While legacy systems may potentially be a backup solution for the new next-generation systems, we do not believe that legacy systems should exist for much more than another five years or so, or as reasonably required.

650 With technologies rapidly changing this will require a balance between two modes of technology capability, one mode being a stable, reliable, and secure base that focuses on reliability and known outcomes; mode 2 enabling agility and the ability to make system changes quickly, to test and deploy new capabilities quickly, and to keep up with advancements in consumer technologies.

651 The bottom line is that the next-generation network, or ESInet, needs to be a stable platform on which future capabilities can be deployed, and enable PSAPs and their partner agencies to improve the level of services provided as technologies continue to evolve, along with the expectations of citizens and responders.

652 Network infrastructure must be public safety grade. It must meet a higher standard of availability, resiliency, reliability, security, and survivability than non-mission-critical enterprise network infrastructure.

653 The ESInet will sit at the core of the NG9-1-1 backbone. However, we respectfully submit that this will be part of a much larger ecosystem, a network of networks. 9-1-1services do not operate in isolation in serving the community. Instead, we work collaboratively with responder agencies, health authorities, search and rescue organizations, and crisis lines, to name a few.

654 Similarly, alarm monitoring companies could link automatically with the ESInet to quickly push data feeds in line of information that is currently shared verbally and transcribed manually over the phone.

655 We respectfully ask the CRTC to provide clear direction with aggressive timelines to build an ESInet, and ask ILECs for the transition plans for enabling this new digital network.

656 At this time I would like to ask Commander Odney to finish up with our final remarks.

657 MR. ODNEY: Thank you Magni. In conclusion we ask the Commission to consider our key points.

658 First, 9-1-1 systems and services have not kept pace with modern communications technologies. There is, at present, a large gap between the capabilities of modern communications systems and the 9-1-1 network. We respectfully urge the Commission to aggressively regulate the development of an ESInet across Canada, such that it is operational by 2020.

659 The network providers should have this network to the PSAPs by this date to enable PSAPs to transition to next-generation capabilities.

660 We believe that the ESInet, as the foundation of the 9-1-1 network system, must remain under the regulatory control of the CRTC. This is too important and critical to be left to the free market. We respectfully submit that this is an urgent undertaking given the gap in capabilities of the current 9-1-1 network.

661 Whether this network is provided by the current ILECs or a single one, we submit that the network provider should be accountable to PSAPs through service-level agreements for the performance and availability of the system.

662 We believe that an ESInet should be test-ready within two years, and deployed with at least basic functionality by 2020. To encourage PSAPs to upgrade their systems, we submit that the CRTC direct the provision of this ESInet by the providers to the PSAPs by that time, and that legacy networks be decommissioned as soon as reasonably possible thereafter.

663 We respectfully submit that accessibility must be a priority. Underserved and vulnerable populations must have safe and reliable access to 9-1-1 services like all other Canadians.

664 We particularly respectfully urge the commission to look at enabling T9-1-1 services for high risk domestic abuse victims. And we also respectfully urge the Commission to look for ways to improve services to Canadians who are both deaf and blind, and other underserved communities.

665 Thank you for the opportunity to appear before you today to share with you our views and concerns. We look forward to working together to deliver the next generation of 9-1-1 services in Canada. And at this point, we welcome your questions.

666 THE CHAIRMAN: Thank you, both, for that presentation. I’ll put you in the hands of Commissioner Simpson.

667 COMMISSIONER SIMPSON: Welcome, Mr. Odney. Velkomið, Mr. Magnason.

668 I -- as the Chair had said earlier, we have quite a grocery list of questions to ask, but my strong suspicion is that you have answered many of the questions that I am about to ask.

669 So if I wander into an area that you have touched on, feel free to just answer with a simple yes or no or, “I’ve answered that already,” or feel free to take advantage of the opportunity to expand.

670 First off, to satisfy my own curiosity, how did you get a fire lit under all those that help you with your mandate and your funding to jump the hurdles that we seem to see other PSAPs struggling with to the extent that you’re able to not only talk the talk but walk the talk with how you’re operating your enterprise?

671 MR. MAGNASON: We’ve been very fortunate in Alberta largely just due to the leadership of the Alberta Emergency Management Agency which, a couple of years ago -- and I believe they’re going to speak tomorrow or the next day about their program; they could speak better to it -- to establish an Emergency 9-1-1 Act which, first of all, provides some standards and guidance with how PSAPs need to operationally manage their business.

672 But it also came with a levy, which is applied to cell phones, and that levy provides funds that are directly provided to the PSAPs through a grant program. And that has positioned us very well to be able to make the investments that we’re going to need to make to upgrade our systems to next-generation 9-1-1 systems. COMMISSIONER SIMPSON: M’hm.

673 MR. MAGNASON: Up until recently, we were also fortunate to live in a very healthy economy and so, you know, some of the things that we already had in play were funded. But as we move forward, we’re going to be looking at all sorts of different funding options to ensure that we not only build our initial infrastructure but we have the funding to, sort of, maintain it as the needs continue to evolve, because they will continue to evolve.

674 COMMISSIONER SIMPSON: Yeah, but even with the economic weight -- you know, heritage funds not excluded from that comment -- there still had to be a tremendous amount of political will that went into this. And I know it’s resulted in the Act and the funding model that is going to be talked about to us tomorrow but is this just the good old Albertan way of just getting on with it or is there something that we don’t know about?

675 MR. ODNEY: I would agree that’s part of it. I would also offer that there’s significant support from our corporation, the City of Calgary, at a political level as well an administration level. So in addition to the funds that provide us the means, there’s also a desire to ensure that we are providing the best public-safety model for our citizen and that tout that.

676 We recently did a survey and we beat the fire department by one percent because citizens said that 100 percent of the time that it is the most important service that services our citizens, 9-1-1. So the fire department scored 99 and we were quite proud of that.

677 So it’s a need for the citizens. Our stakeholders agencies, partner agencies want us to have a very effective system; and they can make good decisions with the best of information and that’s where our journey starts.

678 COMMISSIONER SIMPSON: I just have one more question of a broad nature before I did into my grocery list. When you went through the RFP process for getting prepped for next-generation, you referenced that you were using the i3 template to inform your RFP process. What else did you build into the criteria that we might want to hear about?

679 MR. MAGNASON: So we actually -- we spent about a year developing our RFP and we -- yeah, we definitely looked at some of the technical aspects that we needed to fulfill as part of the i3 Standard but we also reached out operationally to our responders and stakeholders. We had working sessions with our operations staff; asked them -- like, did some engagement and asked them, “What works well with the current system; what doesn’t work well; what kind of capabilities would you like to see?” and even looked at other areas where -- you know, downstream areas that are going to be impacted by the type of system we implement.

680 So, for example, looking at our information management strategy and business intelligence, we engaged those people to gather information about what types of things that they would need from the system in order to help us make more -- well, do better analysis and also move towards doing, sort of, more predictive analysis and predictive deployment.

681 COMMISSIONER SIMPSON: M’hm. When I was reading your written submission as the part one portion of this process, I sensed -- which, I think -- a certain amount of frustration that you -- that there was an undertone to a lot of being said. And I think more of it’s come out today -- that you really feel that our reach should exceed our grasp.

682 And I think a lot of what we’ve been seeing in other part one submissions -- in written submissions is that we have to keep the status quo, use it as a building block, and do, perhaps, less than what is technologically possible, which is where I was sensing some of your frustration.

683 But what I heard today was something quite different and, frankly, enjoyable for my ears, which was that you touched an awful lot on the sociology, the expectations of the one group that’s not here at this table, which is the caller.

684 And I was wondering if you could give me a bit of an insight as to why you felt it was important to look at their expectations rather than just the abilities of the existing system and why you think we should be taking that more into consideration as we go forward on our decision?

685 MR. ODNEY: I’m reminded of the engagement we did with the deaf and hard-of-hearing and speech-impaired community prior to the launch of T9-1-1. That group in Calgary quite literally came to visit us and said, “Why can I text my mother to get me help and I can’t text 9-1-1?” And it was a year, at least, before this initiative and we expressed that the challenges of the technology was not enabling that but we would be your voice and we would work towards that initiative. And that was a success story.

686 And so, like the examples we used today, this is a demand that is coming to us from our customers, from our callers.

687 COMMISSIONER SIMPSON: M’hm.

688 MR. ODNEY: The technology has advanced to the point where we’re feeling like we’re left behind to the point where my own staff, emergency communications officers, are grabbing their own personal devices they have in the centre and saying to the citizen, “Send it to me; I’ll send it to the police.” We need to have that as part of an integrated system.

689 I was privy to some of those examples and broke the rules and went that afternoon, literally, to the Apple Store and bought an iPad and an iPhone and said, “We need to do a now-generation 9-1-1 example and get this in place” and then do exactly what we’re doing today, work together as a collaborative effort to move this initiative forward so that any citizen across our country can receive that excellent service.

690 COMMISSIONER SIMPSON: Thank you. As a follow-on to that, you had also touched on an area that was of interest to me, and I’m sure the Commission as a whole, but it had to do with what I’ll call “third-party providers”. And this is in context to your reference to the Internet of Things.

691 One of the phenomena that we are experiencing in the use of IP networks is that devices are becoming -- monitoring devices are providing more benefits to users on a passive monitoring level. And I took particular note that you seem to not have issues with dealing with monitoring companies and other intermediaries of the sort that I was asking the Coalition of the Willing about earlier.

692 Could you give me your feelings about a scenario that I’ll paint for you now where EComms might find themselves working either collaboratively, or third-party providers might be replacing certain services of PSAPs where third-party providers using Internet of Things and Apps and the like start to encroach on the space as a value-added service?

693 I had used the example earlier of two-tier medical system approaches where those who can afford enhanced services will pay extra.

694 How in that kind of scenario -- you know, would you embrace that change? Would you have to adapt to it, or would you resist it?

695 MR. MAGNASON: I’m just trying to think of how I’m going to articulate this. I mean, ultimately our goal is to provide a system that has an architecture that enables us to gather as much relevant information as we need to effectively deploy the right responses to the right scene, or to the scene. I mean ultimately, you know, through the Internet of Things I think -- I guess if I’m understanding your question correctly, maybe you’re implying that maybe some people have just access to better smartphones or more sensors and in that case they may be providing us with more information than somebody who doesn’t.

696 COMMISSIONER SIMPSON: I think it goes back to the Chair’s question of are there trusted versus untrusted parties that should come into this sphere and a lot of them being technological value-added offerings to customers. Does that throw you a curve to the extent that you’d resist it or could you work with them?

697 MR. MAGNASON: I don’t resist it but I would just urge caution in that. So when you look at things like say a car monitoring company like an OnStar, as an example, I don’t think I’d be interested in having, you know, a vehicle directly connected to the PSAP.

698 COMMISSIONER SIMPSON: Yeah.

699 MR. MAGNASON: You know, I think there’s a lot of value in that case of the alarm monitoring company -- in this example that I’m using is OnStar -- evaluating what’s happening in that vehicle. And I think as Chris Kellett alluded to earlier, only about one percent of those actually get triaged to PSAPs. And likewise, I don’t think PSAPs are looking at getting into the alarm monitoring business.

700 With that said, if we’re working with those trusted providers and they’re doing their due diligence to ensure that the things -- the information coming our way is likely actually an emergency event.

701 COMMISSIONER SIMPSON: I guess why I mention the question is that if you look at how this type of App-driven model is disrupting -- you used the example of the banking industry -- where there’s efficacy in the banking industry and there’s trust, and there’s regulation and there’s insurance and guarantees. If all of a sudden it’s more convenient to ship money via an App but there isn’t the protection that goes along with it, that goes back to your point earlier about consumer expectation.

702 MR. MAGNASON: Yeah. I mean, I think in the banking example actually through the sort of distributed ledger technologies that I alluded to which are called block chains -- Bitcoin is an example of a block chain.

703 COMMISSIONER SIMPSON: Yeah.

704 MR. MAGNASON: There actually is that validation, and that’s actually why it can disrupt that banking industry. I think with respect to 9-1-1, I think we would still need to have some sort of validation that, you know, this is indeed a valid event. We need to make sure that the Apps that are being developed are adhering to standards and that there’s some way to ensure that, you know, A) they provide us with quality information and that it’s relevant information, and that it’s valid, that it’s an actual, you know, emergency event.

705 COMMISSIONER SIMPSON: It’s like autonomous cars; proceed with caution, right?

706 MR. MAGNASON: Yeah.

707 COMMISSIONER SIMPSON: Yeah. I’m going to dip into the grocery list of questions here. And again, if they overlap to your testimony just let me know.

708 One of the models we’re looking at, you know, the consortium model has been talked to by various groups, and you seem to generally support the principle of a coalition. And there’s models, there’s the single model and the multiple provider model.

709 Could you give us a very distinct idea as to whether one model is preferred over the other, or are there pitfalls with a multiple provider model? What challenges would this kind of a coalition model present to you?

710 MR. MAGNASON: When you speak of the multiple provider model you mean of the ESInet or ---

711 COMMISSIONER SIMPSON: Yeah, multiple provider into, you know, managed by coalition.

712 MR. MAGNASON: I mean, I don’t know that I necessarily have an opinion one way or another that, you know, is adamantly one way or another. I think what is important is that we have consistency across Canada so that the services are ubiquitous and the same.

713 You know, if you leave Ontario and you come to Alberta just, you know, much like if you walk into a McDonalds in Tokyo or London or Calgary the Big Mac is going to taste the same. And to some extent anyways, you should have a similar experience across Canada with contacting and working with 9-1-1.

714 COMMISSIONER SIMPSON: So really either model doesn’t present negative issues to you but the consistency has to be with both?

715 MR. MAGNASON: Well, I think there’s pros and cons to each so I mean I think having one model allows us to, for example, work with one provider to do things once. I mean, I think as it was alluded to earlier, having multiple providers means that infrastructure needs to be updated or upgraded in multiple places.

716 And what we’ve seen in recent history is that sometimes it’s done slightly differently, which kind of creates inconsistencies across the country. And so from that perspective, I think the one provider model actually might be desirable.

717 There might be benefits to redundancy having multiple providers, and maybe some of those providers can provide redundancy to one another. But then again, I mean, I think with a properly architected system a single provider could provide, you know, path diverse and geo-redundant services to ensure the reliability and resilience of these networks.

718 COMMISSIONER SIMPSON: But it really is down to the strength of the mandate of the coalition that that would happen.

719 What would happen, in your mind, if you get yourself settled in to that provider -- again, whether it’s a multiple provider or a single provider -- and let’s say that the coalition should deem that they have to change horses in mid-stream. What would that do to you guys with respect to having to adapt to a change of provider either mid-term or even at the end of term?

720 MR. MAGNASON: I mean theoretically, if we’ve architected our own systems and if we’ve followed sort of I guess an i3 standard and approach, then there shouldn’t be a great deal of difficulty in transitioning to a different provider.

721 COMMISSIONER SIMPSON: Okay. You’re going through your own RFP. Is the RFP process the right way to go as far as selection of a provider? Is there another way?

722 MR. MAGNASON: I don’t know what other alternatives we have.

723 COMMISSIONER SIMPSON: Yeah.

724 MR. MAGNASON: So yes, yeah.

725 COMMISSIONER SIMPSON: Again, and surely the strength of the RFP and not the strength of the reply, I guess.

726 MR. MAGNASON: So in this case I mean we went to RFP for our own telephone system that would ultimately connect to, you know, the network, the 9-1-1 network.

727 COMMISSIONER SIMPSON: Yeah.

728 MR. MAGNASON: And we wanted to have our own system. I mean, currently we’re using a Centrex system that’s provided by the ILEC and that has been a very strong stable and resilient system for many years. I’m actually not aware of any outages of the voice services on that system ever. At least to my knowledge.

729 But there’s limitations to it in the sense that we don’t really have full control of that system when we need to make changes say to telephone queues. We don’t have that agility in our centre. Having your own telephone system just operationally provides us with a lot more agility in how we manage our staff on a day-to-day basis and in responding to major events.

730 We sometimes -- we had an event that we called “Snowtember” a couple of years ago where we had a big snow storm in September that just with heavy snow caused a lot of trees and power lines to fall and it was a very fire-intensive day. And other events like the Red Mile if the Calgary Flames ever make it to the playoffs again are more of a police-intensive type of event. And we need to be able to position our resources in a way to sort of manage those dynamic situations. But we can’t do that today with the current telephone system.

731 COMMISSIONER SIMPSON: Yeah, yeah. Just moving into what I guess is back into the trusted entities question that I had asked but it was specific to, sort of, third-party software app-developer-type services. On the issue of who currently can come into the 9-1-1 network now, which are, you know, PSAPs and CLECs and wireless carriers, are there any other what you would consider to be trusted parties that should be allowed into this framework that currently are not?

732 MR. MAGNASON: I think we currently word with a number of trust parties that aren’t really considered part of the 9-1-1 system. So you know, our emergency management agencies; we work closely sometimes with, you know, federal park wardens; and search and rescue; health authorities; poison control centres. I think those are some examples of trusted authorities that we might want to be able to get information to and from.

733 COMMISSIONER SIMPSON: M’hm. And when it comes to the language or the thought process of who should be eligible to qualify that aren’t on the present standards, you know, what do you think would be the criteria that would make a party eligible to come into the network? I’m thinking again along the language side.

734 I’m not trying to get into regulatory law with you, but you’ve said yes, there are trusted parties out there that you’re working with that aren’t necessarily part of the normal cast of characters. But what would the Coalition be looking at in terms of embracing other -- if you were sitting isolated from what you know about who you’re working with, how would you reflect who these characters might be?

735 MR. MAGNASON: Yeah, I mean, location services. I think, I mean, ultimately I think we’d have to just maybe take a step back and evaluate what the value is of each of these. I mean, what’s the outcome that we’re going to see from enabling certain types of parties from, you know, having access to this network and sharing it with 9-1-1?

736 COMMISSIONER SIMPSON: Yeah.

737 MR. MAGNASON: If there’s business value, if it could save lives ---

738 COMMISSIONER SIMPSON: I think where this question is coming from -- and I apologize if it’s causing you to struggle a bit, because it is a bit of an open-ended question -- but I think what we’re trying to get our head around is the present municipal, provincial, federal entities, governmentally and service-provision-wise, coupled with technological industries like the telephony business, are all pretty much set in their ways. And we hear a lot of reference -- and I saw that, again, in your submission, with a little bit of frustration, that the status quo is not good enough anymore.

739 And I guess what we’re trying to understand is if we were to try and design the criteria for a next-generation network, how much further into innovation should we be trying to get to that is not extreme and promotes instability or unreliability of the network? You know, because you had referenced in your written submission that, you know, you’re working with groups like that now. And I’m trying to understand, you know, just how far we should be going in trying to embrace new methodology, location services being one of them, in the criteria for the RFP?

740 MR. MAGNASON: I think the way I would answer is that, I mean, I think first and foremost, like we said, you know, before getting sort of too into the weeds of exactly what functionality, what information that we’re going to enable on the network, we’re really just -- maybe need to just quickly focus on building that network, creating that, sort of, digital platform that allows us, you know, once we have it, to start evaluating different modalities and different partners from coming onto the system.

741 To be honest, I just don’t know that I have a very, sort of, concise answer today. But I think if we had the platform to build on in the future, then perhaps, you know, groups like the Coalition or the ESWG could sort of work collaboratively to identify.

742 COMMISSIONER SIMPSON: Well, let me help you out here and then you can help me out at the same time.

743 Would it be possible to ask you if there is anything you think of that would inform us on this subject, to do it as an undertaking, the idea being that it would give you a chance to catch your breath, put some thoughts together -- given the innovations that you’ve already exhibited to us that you’re undertaking -- and submit it to the Commission in writing? There’s always a cut-off date.

744 Do we know what it is, Mr. Chair?

745 THE CHAIRMAN: Yes, we do. For some reason we have a limited number of mics today. The 24^th of January. That’s okay? Yes?

746 MR. MAGNASON: Yeah.

747 THE CHAIRMAN: You can meet that deadline?

748 MR. MAGNASON: Absolutely, yeah. No, and we’d be pleased to.

749 UNDERTAKING

750 COMMISSIONER SIMPSON: And it’s with the idea of trying to understand how we can establish some criteria that would embrace going a little further than the status quo on the next-generation design. Thank you.

751 Have you read any of the submissions from the United States or Australia that were submitted to this process?

752 MR. MAGNASON: I have not.

753 COMMISSIONER SIMPSON: Okay. It’s on the public record. You might want to because you’ll see as Australia is prone to do, they’ve got an entirely different way of doing things and it may give you some ideas. But anyway, moving on.

754 Now, it’s been said that, you know, statutorily, I suppose, that network providers are currently required to take all reasonable measures to ensure that their networks are reliable and resilient to the maximum extent feasible. Now, could you give me your view on this criteria in terms of how it would apply to next generation?

755 The background of this question is largely that under present 9-1-1 network technological criteria, an awful lot of it is captured within the realm of what we know how to do, both at the ILEC-provider standpoint and at your standpoint. Next generation challenges us all to adopt some new technology, new methods of communication.

756 So what is your view with respect to this next-generation network having some vulnerability because of new technologies and communication processes? Can you give me an idea?

757 MR. MAGNASON: Yeah. I mean, I think, as we mentioned earlier, some of these capabilities that we’re talking about in next-generation 9-1-1, they already exist; this isn’t leading-edge technologies that we’re implementing. We’re just kind of bringing them into the realm of 9-1-1. You know, like Doug alluded to earlier, there’s things that -- I always use the example of my son can talk to his grandmother in FaceTime and share videos, but he can’t do that with 9-1-1.

758 I think the networks -- similar types of networks exist already and similar types of capabilities exist already. They just don’t happen to exist on the 9-1-1 network today.

759 MR. ODNEY: I would add we work in a mission-critical environment and our partners that work with us understand that. And so ahead of, and not after, we always want to ensure that we have that very resilient approach. And the question is always, “What if? What if we need a backup? And is there a fail-over? And is it a hot fail-over so it’s seamless and the network doesn’t experience it but an IT technician knows about it and you correct it?”

760 The hard copper, old system, when the backhoe hits it it’s done until they can make that repair.

761 In our floods in 2013 we had a voice-over internet protocol radio system that was in Banff. A flood took out one of the IP lines and within minutes the company identified that and rerouted and reconnected it by coming through the B.C. side, British Columbia side. That was a perfect example of how the network has the potential to be very resilient. And our partner agencies that understand, when we work with them, it needs to be mission-critical, needs that high-up time. That’s the design that we build and it should always have that backup capability.

762 COMMISSIONER SIMPSON: On the same subject but moving over to monitoring and reporting, one of the criteria we have right now of a 9-1-1 network is a reporting responsibility so that we understand network outages, how many are happening, why they’re occurring, largely to inform how to prevent them in the future.

763 The NG networks are going to have issues that are outside, again, the capture of what -- of how things are normally done now, which, frankly, makes it easier for a 9-1-1 network operator to report on, because so much is captured within what they control.

764 So the first part of the question is, do you see these reports and do you find them of interest, given that the backhoe is always the enemy of the networks?

765 And the second part of the question is, do you think that this kind of reporting should be part of the mandate of the Coalition so that future networks have that same responsibility to report?

766 MR. ODNEY: Absolutely. We do look at those reports. We're continually monitoring our systems.

767 COMMISSIONER SIMPSON: Yeah.

768 MR. ODNEY: When we see issues and identify what the root cause is, that becomes a lessons-learned process, and it makes the system stronger as we go forward. And as we look forward to the future, as we build this, in essence, from scratch and make it a national offering, we have to have the ability within the industry to know what exactly it looks like, what our lessons learned are, and as we move forward, it builds a stronger system.

769 Even in our recent RFP with our IP telephone system, there were industry stories of some of the IP phone providers that moved into some of the States and had hour-long outages and day-long outages, and of course, when we hear what those causes are, those form part of the questions of our RFP to make sure that that's been identified and will not occur in a new product that we're looking at.

770 COMMISSIONER SIMPSON: Okay. And again, just to be clear for the record, you do feel that there should be the same rigour of reporting, even if it involves secondary suppliers to this new network having to come into the reporting and monitoring process?

771 MR. ODNEY: Agreed.

772 COMMISSIONER SIMPSON: Okay, good. Given -- I'm going to move into PSAP operations, and given that you guys are getting well down the road on the model of how to do things, there are going to be PSAPs, secondary PSAPs that just would love to be where you are but can't be. And the question I've got, first off, is, as we get into the belly of next-generation 9-1-1, there are going to be PSAPs that just can't quite keep up with the parade. And I was wondering if you can give me your views on both how they would be able to keep up with the abilities of the network using gateways, and whether, in the secondary PSAP working -- well, working with the network -- whether there should be a cost recovery to those who have to compensate for the availability of the secondary PSAPs, to put a question?

773 MR. ODNEY: Yeah, so our experience as a tri-service dispatch centre is that we can answer the 9-1-1 call and we can implement a system where police, fire, and EMS in that secondary system is all experiencing the value of that one system. We are moving to an environment in Alberta where, in essence, provincially, our Alberta Health Services EMS system is, in essence, a secondary, and when we look at how that affects potential response to citizens, whether it be police, fire, or EMS, we're always taking a collaborative approach to share with our partner agencies and secondary PSAPs and look for opportunities to partner, not only with our knowledge, but look at economies of scale to see if there's partner opportunities to get on the same system.

774 We're fortunate with the same CAD system in Alberta with a vendor that's providing our CAD system through a lot of agencies in the province, and we collaborate and we can find efficiencies with value for money and sharing between agencies. It always does come down to the dollar, and what agencies, municipalities, are able to do, based on their funding opportunities.

775 We predicted a number of years ago that with the movement of AHS, EMS dispatch out of some of our smaller PSAPs, that some of those smaller PSAPs would have to shut down. A smaller number did because of the wireless fees that came into place and helped keep them in operation. But as we face this future of NG9-1-1, we know and hear that there will be challenges around what does it look like for the small, medium, and large to all participate on the same endeavour? And our approach would be, how can we service citizens by doing a collaborative effort to make sure that if you live in Airdrie or Strathmore or Calgary, you can receive that same level of service?

776 It may ultimately require some small PSAPs to collapse, and we may experience some regionalization, where the large organizations will have to use the capabilities that they have to serve a larger geographical area. That may come in the future, but our starting point is to make sure that we're sharing our knowledge and our infrastructure as an industry and providing value to all of our citizens.

777 COMMISSIONER SIMPSON: Thank you. My next question was going to be on the issue of who should be responsible for the -- for those costs of the secondary PSAPs, but I think you sort of answered that.

778 I guess I'd like to go to the issue of funding, just in general. There's been talk of a need for national fund, but we know that for the most part, funding of PSAPs is done at the provincial level.

779 My question is, when it comes to the provisioning of 9-1-1 services -- I'm talking the physical assets: trucks, fire halls, police stations, and bodies -- when the -- is there a topping-up fund now that comes from any -- that you're aware of within Alberta or any other province that helps municipalities cover the basic costs of basic services?

780 MR. ODNEY: WE have some grant opportunities. Our wireless levy is a perfect example. But we have some very strict criteria that that must be used on the PSAP side, on the 9-1-1 call answer side, so we can't do the shell game of moving some funds around police and secondary PSAP initiatives. So we have to be wary of the fact that there's only so much dollars to go around where we have opportunities to make sure that funds such as our wireless levy is used specifically for PSAP.

781 COMMISSIONER SIMPSON: Yeah.

782 MR. ODNEY: Because it's fairly new, since 2014, that has afforded us the opportunity to take some of those other funds that were directed to the PSAP, redirect those, and then provide the funds specifically to the PSAP. But not all the agencies are able to do that ---

783 COMMISSIONER SIMPSON: Yeah.

784 MR. ODNEY: --- based on their size, so other than a minimal number of grants, it truly has turned out, in our history, to be a municipal responsibility.

785 COMMISSIONER SIMPSON: So going back to your example earlier, if a PSAP finds that it can't get to the next level of the game because it's just not functionally or economically possible and collapses and you pick up the slack, how does the funding for that work? You know, does Airdrie get off the hook and Calgarians are on it now? How does it work?

786 MR. ODNEY: So the starting point is the landline fees that still are applicable for that geographical area. The wireless fees would now apply for that geographical area. But as you ---

787 COMMISSIONER SIMPSON: Is that enough?

788 MR. ODNEY: No, is the answer. And so when you look at whether those fees are coming in, is it enough to support that, we're always looking for efficiencies to compare whether or not the intake of the geographical area comes with the necessary funding, and if it doesn’t, then we're always leery to make sure that we're not bringing in too much work ---

789 COMMISSIONER SIMPSON: Yeah.

790 MR. ODNEY: --- that we can't service properly. And I think other PSAPs have that same ---

791 COMMISSIONER SIMPSON: So as you were going through your RFP exercise, the individuals that were crunching the numbers, did they come to any revelations about costs of next-generation compared to levies currently and see that there's a gap there? And if so, did they tell you or do you know how much?

792 MR. ODNEY: We know there is a gap, and it's significant, but we're committed to the endeavour and we will be watching it closely. We have a 10-year strategic plan that we're looking at to make sure that we're looking far into the future, but it's a fair statement. We know that it's a significant gap at this point.

793 COMMISSIONER SIMPSON: I'm running up the clock here, so I'm going to step up the pace. It's my fault.

794 Awareness, now when you roll out your -- this network that you're building, who's going to take the reins with respect to telling the public that it exists? What's going -- who's the body that's going to be doing the awareness?

795 MR. ODNEY: So as a city department, we do have public engagement, public communication through media and through our public affairs. I think our starting point though, with next-gen 9-1-1, is the public should experience that to be seamless. There should be no negative impact of degradation of service, but we should be touting the benefits.

796 And just like we launched the T9-1-1 initiative and encouraged with all of our partner agencies the necessity for those individuals to register their devices in advance, that was a public education campaign that was very positive. And we continue to message that.

797 When we get the specific dates, times, and the roll-out of what exactly it’s going to look like for citizens, I believe that we need to take part in not only a municipal but a provincial and ultimately a federal public education campaign to let the citizens know that we’ve heard them loud and clear and we’re making moves towards providing them the services that they’ve come to expect.

798 COMMISSIONER SIMPSON: And just out of curiosity because you touched on it, how far do you think you’re going to be into the operational aspect of the next-gen before you want to talk about it and let everybody know it exists?

799 MR. ODNEY: We’d like to communicate now. I call it the NG9-1-1 is now-generation 9-1-1. We’re doing things right now that exists.

800 And as we come up with these significant projects around IP telephone launches, and enhancements to our CAD system and integrating all of those components, we’re certainly looking to make sure that our stakeholder agencies -- police, fire, and EMS -- know about the work that we’re doing.

801 COMMISSIONER SIMPSON: Yeah.

802 MR. ODNEY: But certainly pushing that out to the public on an ongoing basis.

803 COMMISSIONER SIMPSON: Thank you.

804 Moving on to alternate methods of communications. I’m thinking Text here. You were pretty eloquent about your position on Text, but I just want to make sure I’ve got for the record a couple of things. Yes and no answers will also suffice.

805 Do you support RTT right now?

806 MR. ODNEY: No.

807 COMMISSIONER SIMPSON: Okay. And why?

808 MR. ODNEY: Why?

809 MR. MAGNASON: Yeah, why. It’s like when you say real-time text, I mean, we have -- the only texting capabilities we have today are basically through the text with the ---

810 COMMISSIONER SIMPSON: Yeah. Well, it’s just there’s so many different formats. There’s SMS and OTT, you know, lots of different ways text is handled in the telephony world and IP world, and I was just wondering if -- because RTT just seems to be something that’s just hanging there and won’t go away. But I’m just trying to get an idea as an advanced PSAP whether it’s still part of your vocabulary or not?

811 MR. MAGNASON: It’s part of our vocabulary but I’m not aware of how that would come through the 9-1-1 network at this point.

812 COMMISSIONER SIMPSON: Okay. With text in general, you know, alluding to the various formats that I’ve talked about, as you are looking at text content coming into your centres, are you discriminating between the formats or are you going to support certain formats and not support others? Again, because there’s so many different ways that text can be transmitted format-wise. I’m referencing SMS and RTT and potentially OTT. You know, that’s why I’m a little curious or surprised that, you know, you’re not supporting RTT right now.

813 MR. MAGNASON: So I mean, yeah, at the moment we have like we said what we call now our NG9-1-1 solution which is just Wi-Fi and LTE-enabled tablet.

814 COMMISSIONER SIMPSON: Yeah.

815 MR. MAGNASON: And otherwise, we have the infrastructure that was put in place, the aging 501 system for the deaf, hard of hearing, and speech-impaired community.

816 But through the 9-1-1 system, I’m not aware of another way to communicate through text.

817 COMMISSIONER SIMPSON: Yeah.

818 Could you just refresh my memory again as to when your rollout is going to happen on Text-to-9-1-1, or is it happening now?

819 MR. MAGNASON: For the deaf and hard of hearing community?

820 COMMISSIONER SIMPSON: I’m sorry?

821 MR. ODNEY: IP phone.

822 MR. MAGNASON: Oh, for the IP phones?

823 COMMISSIONER SIMPSON: Yeah.

824 MR. MAGNASON: I mean, our IP phone implementation will be -- we’re currently planning for Q2 of 2018.

825 COMMISSIONER SIMPSON: Okay.

826 MR. MAGNASON: However, in order to actually do text with 9-1-1 we’re going to need for some changes to be made on the 9-1-1 network obviously.

827 COMMISSIONER SIMPSON: Okay. Onto other forms of communication. You’ve been very clear about your support of advanced technology. Do you have your own App or are you planning on building one?

828 MR. MAGNASON: We do not. We have no imminent plans to build our own App. I mean, I think we ---

829 COMMISSIONER SIMPSON: Have you looked at it?

830 MR. MAGNASON: I think we would prefer that there would -- I mean, for a municipality to build its own App I think would create sort of an inconsistency, right. It doesn’t create that national brand, that national capability that I think would be the ultimate best solution.

831 COMMISSIONER SIMPSON: Okay. Yet Apps seem to be a reality with that consumer expectation you talked about earlier. So are you -- I had asked you this initially but I think I’ll rephrase it to ask it this way.

832 If Apps are potentially a reality that you have to embrace, are there safeguards or issues of concern that you’re aware of that you could also inform this Commission about?

833 MR. MAGNASON: Well, I think first off ---

834 COMMISSIONER SIMPSON: Operationally or otherwise.

835 MR. MAGNASON: First and foremost I think we need to be aware of sort of the cyber security risks of Apps and what type of, you know, malware could be introduced into the 9-1-1 system. Sorry, just off the top of my head I can’t think of any other major risks.

836 COMMISSIONER SIMPSON: Yeah.

837 MR. MAGNASON: Other than just, you know, introducing -- like to your earlier questions, introducing something in Calgary that isn’t necessarily consistent across the country I could see as a risk. Somebody might download the App thinking that when they travel to Regina they can get the same service. And if it’s ---

838 COMMISSIONER SIMPSON: Well, but perhaps again thinking of the undertaking route, you’re very much a proponent of embracing as many technologies as the consumer -- perhaps this is overstating it -- as the consumer would choose to try and employ, but you’re also cautionarily not wanting to get into your own App.

839 Could you, if you choose to, give us some insight as to what safeguards or criteria you would apply should you all of a sudden find yourself in this new-generation 9-1-1 world starting to get pushed by third-party providers who want to introduce security Apps or monitoring Apps? What would be your best advice to us that you would be looking for before you’d embrace them?

840 And you don’t have to answer that now, but given that you guys have really stepped up on the technology side, embracing it, I’m challenging you back to give us some ideas as to where the cautionary issues are with respect to Apps in particular.

841 MR. MAGNASON: Yeah.

842 COMMISSIONER SIMPSON: And if you could do that, or answer now; it’s your choice.

843 MR. MAGNASON: That’s a great question. And actually, I think if we could articulate that in our written response that would give us ---

844 COMMISSIONER SIMPSON: Great. Same deadline as before.

845 MR. MAGNASON: Yeah.

846 UNDERTAKING

847 COMMISSIONER SIMPSON: And that pretty much takes care of my next question.

848 The last area I want to ask about is data capture. Now, you know, we’ve heard I think in the majority that PSAPs and working groups are saying, you know, data is nice but don’t give it to us unless we ask for it. And otherwise we have to capture it, we have to handle it, you know, there’s all the onus and responsibilities of, “I told you. I sent you pictures.”

849 Now you’ve come out and said, you know, “We’re willing to innovate and we’re willing to take whatever is given because if it can aid us in response or understanding of the need for response in the way you want to respond we’ll take it.”

850 But with respect to data capture, management, storage, and privacy this very willing nature of yours to want to take all this stuff in even if it’s not asked for does it -- what are the downsides that it brings about with respect to management of the data, having to share it with other emergency organizations -- I’m thinking Coast Guard, which doesn’t necessarily apply so much to you guys in the Prairies -- but also in the area of privacy as well, both from the misuse or the unintentional use of private data that puts you guys at peril.

851 You know, does that enthusiasm bring with it some downfalls that you’ve thought about but you still feel the importance of that information, getting it whether it’s asked or not outweighs the responsibilities of getting it, holding it, keeping it, and managing it?

852 MR. MAGNASON: So just to -- actually, first of all, just to articulate our position on it. I mean, I don’t think our position is that we’re willing to just receive all sorts of data regardless of what it is. I mean, there absolutely is such thing as too much information.

853 I do, however, believe that our emergency communication officers sitting at a 9-1-1 desk are in a unique position to be able to capture all sorts of different types of data, some of which may be relevant to them, some of which may not. I mean, somebody may send a picture in that. It actually really has nothing to do with the response; it might actually be more valuable for an investigator.

854 And so, I mean, I would actually still urge caution in how we collect that data. I would suggest that actually rather than us being inundated with data -- I mean I think it’s great if there’s partner agencies that have access to our network that have data to offer but we would still only, I guess, retrieve or request that data if we felt that it was relevant or necessary.

855 So for example, I think somebody talked earlier about health information. You know, if our CAD system perhaps, you know, gave us a little us a little flag that said, “There’s health information on this caller,” you know, we might link that to the call.

856 That again might -- that might be something relevant to us; we might be able to read it and decide that it needs a different type of response or maybe we even just alert the paramedics that the information’s there so that, as they’re responding, they can read that information and, you know, use that for their assessment when they get there.

857 Insofar as storage, I would only want to be responsible for storing data that we actually collected and used. I think a lot of the data might just actually sit there in a repository by whoever owns and manages that data in the first place.

858 Maybe because we come from a larger organization that has a fair amount of infrastructure in place for things like data storage, we’re maybe not as worried about the requirements to store some of this data.

859 COMMISSIONER SIMPSON: M’hm.

860 MR. ODNEY: I would offer we’re taking baby steps, I think, as we’re building towards this integrated completely connected NG9-1-1 system. And the baby steps in the sense that when those images or videos are offered to us, we have a means to collect those and gather them. And at this point we’re not scared of the amount of data.

861 And as a police dispatch agency, we’re very conscientious of security requirements; and as a AHS-EMS dispatch centre we’re concerned, as well, with the Health Information Act in compliance with health requirements.

862 But at this point we’re not concerned with the volume but certainly it is something that we’ll need to talk about when the complete system’s up and running, and what a purge level would look like. So data’s acquired; it’s not used; and what is the timing?

863 Our police agency uses 13 months. Within 13 months nothing was required, no court case, no evidence maintenance issue, and you can purge that; whereas other incidents that are clearly going to be requiring that data as we go forward, it can be archived appropriately and you can save some of the storage that way.

864 COMMISSIONER SIMPSON: With respect to the privacy side, which we just haven’t touched on -- and by the way, my apologies if I’ve misstated or misinterpreted your enthusiasm for technology with wanting to get pictures of Grandma’s dog and the like.

865 The issue of privacy, though, we have some prescribed requirements on privacy. Does this type of data, regardless of who’s capturing and holding it, require us to change or modify our privacy criteria for both the network and the PSAP -- well, for the network?

866 MR. ODNEY: I believe it needs to be updated, yes.

867 COMMISSIONER SIMPSON: Okay.

868 MR. ODNEY: We would -- we seem to get lots of questions around that and we get different answers. And so it will be incumbent on us all within the system to know what those privacy requirements are and ensure that we’re compliant on an ongoing basis.

869 COMMISSIONER SIMPSON: Still on this subject, your neighbours at Shaw had weighed in and said that TSPs or the NG9-1-1 operators should not be responsible for capturing and holding data but that it should it be the PSAPs. How do you feel about that? I mean it’s an obvious question but just for the record.

870 MR. ODNEY: Not surprised. And I think that’s a natural evolution of what our responsibility has been to date and that position doesn’t surprise us.

871 COMMISSIONER SIMPSON: But do you think it should be the responsibility of the operator -- the 9-1-1 operator?

872 MR. ODNEY: I think at this point, in the early stages, yes. And hopefully nothing’s final but it could be something that is a starting point and, if there’s issues with it, we could adapt, I believe.

873 COMMISSIONER SIMPSON: And just out of curiosity, would -- going back to network operational criteria, would that 9-1-1 operator, do you think -- should they have a responsibility for sharing that data when asked downstream to, again, other emergency organizations -- I’m thinking coast guard and the like -- if that’s -- if they’re asked for it, do you think they should have a responsibility to provide it?

874 MR. ODNEY: Yeah, I think we have a vetting process to make sure that bona fide requests for information are applicable and the agency has a valid right to that. There should be a sharing process through those agency pathways, absolutely.

875 COMMISSIONER SIMPSON: Last two questions. On transition -- again, I’m asking this because you guys are in the thick of it -- how long do you think there should be a parallel operation of the existing 9-1-1 network overlaying on top of the next-generation network until it can be furloughed or mothballed? Have you got any opinions on that?

876 MR. ODNEY: I would suggest just -- there has to be a balance. You’d have to look at it -- the time that would not put an undue burden on agencies to transition and force them to not transition appropriately. But when there is not end-sight, where is the loss of desire to actually get to that end-point? I think that’s the balance.

877 COMMISSIONER SIMPSON: My last question is on accessibility. And given, again, your go-forward plans, there’s been ample information provided so far on what the next-generation networks should be capable of offering in provision of services to the disability community but could you give us some insights as to some of the challenges that you’ve seen operating a PSAP that you’ve incorporated into your own planning?

878 MR. ODNEY: With respect ---

879 COMMISSIONER SIMPSON: I’m thinking specifically of how you’ve been able to address, manage, and operationalize the calls that have been coming in from disability callers.

880 MR. ODNEY: Sure. So the deaf, hard-of-hearing, speech-impaired community, once T9-1-1 went live ---

881 COMMISSIONER SIMPSON: Yeah.

882 MR. ODNEY: --- that was a success force in the sense that the service class was a trigger for us to know that that was a registered user. That was a balance, though, for the, what we call, “pocket dials”, the three to four hundred per day in a 24-hour period, which were no-voice activations of 9-1-1.

883 And as we move forward, we’ll want to make sure that there’s a trigger in place that allows us to identify immediately that this is a bona fide or a registered user, or from that community, and that we can engage and use the technology to answer their call and deal with their call appropriately.

884 COMMISSIONER SIMPSON: Have there been any issues, positive or negative, with respect to the video relay at this point?

885 MR. ODNEY: I’m sorry; I missed the last ---

886 COMMISSIONER SIMPSON: Video relay.

887 MR. ODNEY: Video relay? No.

888 COMMISSIONER SIMPSON: Video relay is something we’ve just ---

889 MR. MAGNASON: I don’t believe. Since the service have been offered, I’m not aware of any cases where we’ve used it.

890 COMMISSIONER SIMPSON: Well, it’s been around but it hasn’t been operational as much as -- it was something that came down as a decision in this Commission about a year ago and I was just wondering if you’ve had any experience at this point.

891 MR. MAGNASON: Yeah, I’m not aware of any experiences that we’ve had to date.

892 COMMISSIONER SIMPSON: Those are my questions. Thank you very much.

893 MR. MAGNASON: Thank you.

894 THE CHAIRMAN: Thank you. Just a few areas. Is pocket dialing still a big issue or is that in diminishing amounts now?

895 MR. MAGNASON: It is declining, for sure, but we still -- like Doug alluded to, at the peak we were getting three to four hundred a day. We’re still getting close to 200 a day.

896 THE CHAIRMAN: Per day?

897 MR. MAGNASON: Per day.

898 THE CHAIRMAN: That’s just in your territory?

899 MR. MAGNASON: Just in Calgary and the surrounding communities that we serve.

900 THE CHAIRMAN: And yet there’s easy strategies to prevent that?

901 MR. ODNEY: Yes, there are.

902 MR. MAGNASON: There are for the end-users, yes.

903 THE CHAIRMAN: Yeah, of course, and they just need to wake up and do it.

904 MR. MAGNASON: Correct.

905 THE CHAIRMAN: Well, hopefully the members of the media who are following this hearing could remind people that there are easy ways of preventing costly and ineffective pocket dialing that get in the way of real emergencies.

906 MR. MAGNASON: We would greatly appreciate that.

907 THE CHAIRMAN: Do you currently have a service-level agreement with Telus?

908 MR. MAGNASON: I’m aware of an agreement being in place that, to be honest, I’ve never seen. I think it was written many, many years ago. But I don’t believe that we have anything in place that actually specifically identifies the precise roles and responsibilities and the types of mitigating measures or how we can maybe, perhaps, escalate issues up through their system.

909 THE CHAIRMAN: So that’s why you’re advocating on a going-forward basis that SLAs be put in place?

910 MR. MAGNASON: I believe it would be very advantageous to have a very clear set of roles and responsibilities that identify who is responsible for which components of the system and for identifying maybe, you know, what’s reasonable in terms of, you know, the time it takes to mitigate issues or to make enhancements to the system.

911 THE CHAIRMAN: Do you think the Commission should mandate the presence of service-level agreements going forward?

912 MR. MAGNASON: I think that would be of value, yes.

913 THE CHAIRMAN: And how would we identify the content or the ideal content for such a service-level agreement?

914 MR. MAGNASON: I mean, I think that would perhaps be a good discussion point for a coordinating body.

915 THE CHAIRMAN: Right. Or CISC.

916 MR. MAGNASON: Or CISC, absolutely.

917 THE CHAIRMAN: Okay. But there is work to be done to create a model, in your view?

918 MR. MAGNASON: Absolutely.

919 THE CHAIRMAN: If we were to expand Text-to-9-1-1, the current system, to other vulnerable groups -- I think that’s what you were suggesting -- it requires the current model -- maybe not the going-forward model -- but the current model requires people to self-identify and register. How would we do that going forward? How would we define other vulnerable groups in the population for that self-identification and registration? What are you thinking about?

920 MR. ODNEY: In our example specifically with high-risk domestic abuse citizens, they are identified. They are working with social agencies that we’re aware of within our community. We would partner with those communities, with those agencies, and with their assistance have a public education campaign to identify that as a solution for those high-risk individuals and allow them to self-register and pre-register in advance of a known high-risk situation. And that would come with the information through the system for us to know subscriber information and know who the phone is assigned to and certainly give us that advance information to start a session with that individual and provide that service to that group.

921 THE CHAIRMAN: Is domestic violence the only example you were thinking of when you were thinking of expanding the current Text-to-9-1-1?

922 MR. ODNEY: We’d see it as value with the general population, the scenario of the citizen on the C-Train or the bus and an assault occurring and not wanting to pick up their phone and place a voice call to present themselves as a target, communicating to the general public. The challenge obviously in that scenario is they must pre-register in advance and start that trigger.

923 So I think as we look at the future of NG9-1-1 and see what some of the States are doing, dealing with the pocket dial specifically, automated opportunities to push text messages out to those pocket dials and start a session and let the public know that that’s -- you’ve activated 9-1-1, you’ve reached us, and that there’s other means to communicate with us, that would be an opportunity. But it would require a system approach and it would include a public education campaign.

924 THE CHAIRMAN: Right. So on taking the existing Text-to-9-1-1 and expanding it to more people, what would the barriers be, in your view, to getting that done? Or do you consider that we should do it as part of this transition to next-generation 9-1-1? I got the impression you were more keen to do it sooner and not wait for the larger next generation?

925 MR. ODNEY: Agree. Our request would be to enter into that early and start working towards that, see what the public response is. And with timing -- and you heard some of our requested timelines. I think we’d be in a position, then, to have our system integrated. We’re working in separate sessions right now on disparate computers to do that session and we’re transcribing information. But as we move forward -- and the vision is to have this completely integrated -- we believe we would have more capacity to enter into those sessions and gather information for those legitimate calls and provide that service that way.

926 THE CHAIRMAN: Is it your view that other PSAPs are less keen? Or are you more ready than some of your colleagues to using the current texting solution? Would there be reticence elsewhere?

927 MR. ODNEY: I think we’re pretty keen. But the industry communicates, I think, a lot amongst themselves. And we do lots of site visits and best-practice visits. And some people are a little quicker out of the gate and others a little bit more cautious. But I think as we get comfort as we move forward and we take a systems approach, I think we’ll have successes.

928 THE CHAIRMAN: If you’re already operating Text-to-9-1-1 for the deaf, the accessibility community, the marginal -- explain to me what other -- I mean, there will be greater volume, but are there any other considerations from a PSAP’s perspective that you need to worry about? Or is it just a variation on -- because you will just have more?

929 MR. ODNEY: More volume.

930 THE CHAIRMAN: Right.

931 MR. ODNEY: Yeah.

932 MR. MAGNASON: Maybe some training. I mean, we did a lot of very specific training around communicating with the deaf community, especially around people who are naturally deaf. There’s just different, you know, language and communication methods that you need to deploy even just with text. And I would suspect that perhaps with another vulnerable community like domestic abuse victims, we would just maybe just need to do some training, you know, with our staff to just alert them of the fact that these types of calls might be coming through and that they need to be more vigilant and, you know, watching for, say, perhaps a different class of service and, you know, ensuring that they initiate a text session other than just treating is a pocket dial if there’s no voice.

933 THE CHAIRMAN: Right. Would there be some wisdom in maybe trying in Calgary, for instance, to do a pilot project to see how it works and realize the impacts that we may not foresee at this time?

934 MR. MAGNASON: Yeah. We would be pleased to participate in a trial.

935 THE CHAIRMAN: Thank you. We don’t see as many epaulets as we’ve had today at our witness table so it’s a refreshing reality in this hearing. So thank you very much for having come to the hearing and continuing to participate in it. Thank you very much.

936 MR. ODNEY: Our pleasure. Thank you.

937 MR. MAGNASON: Thank you.

938 THE CHAIRMAN: So what I think we’ll do is we’ll hear the presentation from the next presenter and then we’ll take our mid-afternoon break after that.

939 So madam la secrétaire?

940 Ms. ROY: I would now ask Telus Communication Company to come to the presentation table.

941 Please introduce yourself and your colleagues and you have 20 minutes for your presentation.

PRESENTATION

942 MR. EDORA: Good afternoon, Mr. Chairman, Vice-Chair Menzies, and Commissioners. My name is Eric Edora. I am Director, Regulatory Affairs at TELUS.

943 I’m pleased to introduce the rest of the Telus panel.

944 Starting at my far left is Andy Brauer. He’s Manager of Products and Services. He’s our product manager of 9-1-1.

945 To my left is Orest Romaniuk. He’s Vice-President and Controller and he’s here to talk about funding issues related to next-generation 9-1-1.

946 To my immediate right is Jeff Smith, Senior Regulatory Advisor. He’s our regulatory prime for 9-1-1.

947 And to his right is Richard Polishak, TELUS Fellow, Technology Strategy. And he’s here to talk about all technical matters related to next-generation 9-1-1.

948 Every day, access to 9-1-1 saves lives. 9-1-1 is successful for two reasons. One, 9-1-1 is simple for the user. When there is an emergency, people know that they must “call 9-1-1”. This simple and easy to remember way to contact emergency services is a hallmark of the service.

949 Two, 9-1-1 is incredibly reliable. What many people do not know is that a 9-1-1 call is actually a series of communications links. It starts with an individual dialling 9-1-1, with the call carried by a wireless or wireline service provider. From there the call is sent to a core 9-1-1 network, operated by the serving ILEC in the area. That core network then sends the call to the serving PSAP, which is operated by a local government, and then onto the secondary answering point or SSAP for response by the first responders.

950 In the CRTC’s review last year of the ILEC core 9-1-1 networks, it was found that today’s 9-1-1 network providers have the willingness, capability, and expertise to design high quality 9-1-1 networks, and that those networks are both reliable and resilient.

951 Current 9-1-1 networks are predominantly based on circuit-switched technology. As with all telecommunications, 9-1-1 needs to transition to IP-based technology. TELUS supports this transition.

952 Next generation 9-1-1 service has the potential to dramatically change and enhance how Canadians access and communicate with emergency responders. However, this migration must be carefully planned to ensure that accessing 9-1-1 remains as simple and reliable as the services in place today. There are activities already underway at the CISC’s Emergency Services Working Group to examine issues related to next-generation 9-1-1.

953 Many parties have identified today’s 9-1-1 networks as “legacy.” In truth, today’s 9-1-1 networks are ever-changing. After the introduction of basic 9-1-1, which operated very similar to an operator services, 9-1-1 service became enhanced with the introduction of E9-1-1. Enhanced 9-1-1 provides automatic location information and direct routing to the serving PSAP.

954 More and more 9-1-1 calls are now being made on wireless devices. According to B.C.’s PSAP, largest PSAP, EComm, 65 percent of all 9-1-1 calls are now placed on wireless handsets. And we heard earlier from Calgary, it's 70 percent in their territory. With mobile services, a new problem had to be solved –- how to ensure that wireless calls are routed to the right PSAP and that location information is automatically delivered.

955 ILECs, wireless service providers, and PSAPs developed and implemented Phase I and Phase II wireless E9-1-1, which allowed for location information to be delivered to the PSAPs from wireless callers, no matter where they are in Canada.

956 More recent improvements to wireless E9-1-1 include Text with 9-1-1 for the deaf, hard-of-hearing, and speech impaired community, and in-call-location update, which updates the location of a wireless customer during a 9-1-1 call. The product of all of these enhancements means that Canada’s 9-1-1 services lead the world in terms of simplicity, reliability, and effectiveness. This was only made possible as a result of all of the stakeholders’ commitments to make 9-1-1 as good as it possibly could be. This commitment holds true for next-generation 9-1-1.

957 Today’s 9-1-1 networks are predicated on voice telephone calls. An IP-based 9-1-1 network will enable new forms of communications between Canadians and PSAPs. Two-way text messaging, communicating by way of social media, and the transmission of photos, videos, medical records and building schematics, among others, have all been raised as new potential 9-1-1 communications tools; however, any new communications tool gives rise to a set of questions:

958 One, which of these new tools do PSAPs find enhance public safety and therefore, should be supported by next-generation 9-1-1?

959 Two, when will the network be able to support such capabilities? These are important questions that should not be answered by the art of the possible.

960 In any event, it must be understood what can be accomplished in this proceeding. The CRTC’s jurisdiction is over the core of the 9-1-1 network, and ensuring that connectivity to that network is facilitated. Through that lens, the issues in this proceeding are the following:

961 Who is going to build the core next-generation 9-1-1 networks in Canada?

962 How will the capital and operational costs for the networks be recovered?

963 And three, what is the transition plan to next-generation 9-1-1? TELUS goes through these issues in turn.

964 Network reliability must be the primary factor when deciding who should build the next-generation 9-1-1 networks. In a proceeding last year, TELUS filed evidence that demonstrates that we, as a company, deliver a reliable and high-quality 9-1-1 network. Since 2010, TELUS’ 9-1-1 network has delivered almost 30 million calls with better than “6 nines” reliability. Whoever builds the next-generation 9-1-1 network has to meet or exceed this historical level of reliability. Canadians deserve nothing less.

965 ILECs who currently operate 9-1-1 core networks have invaluable network experience. They have developed tremendous working relationships with the PSAPs and SSAPs in their respective areas. These are the foundational elements upon which the next-generation 9-1-1 network should be built.

966 Next-generation 9-1-1 will be a capital-intensive project. First, the core network itself has to be built. In addition, IP connections will need to be built to connect the PSAPs and SSAPs to that network. These activities require engaging and collaborating with PSAPs, SSAPs, and equipment and software vendors, and then performing tests and re-tests on the entire network.

967 This is a complex and important undertaking and it must be considered to maintain and continue the support of the existing 9-1-1 network. It would be best to use the existing network providers that already have an intricate knowledge of the current 9-1-1 network and what a next-generation 9-1-1 network might require.

968 Orest?

969 MR. ROMANIUK: Thank you, Eric, and good afternoon.

970 The capital construct and operation of next-generation 9-1-1 networks requires funding. When it comes to funding of 9-1-1, those who benefit from these services should be the ones who pay for the service. The existence and availability of 9-1-1 equally benefits all Canadians.

971 Furthermore it is often the cause that those who are in distress are relying on others and their communication devices to initiate the 9-1-1 call. It is for these reasons that TELUS has proposed that funding for next-generation 9-1-1 networks be financed from general tax revenues to spread the cost of 9-1-1 networks over the entire taxation base. This is the most equitable manner in which next-generation 9-1-1 networks should be funded.

972 In the alternative, TELUS has proposed that funding for the next-generation 9-1-1 network be managed through the current process and methodology of the National Contribution Fund in that amounts that are collected by carriers from their voice and internet customers, and subsequently remitted to the National Contribution Fund. Those funds would then be disbursed to those incurring the costs to develop, build, and support the next-generation 9-1-1 network.

973 Again, the premise is to spread the cost of 9-1-1 networks across the vast majority of Canadians who benefit from this service and subsequently remit to those incurring the costs.

974 The critical element of this model is that customers who have access to next-generation 9-1-1 networks would pay into the National Contribution Fund as a product of network access. This would be collected from those customers and then remitted to the National Contribution Fund. It would then be distributed to the next-generation 9-1-1 network providers.

975 TELUS also asks that service providers be permitted the opportunity to itemize on their customers’ bills the amount that is being collected for next-generation 9-1-1. This ensures competitive neutrality and transparency.

976 Of course, the Commission could retain a tariff model to fund next-generation 9-1-1 networks. TELUS is not against use of a tariff, but the issue is that not all providers, such as the rapidly evolving access-independent VoIP segment, pay into the current regime and absent a change, they would continue to not contribute to the deployment of next-generation 9-1-1. This means that some customers get access to 9-1-1 without paying for this through the tariff.

977 On the question of expense, the Commission’s existing cost study review process would ensure just and reasonable rates. On the issue of transparency, the tariff itself identifies the specific amount that each connection pays for 9-1-1 services. This is a clear and itemized amount for provision of 9-1-1 services.

978 Richard?

979 MR. POLISHAK: Thank you, Orest, and good afternoon.

980 Once the Commission has selected the next-generation 9-1-1 network provider or providers, the next critical steps towards making next-generation 9-1-1 a reality for Canadians can begin. Leveraging industry bodies like the Alliance for Telecommunications Industry Society and the National Emergency Number Association, in conjunction with working within oversight of the CRTC’s CISC-working groups, a standard-based solution, optimized for Canada, can be developed.

981 Determining the ideal ESInet architecture to interconnect emergency service providers, and designing the next-generation 9-1-1 core infrastructure, will be the critical initial steps in building this foundation. This process will involve partnering with vendors who can provide the equipment that will form the core, software providers that will develop monitoring and reporting tools, working with carrier partners to design redundancies and develop call routing logic, and consulting with PSAPs and SSAPs to define call delivery.

982 The move to next-generation 9-1-1 requires transformational activities on the parts of both the next-generation service provider and the PSAP networks. Adoption by PSAPs is dependent on funding levels for each individual PSAP and the level of technological comfort and expertise available to that PSAP. Some PSAPs in TELUS’ operating territory, such as the City of Calgary and EComm, may have the resources and ability to adopt next-generation 9-1-1 more rapidly, while other PSAPS may take longer. Bell opined in its reply comments that PSAP migration might not be completed until 2028. TELUS considers that timeframe a reasonable estimate.

983 With respect to the build itself, TELUS envisions a three-stage approach.

984 In stage one, the next-generation infrastructure will be introduced but only a select number of PSAPs will be on the network. This phase will involve rigorous testing and optimization as networks and platforms are brought online for the first time.

985 The second phase will see call logic moved to the next-generation 9-1-1 core and a majority of PSAPs and SSAPs now interconnected via the ESINet. Some PSAPs will not yet be ready to migrate so the legacy network, with interfaces into the next-generation 9-1-1 core, will be maintained.

986 Finally, the third phase will see all legacy infrastructure removed and all PSAPs will be receiving their calls and information over the next-generation 9-1-1 network.

987 Eric?

988 MR. EDORA: Thank you, Richard.

989 On a final point, some parties have advocated for the creation of a national organization to manage next-generation 9-1-1 in Canada. However, there is no consensus as to what this national organization or consortium would do.

990 Rogers has suggested that the consortium be created to manage 9-1-1 budgets and disburse funding, carry out inspections, and perform investigations. Central to Rogers’ vision is managing interconnection requirements and interconnection rates for TSPs.

991 The Coalition of the Willing envisions a next-generation 9-1-1 consortium to coordinate municipal, provincial, and territorial fundings for the PSAPs and to keep up with emerging technologies.

992 PIAC proposes that the next-generation 9-1-1 administrator allocate funding collected directly from TSPs and oversee the national operator of the next-generation 9-1-1 network.

993 Though there is no single view as to what a national consortium or administrator would do, it is clear that it would do one thing. It would add bureaucracy -- another national administrator that would require its own governance and management. Moreover, there is potential conflict with the duties and jurisdictions of governments.

994 In contrast, there is already a central body that has jurisdiction over major 9-1-1 elements. That’s the CRTC. The CRTC’s own Emergency Services Working Group, as part of CISC, is the forum where different stakeholders representing TSPs, 9-1-1 network providers, PSAPs, and first responders meet and collaborate on different initiatives and 9-1-1 developments. This model has worked very well to date and there is no reason to develop an additional more complex form of administration.

995 The CRTC reviewing the Emergency Services Working Group output has proven very effective at evolving our emergency services from basic 9-1-1 to the robust and advanced system in place today. It will also be effective for the network that will be built for Canadians tomorrow.

996 Therefore, in conclusion, first, the Commission should determine that the core next-generation 9-1-1 networks should be built by the ILECs.

997 Second, the Commission should ensure that the next-generation 9-1-1 networks are efficiently and fairly funded by those who have access to and benefit from next-generation 9-1-1 service.

998 Third, next-generation 9-1-1 standards have yet to be fully ratified. Any timeline for the transition to next-generation 9-1-1 is dependent on the definition and availability of standards-based infrastructure, deployment by the next-generation 9-1-1 network providers, and the speed in which PSAPs and SSAPs are able to support the next-generation 9-1-1 requirements.

999 Finally, the Commission should discount calls by various parties to add another national organization or consortium. The ESWG and the CRTC already perform these functions very capably.

1000 This concludes our presentation. We are pleased to answer any questions that you may have.

1001 THE CHAIRMAN: Thank you, all.

1002 As I said before, we will take a break. But just before we do so, Mr. Edora, just so I understand, the TELUS Regulatory Department reports through Monique Mercier; is that correct?

1003 MR. EDORA: That’s correct?

1004 THE CHAIRMAN: And gentlemen, don’t take this as directed to you, but I find it quite surprising that this is the second time in a major telecom hearing that we face of a panel of a regulated important telecommunication company with a panel entirely made up of men. So my message to you, Mr. Edora, is one that I would like you to communicate to Madam Mercier. Perhaps she should review her online CV, which puts so much emphasis on what she has done for women in the business world and particularly the telecommunication world, where she can’t even send a single woman. I can’t believe that E9-1-1 is not delivered in your company without a single woman involved. I find that shocking. The 2016 Woman of the Year.

1005 We’re adjourned until 3:30.

--- Upon recessing at 3:08 p.m.

--- Upon resuming at 3:30 p.m.

1006 MS. ROY: Please take your seats.

1007 THE CHAIRMAN: A l’ordre s’il vous plaît. Order, please.

1008 Monsieur le vice-président, s’il vous plaît?

1009 COMMISSIONER MENZIES: Hi. I thought we’d start with your objection to the Coalition’s idea to have a coordinating entity above that.

1010 I understand that you might see it as an additional and unnecessary layer, but they seem to see it as temporary and something necessary, sort of like an injection of adrenaline, to move the process along, which -- this is not what they said, but you could see if there are PSAPs -- and there are many -- and there are governments that might be viewed by some to be less leading-edge or need a little bit of inspiration to move along, that having a coordinating body like that in the short-term, or so I believe the argument goes, is necessary to be able to get things moving.

1011 So why would you not share that view?

1012 MR. EDORA: Thank you for the question, Vice-Chair.

1013 Our objection, if you want to characterize it as such, isn’t to do with the coordination of next-generation 9-1-1. That obviously is an important function. Our position on that is that the CISC and the CRTC can already take on that coordination type of role in terms of implementation of the network and then that monitoring of that process and in addition finding out which PSAPs are actually ready for interconnection.

1014 The main issue we have with the Coalition of the Willing proposal is the way we read it had a lot to do with funding of the actual PSAPs. And to our view, that type of model does not work because the funding of the PSAPs is done by provincial and local governments. And so we weren’t sure from their proposal how a national consortium would gather monies for disbursement to the PSAPs for their own implementations. That seems to us to be a function for the local and provincial governments in terms of the allocation that they want to make to their 9-1-1 call centres.

1015 COMMISSIONER MENZIES: Okay. I understand that.

1016 Why is it, then, in your view, in the best interest of Canadians, the people who would be using, the people going, “Help! Help!” when things come up, to stick with the current model with the CRTC having sort of direct oversight over the ILECs, in terms of that.

1017 I mean, I get that in most cases the burden of proof belongs to those who are advocating change. You're not advocating for change in that sense, in terms of the current government's model of that, but I'm going to turn things around and ask you to explain why that our current government structure is in the best interests of Canadians as opposed to some of the new government structures proposed.

1018 MR. EDORA: As it pertains to a national administrator or coordinator?

1019 COMMISSIONER MENZIES: Yeah ---

1020 MR. EDORA: Is that what ---

1021 COMMISSIONER MENZIES: --- versus that national administrator. I mean, the CRTC having oversight over the ILECs as network operators, as network providers right now, that's the system we have right now ---

1022 MR. EDORA: Yes.

1023 COMMISSIONER MENZIES: --- which you are saying is fine?

1024 MR. EDORA: Yes.

1025 COMMISSIONER MENZIES: And what makes it superior? What -- how can Canadians be assured that that is the best way to keep on going?

1026 MR. EDORA: The -- well, I -- it starts with ---

1027 COMMISSIONER MENZIES: Well, just make it easier. Just -- is there one or two points that you could narrow in on and say, "We do this so well," that you really don’t want to risk changing it?

1028 MR. EDORA: I appreciate the question. What I want to zero in on is the fact that the 9-1-1 system, the telecommunication service that we provide as 9-1-1, is an integral part of public safety, and the way that the service has developed over the past 40 years has been through the direct regulation by the CRTC over the 9-1-1 core elements and the connectivity interconnection to the PSAPs.

1029 That -- the reason that the model works is because there's a regulator with direct jurisdiction over this really important service, and it just so happened from the history of telecommunications that it was the ILECs that were in a position to provide 9-1-1 in their various ILEC regions.

1030 And so you have all of these components of the system that the evidence has clearly shown worked very well, and to the point where we have dedicated teams across the ILECs dealing with 9-1-1 services every day. And that's the type of infrastructure that we would like to continue. It's the fact that the historical elements have led us to a situation where we have a high quality, robust 9-1-1 network, and those are the elements we want to continue into next-generation 9-1-1.

1031 And so to directly go at the question about governance, instead of a third-party agency or national consortium or administrator or whatever, the -- what we want, what TELUS sees is a regulator that already has within it the jurisdiction oversight of this service, and for that to continue.

1032 COMMISSIONER MENZIES: Okay. Would you see NG9-1-1 having any impact on ILECs? I believe you just have one CLEC that you deal with, Prince Rupert, but would you see it having any impact over those relationships, the -- a new -- an NG9-1-1 framework?

1033 MR. EDORA: I just want to clarify. NG9-1-1 framework having an impact on our relationship with other CLECs in our territory; is that what you're asking about, or ---

1034 COMMISSIONER MENZIES: CLECs.

1035 MR. EDORA: CLECs?

1036 COMMISSIONER MENZIES: Yeah.

1037 MR. EDORA: Likely just one.

1038 COMMISSIONER MENZIES: I think you’ve just Prince Rupert, but I stand to be corrected.

1039 MR. EDORA: Right, just one moment. In conversing with my colleague, we're actually not familiar with how Prince Rupert Tel provides 9-1-1. They have their -- obviously, they provide it to their citizenry in Prince Rupert. And so we could take that away if you want to find out more about that.

1040 COMMISSIONER MENZIES: Yeah, if you could, because it -- I mean, it could be me. I was under the impression that you were the network provider for them, but if you can clarify ---

1041 MR. EDORA: Yeah, absolutely.

1042 COMMISSIONER MENZIES: --- and reply, I think, January 24th ---

1043 MR. EDORA: Yes.

1044 COMMISSIONER MENZIES: --- is the undertaking day?

1045 MR. EDORA: Absolutely.

1046 COMMISSIONER MENZIES: Thanks.

1047 UNDERTAKING

1048 COMMISSIONER MENZIES: Yeah, so you suggested interconnecting regional networks to create a national network as the way to go. Why, in your view, is that the most cost and time efficient manner to implement NG9-1-1?

1049 MR. EDORA: My colleague, Richard, will have a lot to say about this, I think, as well, but going back to my earlier response to your question, we're trying to build the next-generation 9-1-1 network using what's good about the current system right now. And also in terms of good network design, you always want to build in a redundancy and fail-safe techniques so that the network is always available. And so the next-generation 9-1-1 network will be a national network, but you will, obviously, have components, duplicate components, running redundant, redundant networks so that connectivity is always made available.

1050 And so in our view, the way that you can actually take the current system and build the national 9-1-1 network is to actually have separate core networks operated in different regions. And Richard will add to that.

1051 MR. POLISHAK: Thank you. Yeah, so part of the efficiency -- sorry, part of the efficiency and from a cost perspective is that we have some of those, you know, interfaces already with these providers, so you know, we can -- from an enhancement perspective, it's more along those sides, because your -- forgive me, your consumers are on cost and efficiency. So yeah, so from that perspective, we have those links in general.

1052 In terms of from an overall perspective, we believe that, you know, building the most robust network possible would mean, you know, more than a single provider.

1053 COMMISSIONER MENZIES: Can you -- just a minute -- can you quantify that existing relationship, like, in terms of cost or price, that by having the existing relationship with the PSAPs and that sort of stuff the way it's structured now, why is that going to be more efficient than say, having another national network provider come in with a new system? How big of an edge in terms of cost do you think that is?

1054 MR. POLISHAK: I'm not sure from a cost, necessarily from a cost perspective how big of an edge that would be from an efficiency perspective. We obviously have into these locations already network facilities that, you know, could be enhanced in some cases to support the additional, you know, bandwidth and IP infrastructure that would be needed.

1055 COMMISSIONER MENZIES: Okay, in terms of interconnecting with other regional networks, are there economies of scale that could be achieved in terms of doing that in contrast to the idea of having a single national network provider?

1056 MR. EDORA: I apologize. I was thinking you might be talking about PSAP consolidation, but it doesn’t sound like you're talking about that.

1057 COMMISSIONER MENZIES: No, I'm talking about network provider.

1058 MR. EDORA: Network provider by interconnection regions? Is that what you're ---

1059 COMMISSIONER MENZIES: If we have the options of going with a single national network provider with a new network, and your idea of interconnecting regional networks to create a national network. That's what I was trying to get at.

1060 MR. EDORA: Okay, and you're asking why one is more efficient than the other; is that right?

1061 COMMISSIONER MENZIES: Yes, in your view, is -- would the interconnecting the regional ---

1062 MR. EDORA: Right, I understand.

1063 COMMISSIONER MENZIES: --- networks, what sort of economies of scale might exist or other efficiencies?

1064 MR. EDORA: The emergency services is a -- it's a local issue. I mean, emergencies are handled by local agencies because emergencies happen in a specific area. And so if you actually separate out the network from who's actually responding, it's the PSAPs that have built their infrastructures to actually contact the first responders and actually then respond to wherever the emergency actually takes place.

1065 So the next-generation 9-1-1 network is actually going to be a national network, but you'll have many different entities actually interconnecting into that. And so what we're positioning as valuable for Canada is to actually -- because you're going to have to build redundancy into the national network anyways, and so you're going to have core regional networks, and so to build from the existing model where you have ILECs in their own regions, building their own existing 9-1-1 networks, is to continue that type of model for next-generation 9-1-1.

1066 I -- the efficiency question is a little bit difficult to answer, but I can tell you that what we're trying to build is a overall network design that will look a lot like what you would have with one provider, which is a bunch of regional networks that are redundant for each other.

1067 I'm not sure, Richard, if you want to add on to that?

1068 MR. POLISHAK: Yeah, I think that that’s from a connectivity -- I’m not sure that there’s an efficiency gain or cost gain or decrease either way. Those networks will need to be built out to all of those emergency providers and then, you know, interconnected from a regional -- at a regional level.

1069 If it’s done by one national provider it would be similar. They would still have to build up -- you know, a national provider would need to go into all the areas and build out those connections. So the ESInet being kind of a network of networks from that perspective.

1070 COMMISSIONER MENZIES: So if we were to mandate a single engine 9-1-1 network provider, national network provider, would TELUS apply for the job? And why or why not?

1071 MR. EDORA: Would this be through some sort of RFP process or some sort of bidding process?

1072 COMMISSIONER MENZIES: Something like that.

1073 MR. EDORA: Well, I think that -- I mean, as you can tell, I mean we have a major interest in 9-1-1 and it is a business and a service that we offer. And so certainly we would have interest just as a concept behind any sort of 9-1-1 network service provision.

1074 But whether we’d want to actually undertake and put in a bid for a national 9-1-1 provider, I think that’s highly contingent on first of all what that overall RFP process -- well, RFP looks like, what are the terms and conditions, and then how viable we think it is to actually then start providing the service in territories where we currently aren’t located.

1075 And so there’s a number of business and practical questions that I think that we would actually have to research before we made that decision. But I can tell you, I mean, as a 9-1-1 service provider it is something that we would definitely consider.

1076 I’m not sure, Orest, did you want to add?

1077 MR. ROMANIUK: Just along this questioning and the earlier one where you asked about the efficiencies of working with the PSAPs. I think if a national provider came in there would definitely be inefficiencies in terms of we’ve already have relationships and contracts built and agreements. You would be -- and those are subject to obviously confidentiality clauses. You’d almost have to be starting from scratch as well.

1078 So it’s like you go out to any RFP there’s a large build-up process to get to where you’re at with the customer that you’ve had for 5, 10, 15, or 35 years. That wouldn’t necessarily need to be rebuilt, so there is that component that may be a deficiency that slows down the process if you go down that route.

1079 COMMISSIONER MENZIES: So if you look forward to building NG9-1-1 networks, what does that process look like to you right now in terms of architecture, in terms of planning, in terms of timing? How would you see this? I mean, you mentioned 2028 as being the end of the migration period. When would be the beginning of the migration period in that sense, and where would TELUS be at in being able to provide those? You’ve mentioned Calgary and EComm as ones that would happen sooner, but what would your process planning look like?

1080 MR. EDORA: Right. And my colleague Richard will be able to add to this.

1081 Our understanding, or my understanding, is that there are still standards that need to be finalized as part of CISC. There are a number of CISC ESWG activities that are taking place. The NENA i3 standard has been accepted but there’s still a number of things that need to be analyzed further in relation to that.

1082 And so I’m not sure if we’re in a position to actually state a definitive timeline in terms of when we would be ready to build or when our build would be finished, but I can tell you that we’re ready, willing, and able to work within the CISC and to help define those standards and undertake the process. And whatever timeline the Commission deems as reasonable based on the record of this proceeding we’re certainly going to live to.

1083 And, Richard, if you want to top-up on that?

1084 MR. POLISHAK: Thank you.

1085 Certainly to add to what Eric said, I mean, we have processes in place. We have activities underway in terms of lab, you know, starting our own processes around, you know, preparing for these network components and bringing them to fruition, you know, we’re starting on.

1086 You know, in terms of definitive timelines, as was stated, as the standards that we agreed to within ESWG and other associations come online and our vendor partners are able to support those, we would absolutely, you know, look to drive those in as quickly as possible.

1087 COMMISSIONER MENZIES: Another interconnectivity question. In the current framework we’ve got CLECs, wireless carriers, and PSAPs are all trusted entities. As we’re taking a look at this, is there anyone we should be adding to that list of trusted entities?

1088 MR. EDORA: I just want to make sure I -- you had CLECs, wireless providers ---

1089 COMMISSIONER MENZIES: And PSAPs.

1090 MR. EDORA: --- and PSAPs.

1091 COMMISSIONER MENZIES: So they can all connect directly.

1092 MR. EDORA: Right. In the current environment, that’s the reason that those are the entities that have the interconnection is because this is a voice-based system and so it certainly makes sense that those are those are the trusted connectivity partners for ---

1093 COMMISSIONER MENZIES: I wasn’t asking you to say if they should be booted out.

1094 MR. EDORA: Yeah, no, I understand.

1095 COMMISSIONER MENZIES: I’m asking if anybody else should be added.

1096 MR. EDORA: I understand. But I think who should be added that’s a secondary question to what are the tools that we want to enable on next-generation 9-1-1. And that discussion I think is a product of -- that decision is a product of a discussion by the PSAPs where they can say -- where they say the tools that they would like to see to have their customers be able to communicate, and then a decision is made from that.

1097 I don’t think that -- like, there’s a whole host of over-the-top communication providers available on the Internet. I’m not sure if we’re in a position to say which ones should be trusted and which ones shouldn’t. I think that’s part and parcel to a discussion about what applications themselves should be made available on 9-1-1. And then of those applications, which of those service providers can actually send traffic.

1098 COMMISSIONER MENZIES: Right. So where would it be most appropriate for that discussion to take place in terms of establishing criterion for membership of the trusted entities group? That’s emergency service working group or ---

1099 MR. POLISHAK: I would say that that would be an appropriate ---

1100 COMMISSIONER MENZIES: I’m guessing you’re not saying the Coalition’s idea.

1101 MR. POLISHAK: I would say what would be an appropriate group is obviously when the -- the one question obviously is you say “trusted”. I mean, I’m thinking we’re talking trusted from the perspective of, you know, the information that is being provided, provides an enhanced capability to the 9-1-1 service providers. Or sorry, to the end users of that which are the PSAPs and the SSAPs.

1102 You know, so we would want to work in conjunction with them to make sure that we are going to enable any tool that they would find allows them to make an improvement for, you know, saving Canadian lives and getting emergency services there.

1103 COMMISSIONER MENZIES: In terms of reliability, security, resilience, some people -- folks -- have made the point that open standards and IP-based communications have some exposure to network vulnerability. Do you agree with that? And if so -- I mean, is there an issue to be managed or -- and if so how should we manage it? Or is there not an issue there, in your view?

1104 MR. POLISHAK: I think that that points certainly to the larger question, which I would agree wholeheartedly, around cyber security is very critical to this overall deployment. You know, in general, as we’re moving towards IP obviously we’re talking about a much more widely, you know, attacked infrastructures and so forth.

1105 So, you know, from open standards and so forth there are certainly things that we want to or would recommend that, you know, be considered right from a private network. And maybe looking at what are the best practices that we can implement around protecting that network and, you know, the platforms within the IP architecture that would support that. Which is to say that, yes, we share some of those concerns. But we think that collaboratively -- and obviously this goes even beyond Canada working as an overall 9-1-1 service provider community -- there are ways that we can help to lock that down.

1106 COMMISSIONER MENZIES: Okay, thank you.

1107 Now in terms of funding, your oral presentation cleared up a few things. But your plan A is still direct government funding, yes?

1108 MR. ROMANIUK: That is correct.

1109 COMMISSIONER MENZIES: And I mean you have sort of created fulsome plan B’s and plan C’s thinking that maybe that might not be possible, I guess. But I’m curious to know why you think direct government funding would be superior? And if we were to make that recommendation as you request to the government, would we recommend to them a Phase II costing basis or what sort of costs would we be talking about and why -- give me the sales pitch that you would want us to give them on your -- that this was better.

1110 MR. ROMANIUK: Because it’s great for all Canadians, would be the sales pitch.

1111 COMMISSIONER MENZIES: Yeah, but I’m guessing they’d want more detail than that.

1112 MR. ROMANIUK: Agreed. No, 9-1-1, you can see, it’s akin to, you know, a public service or -- you know, as police force or defense, whatever, it’s all Canadians love to have it; you never want to actually need it or use it but every Canadian should have access to the same level of public-service good and same level of 9-1-1 service.

1113 We believe it’s a requirement and a need for the Canadians. It should be equally funded across the largest base of Canadians, therefore general revenues is the largest base -- general revenues is the largest base to fund national 9-1-1. And it is akin the Connecting Canadians Program where, you know, the government has identified this need, or this desire, and, for ourselves, we seem to have the best-in-class or world-class level 9-1-1 is desirous -- it would be desirable for the government, and therefore they should assist, if not fund for the entire program.

1114 COMMISSIONER MENZIES: Okay, and this would be purely for network provision, in terms of the funding?

1115 MR. ROMANIUK: I think that would be the most ---

1116 COMMISSIONER MENZIES: What would be being funded would be the network?

1117 MR. ROMANIUK: The construct of it, I think would probably be the most efficient, which would -- yes, you could apply to all builders and then you probably would go for -- the ongoing operating costs would be funded via those customers who are using it or across the customer base. So yes, the original capital cost would probably be the most efficient.

1118 COMMISSIONER MENZIES: But the PSAPs themselves would still continue to be funded by municipalities across the ---

1119 MR. ROMANIUK: I’m sorry. I mean yes, separate funding.

1120 COMMISSIONER MENZIES: Yeah, in terms of that, but the network?

1121 MR. ROMANIUK: Yes.

1122 COMMISSIONER MENZIES: And that’s -- so if somebody came back and said, “Well, why is that any different than doing it through the National Contribution Fund?” Isn’t that the same -- doesn’t that satisfy the same moral imperative in that sense?

1123 MR. ROMANIUK: Well, the National Contribution Fund as we know it today, it’s, you know, set up for high-cost serving area and, to an extent now, for the telecommunications service. Should it be funded similarly? I guess that’s a -- it’s a good question. That’s what we look at in default.

1124 It should be a similar process and that process is where the users -- if not the Canadian government, because it’s almost like an essential or basic service, then it defaults to the users and those who benefit most should fund for it. And we find that the national contribution mechanism, the process that has been created in terms of it separates the funding in versus the funding out, the CRTC monitors it and it creates an equal review process.

1125 COMMISSIONER MENZIES: So it’s the collection -- the system of collecting the funds that you find inferior as opposed to the distribution of them?

1126 MR. ROMANIUK: Distribution we based on where the costs were incurred. And that’s right, the collection is where we think the National Contribution Fund could improve the system and also address some deficiencies that may be present in the current mechanism, so fix it in the future on those existing deficiencies.

1127 COMMISSIONER MENZIES: Okay. And how would you address the points made by some that under the current structure -- the tariffed model, anyway -- you -- I shouldn’t say “you” -- ILECs, in general, may be collecting currently more than they need to provide the 9-1-1 service?

1128 MR. ROMANIUK: Yeah, we have not done a full cost study looking at the current source of revenues versus the cost but a cost study was done by Stentor at a time and it was -- sorry, it was over an extended period of time.

1129 It’s interesting that most people believe that, you know, your costs decrease over time; however, as, say, their lesser capital constraints, or costs up front, your maintenance ramps up, the network has evolved and changed, which were costs that were not originally contemplated.

1130 As an example, I believe I saw something that the number of trunks that we have deployed is twice of that amount that was way back when in the early-2000s when the study was done by Stentor and subsequently, you know, reviewed, and that’s because of emergency-centres requirements -- so those things, software changes, and then your ongoing maintenance and training and everything, and such.

1131 So I -- again, we haven’t done a fulsome cost study but the costs do evolve and change and they do change in nature as assets do wear out. In fact, I think the comment was earlier on -- looking forward, the equipment we have today, in ten years’ time there’s not going to be a manual for it; there’s not going to be a switch; there’s not going to be a replacement part.

1132 All we can -- 15 years ago when this equipment was in place, we’re running into those issues right now given that those assets are starting to, and have reached their, you know, average asset life term period. So -- but those other costs are still -- they are an ongoing ---

1133 COMMISSIONER MENZIES: So there’s a chance they’re correct?

1134 MR. ROMANIUK: And an equal chance that they’re incorrect. I haven’t done the study so I can’t confirm.

1135 COMMISSIONER MENZIES: Right, so it might an opportunity to take a longer look at those sorts of things ---

1136 MR. ROMANIUK: In terms of ---

1137 COMMISSIONER MENZIES: --- particularly going forward to make sure that whatever costing model or reimbursement model was flexible over the years because there are bound to be things that are more expensive at the front end and need to be amortized in terms of costs and that sort of thing?

1138 MR. ROMANIUK: Absolutely. In fact, if you think of the example you’ve got the old highway going down between the two cities, and that you got more maintenance on it, and you’ve added a few, you know, turns off it but in the meantime you will be building the new highway.

1139 And when you do the cost study, you would, assume, add the two costs, and then one would fall off gradually and then, assuming there would be a cliff at a point in time -- and as long as the tariff process is long enough to capture all those steps, that would cost the escalation, the decrease, and the drop.

1140 COMMISSIONER MENZIES: And -- yes, and you detailed your thoughts about how the contribution fund funding would be costed out.

1141 MR. ROMANIUK: Yes.

1142 COMMISSIONER MENZIES: Just going back to the idea of have a general revenues fund, if that sort f recommendation was made, how much money would we be talking about more than is currently spent -- 30 percent, 50 percent, under ---

1143 MR. ROMANIUK: I have no idea. We have not -- given that the service level -- service levels have not been developed yet. You know, and we’ve identified in our response to interrogatories in the May timeframe is that we just don’t have a cost estimate. It’s going to take a while to get that, and then what gets deployed and how long. And then you have to take into account how long do you have to keep both systems parallel. You’d have to make estimates on that. But we just don’t have that cost estimate right now.

1144 No, I don’t -- the U.S. was immensely ---

1145 COMMISSIONER MENZIES: So if we were to make that recommendation it would have to be kind of a blank cheque we’d be asking for?

1146 MR. ROMANIUK: In terms of ---

1147 COMMISSIONER MENZIES: In terms of asking the government to provide funding from general revenue for NG9-1-1 network ---

1148 MR. ROMANIUK: I think it would be, you know, not a blank cheque but you would go to them at a time when you started to develop preliminary cost estimates. You know, we have this range of X to Y risk going to them today; there should be a range of cost, I would assume, in the future.

1149 COMMISSIONER MENZIES: Okay, thank you.

1150 Do you think NG9-1-1 should or could be viewed as -- or designated as a basic telecommunication service?

1151 MR. EDORA: Well, under the Telecom Act, if we’re asking for national contribution funding,it would have to meet that definition of a basic telecom service, I think. And I don’t think there’s probably any debate about this, that 9-1-1 is probably -- the most important telecom service that we provide, and that any telecom provider provides. And so, on that basis, I can’t see how it would not meet the definition of a basic telecom service.

1152 COMMISSIONER MENZIES: Okay, thank you.

1153 There seems to be some general consensus, anyway, that IP Voice services and then Text-to-9-1-1 are the priorities of most -- folks see it that way in terms of transition to NG9-1-1. What would you see would be the next-generation services provided after those two?

1154 MR. EDORA: It’s the power of the internet. The IP networking allows so many different types of communications tools and so many different types of tools that we haven’t been invented yet or have not made the light of day yet. So many ways that people communicate weren’t around five years ago.

1155 And so when people are talking about communications tools, I think we need to step back and say, “How do we enable that, anything to -- any type of tool to actually be 9-1-1 connectable?” And that’s the NH9-1-1 network.

1156 And I think that’s the focus of the TELUS panel, is that this proceeding is about the network. The applications that are enabled by that network, that could be a separate discussion. I think that’s an important discussion that needs to happen at a later date when those communication tools arise. People will start to look at inventing new applications that might hook into our NG9-1-1 IP network.

1157 And so if that becomes a possible future development, then we can have a consultation to determine, “Is this the way that people want to communicate with 9-1-1? And is this a way that PSAPs can actually communicate with their callers or with their communicators?” So I think the context of what applications is the second question after, “How do we get the network in place that enables that connectivity?”

1158 COMMISSIONER MENZIES: Okay. Who do you think or should -- or do you think anybody should be responsible for public education, if you believe it’s necessary, over changes to the way the public and PSAPs interact with 9-1-1 services?

1159 MR. EDORA: Yeah, that’s an excellent point. I’m kind of embarrassed to say, but I grew up in a day when 9-1-1 was just being introduced in my hometown, in Richmond, British Columbia. And I remember seeing in the phonebook and in newspaper advertisements and in magazine adverts and on TV, “Don’t call directly to police. Call 9-1-1.” And so though I was quite young at the time, I understood that this was a concerted effort by a number of different parties to do that public education campaign.

1160 And I think the same type of thing will have to be necessary. Obviously calling 9-1-1 is ingrained in so many people’s minds when they have an emergency. If there are other tools then definitely I think all stakeholders have an obligation and a duty to inform their customers and their citizens -- and the citizens of the different tools that are available to them.

1161 COMMISSIONER MENZIES: But do you see that being done on a local and sort of municipal or ---

1162 MR. EDORA: It could be a combination thereof. I mean, the CRTC has proven to be very good at sending out communications via social media and via different promotional materials on the new initiatives and new service offerings to customers or regulatory requirements for customers. And so it’s a combination thereof.

1163 And I think that’s -- what you see at CISC is a whole host of different types of stakeholders. It’s the CRTC; it’s the TSPs; it’s the PSAPs; it’s governments; and it’s also the first responders. And I think all of those entities at some level will have a duty to play with that education campaign.

1164 COMMISSIONER MENZIES: I just want to talk about text messaging for a second -- well, maybe longer than a second -- a few minutes. Is SMS on the way out?

1165 MR. EDORA: Well, I’ll hand this over to Richard.

1166 COMMISSIONER MENZIES: Just to give you context, I’m trying to look at the text messaging as is this a chicken and egg situation? Should we wait for RTT and before or ---

1167 MR. EDORA: I’m not going to say that text messaging is on the way out. I mean, obviously I use it a lot and I know lots of people that do use it. But my understanding is that there’s other over-the-top messaging applications that might be popular amongst different people. But certainly, I mean, as a company that provides text messaging I think that we have lots of customers that use text messaging every day.

1168 Richard, do you want to comment?

1169 MR. POLISHAK: I think that what you’re alluding to is accurate in that people are, you know, particularly looking at and using other services other than direct text messaging through the handsets, certainly like, you know ---

1170 COMMISSIONER MENZIES: OTT and RTT?

1171 MR. EDORA: Right, iMessaging, all these sorts of different OTT types of apps, for sure. Yeah. And so, you know, I know that we’ve certainly seen through our friends in the U.S. that, you know, they have taken I think a stance similar to what you’re suggesting in terms of, you know, SMS is something that is an older protocol that is being supplanted. So you know, the recommendation from that perspective was to focus the efforts on the newer technologies to make sure that they’re delivering, you know, what is required.

1172 COMMISSIONER MENZIES: Okay. If you can, at what point in the future do you see, let’s say, the large majority, let’s say about 80 percent, 75, 80 percent of Canadians having RTT- or OTT-enabled mobile devices as opposed to text messaging with SMS to 9-1-1, that they would be using an IP-based system to text?

1173 MR. EDORA: I’ll let Richard fill in some details here. But if we’re talking about over-the-top text applications, those are readily available now. You can download a whole host of different types of applications ---

1174 COMMISSIONER MENZIES: Well, no, I know. I meant Canadians actually -- the overwhelming percentage of Canadians actually having the devices as opposed to whatever devices they have now. Are we there?

1175 MR. EDORA: I’m not sure about real-time text, but certainly over-the-top texting is readily available on most devices.

1176 COMMISSIONER MENZIES: Right.

1177 MR. EDORA: I’m not sure, Richard, if you want to comment on real-time?

1178 MR. POLISHAK: If what I’m understanding is correct, you’re asking when RTT would be just like -- be enabled by de facto, if you will, text solution within the handset itself?

1179 COMMISSIONER MENZIES: Yes.

1180 MR. EDORA: Yeah. I don’t have a definitive time as to when those will be reached, from our perspective. That’s part of the RCS, Rich Communication Suite, that’s included in the next generation of our fortune handsets. We are, as a level set, testing and have those capabilities in -- you know, from a test perspective. But we don’t have that service commercially available today. So I’m not exactly sure what the timelines would be.

1181 But certainly one of the interesting and obviously exciting things about the wireless market is people want the newer handsets with some of these capabilities in place. So you tend to see more rapid adoption of those technologies than, say, from a wireline perspective.

1182 COMMISSIONER MENZIES: I was going to ask you a question and I’m sort of going to ask it anyway because it will come up and be discussed with the idea of having a national App for 9-1-1.

1183 You made a comment just a few minutes ago that made me assume that your answer might be, “We might be getting a little ahead of ourselves with that discussion because we’re talking about the network right now.” I just wanted to confirm that or if you have another view about the idea of promoting a national App, 9-1-1 App.

1184 MR. EDORA: Well, the App is only made possible by the network.

1185 COMMISSIONER MENZIES: Right.

1186 MR. EDORA: And so we can’t talk about what’s possible before we actually put in place the framework that allows that to be possible.

1187 And I think that was my response from earlier. I don’t think we have a -- I don’t think we’re pro or con on a mobile App for 9-1-1. Certainly again, these types of technologies, they’re really driven by what the PSAPs can handle. And there was discussion earlier today about mistaken calls to 9-1-1. And so, you know, as easy as you make it to call 9-1-1, you make it really easy to make problem calls to 9-1-1. And so the PSAPs themselves, they are in best position to talk about the pros and cons of different types of things.

1188 Certainly the customers -- the mobile wireless customers today, they want to do everything on their Apps. And so that might be a very logical development in terms of how to contact 9-1-1 for a lot of people. But as a telecom company, I’m not sure if -- I don’t think that we’re going to say yes or no to that. I think that’s really a question for, “Is this the right communications tool for the PSAPs?”

1189 COMMISSIONER MENZIES: Okay. Similarly, this has been discussed and will be discussed, I expect, the extent to which people may connect through what we’ve referred to very broadly as the “Internet of Things”, in other words -- it was mentioned earlier, your refrigerator -- but also, you know, more directly items like crash-notification technology in automobiles and that sort of stuff, contacting 9-1-1 directly in the future. And here we’re just really tapping your expertise.

1190 At what point in the future do you see -- I mean, obviously yes, we need the network first, but we have that network in place. We’re also talking about what that network might be carrying. Do you see those sorts of connections, particularly crash notification technology, calls or messages going directly to 9-1-1 any time soon, and if not soon, do you see it later and when?

1191 MR. EDORA: Well, I'll start and look to my colleagues if they want to add in.

1192 I hate to repeat what we've commented on earlier. The -- it's -- the network makes all of these feasible. The main question, I think, that we need to step back and actually consider is how do these over the -- not over the top -- these machine-to-machine applications, if they're sending direct communications to 9-1-1, how is the PSAP going to handle that? And so I think -- I mean, as the telecom -- as a telecom provider who could provide the core 9-1-1 network, we'll transmit whatever has been deemed appropriate and will send this to PSAP -- to send it to PSAP for them to actually then handle the communication.

1193 But the concern that I think that you might hear from some of the PSAPs is, do they have the systems in place to actually receive those? And I think -- so I think that's the big variable, in terms of timeline. And the second concern they might raise is, are we actually equipped to handle this in terms of personnel and in terms of potential deluge of communications at a particular time?

1194 COMMISSIONER MENZIES: Yeah, I mean, there's -- I've heard that from many PSAPs.

1195 MR. EDORA: Right.

1196 COMMISSIONER MENZIES: You know, they want to be able to have a network and an internal infrastructure that's going to be able -- you know, when it comes to talking, but when you're sending video and then you might be sending crash notification and sending whatever it is you're sending, they don’t want to be overwhelmed.

1197 MR. EDORA: Right.

1198 COMMISSIONER MENZIES: So that, in a sense -- not directly, but it indirectly goes to talking about the overall architecture of the system, if not just the network that we're trying to conceive of as we put this together. So that's helpful in terms of context. That's why that information is useful to us; not so much for the network capacity, but to talk about timing, rollout, that sort of stuff, and have for all the parties involved.

1199 MR. EDORA: Well, I think Richard might be able to add to this, but certainly, that's something for the PSAPs to have to consider. I mean, when they build their interconnection facilities to the core network, they're going to have to think about how -- what types of transmissions are actually taking place, the volume of the -- not just the volume of transmission, but how bandwidth-intensive the actual transmission is.

1200 So it's video, a live video, a streaming video, and then two-way -- being able to facilitate two-way conversations and a lot of communications at the same time. So certainly, I think that that plays a part in how quickly the PSAPs will be able to migrate.

1201 I'm not sure, Richard, if you want to add anything to that?

1202 MR. POLISHAK: I think that that's -- thank you, that's a -- it's a great question to think about, in terms of when could some of these capabilities come on board. I mean, I think from a -- you know, our perspective, just -- we want to make sure that the network is in a position to deliver whatever is defined reliably, you know, and securely, to those PSAPs.

1203 You know, having something like this in place, if we could hypothesize that there was a way for the car's, in this case, an automobile's metrics to know that this is a serious accident and this information should, you know, go directly forward instead of -- I think it was mentioned with like, a flat tire situation or something -- you know, the building of those networks can facilitate that interconnection.

1204 So I apologize, but I -- that's the -- if that's the gist of the question, it would be yeah. I mean, as these come online and as the PSAPs are able to utilize this information in support of emergency services, you know, it can accommodate those.

1205 COMMISSIONER MENZIES: And I just wanted to confirm in that area that you mentioned in your initial intervention that you saw sort of three to five years as the timeframe for getting this started. Is that still the timeframe you're looking at, so 2020 to 2022, somewhere in there, for the network?

1206 MR. POLISHAK: Apologies, yes. Yeah, that's it. So we view it as once we have the specifications and the guidance in terms of how we're going to architect this out, it's -- it would be about a three to five-year process to have the network in and built out and in support of, you know, the first iteration around next-gen 9-1-1 and those capabilities. As alluded to, that, you know, not all PSAPs may be in a position, obviously, to take part in that. That's something else.

1207 COMMISSIONER MENZIES: And you mentioned -- I think you mentioned lab work?

1208 MR. POLISHAK: Yes.

1209 COMMISSIONER MENZIES: Asking if you had any -- if you would be doing any trials or pilot projects in this area, or you foresee doing them?

1210 MR. POLISHAK: Assuming our plans are -- to get those -- the lab work kick started this year and start those pilot kind of internal testing to be started in a year.

1211 COMMISSIONER MENZIES: Okay. And you -- when you mentioned 2028 as an end date for the current system -- and you made a good point about calling it a legacy system versus -- and all the changes, how much it's developed -- do you think we should get involved in setting decommissioning dates for that, or is that again -- is it too early or unnecessary?

1212 MR. EDORA: It's -- I wouldn't say it's unnecessary I think you might be -- I think you're right when you say it might be too early. I certainly heard some comments this morning about if you don’t set a date, then there will always be laggers that will never actually adopt. This is something I think that when the NG9-1-1 is actually operational and we're running the existing 9-1-1 network and the NG9-1-1 network in certain areas, I think that's something that we can actually analyze and determine okay, so what are the -- what do the PSAPs need to actually move to NG9-1-1, and what PSAPs do we identify as ones that can move and which PSAPs might have more problems?

1213 And then we analyze those that might have more problems in terms of moving, and then maybe further down the road, you can set a definitive time when 9-1-1 traffic is expected to be on -- all on NG9-1-1. But at this particular time, I don’t think that we're in a position to say that an end date should be set.

1214 COMMISSIONER MENZIES: Privacy issues, where do you see NG9-1-1 having the biggest impact, or do you see it?

1215 MR. EDORA: Well, the biggest impact on privacy, we think, is going to be in terms of the PSAP. Again, the telecommunication service provider is just transmitting information. Our network -- well, the NG9-1-1 network will be secure and secure as much as possible, so even though that there's going to be sensitive information being transmitted over that network, it will still be transmitted in a secure manner.

1216 It's when the PSAP actually obtains that information. I think that's when you might have some privacy issues. I mean, obviously, the caller into 9-1-1 or the communicator into 9-1-1, they have sent that information because they think it's useful, but that information might pertain to them, it might pertain to a third party, it might pertain to a particular incident that they don’t want publicized beyond that or that they don’t want archived.

1217 And so I think there's a host of customer issues related to that information, but my understanding is that PSAPs already today have to adhere to strict provincial legislation with respect to privacy. And so I think the investigation really would have to be on whether those regulatory frameworks are actually sufficient.

1218 But as a telecom provider, I'm not sure if the privacy issue is one that really touches us directly.

1219 COMMISSIONER MENZIES: So -- but I'm taking your views are then somewhat similar to Shaw's, that no TSP should be involved in storing any information. You're just transmitting it. That responsibility should stay with the PSAPs?

1220 MR. EDORA: Right. The present 9-1-1 network has the automatic location information archived by the -- it's the ALI. The ALI database is kept by the ILEC 9-1-1 provider. We don’t see a need to actually have a database that archives people's medical records for 9-1-1 that might -- the call that might happen at some point. I mean, that's definitely not the goal of the TSP.

1221 The information that might be transmitted over a next-generation 9-1-1, it's going to be in the hands of the customer. It's not going to be in the hands of the TSP. And so the issues pertaining to the archiving of information are much less pronounced on those types of communications media on the next-generation 9-1-1.

1222 COMMISSIONER MENZIES: Do you think it would be appropriate to formulate that into policy, or is it necessary, in your view?

1223 MR. EDORA: Well, I think it's important to formulate into policy if the TSPs are planning some sort of archival information role. Then certainly, I think that a privacy policy might be necessary. But as I say, and as we foresee, we don’t think that the database requirements for the TSP are going to be more than what they are today.

1224 COMMISSIONER MENZIES: You mentioned six nines reliability earlier. I think that's what you said, right, six? It's a lot of nines. So do you think it would be necessary to -- with NG9-1-1 to amend or add any reporting or monitoring requirements regarding outages or any disruption like that? And how might that differ between say the three different structures we’re looking at, the contribution fund, the consortiums idea, the current model with individual ILECs tariffed and that sort of stuff; would there be any difference? Or do you see any need to make any changes or adjustments with NG9-1-1?

1225 MR. EDORA: Well, there is a current monitoring requirement that the Commission just mandated last year.

1226 COMMISSIONER MENZIES: Yeah.

1227 MR. EDORA: Certainly we support that. We think that 9-1-1 is of such a critical nature that as much information about the reliability of the network should be provided as much as possible. And so if that monitoring requirement is to continue or if additional monitoring and reporting requirements are mandated, we don’t have an issue with that.

1228 COMMISSIONER MENZIES: And do you have any problem with providing usage statistics to PSAPs or the CRTC if they were requested?

1229 MR. EDORA: I don’t think so, no, absolutely not.

1230 COMMISSIONER MENZIES: Do you see any different accessibility concerns with NG9-1-1 going forward, how we might address those, or if you see them?

1231 MR. EDORA: I think that again this goes into the tools that are actually enabled by next-generation 9-1-1. A lot of those communication tools are actually quite accessible. I mean, Text with 9-1-1 is not a next-generation 9-1-1; it’s current 9-1-1 but that was necessary for a certain population that can’t communicate via voice. And so if those types of applications are enabled, I think that accessibility is only enhanced by next-generation 9-1-1.

1232 Siri and those types of tools that are available on telephones or wireless handsets those help customers who might have accessibility issues. And so if those types of tools are made available to call 9-1-1 then I think that’s only -- will only increase the amount of accessibility, not decrease.

1233 COMMISSIONER MENZIES: All right, so no necessity for any new provision.

1234 And just while we’re on that, what has been your experience with the Text-to-9-1-1 since it was launched?

1235 I touched based with some PSAPs some time ago when it was first launched, and the usage seemed to be fairly minimal. Not so much the usage because it’s a good thing when people don’t call 9-1-1 but the registration levels were unknown, I think, at the time.

1236 MR. BRAUER: Yeah, your information is similar to ours; calls are minimal, which is a good thing. So that’s aligned with our understanding as well.

1237 COMMISSIONER MENZIES: Good awareness of availability as far as you know?

1238 MR. BRAUER: I’m presuming so. I mean, in dealing up with the PSAPs, we haven’t heard that people aren’t getting the information out but we’ll certainly hear back, I think, when the other groups show up this week, to see if we’ve communicated it well or not.

1239 COMMISSIONER MENZIES: Okay, thank you.

1240 My colleagues may have some additional questions; those are mine. Thank you.

1241 THE CHAIRMAN: I believe legal counsel has a question for you.

1242 MR. BOWLES: Yes, thank you, Chair.

1243 I just have a few questions. I want to go back to the -- a question was put forth to you as to whether you had any interest in becoming a national NG9-1-1 provider should that opportunity arise. I just have a few facilities-based questions that flow from that.

1244 If your company was to fulfil that role, does it currently have all infrastructure necessary to provide the service throughout the country?

1245 MR. EDORA: And with respect to the facilities that you do not ---

1246 THE CHAIRMAN: Perhaps you could actually answer so we can put it on the record.

1247 MR. EDORA: I thought I said no. I apologize.

1248 THE CHAIRMAN: Thank you.

1249 MR. BOWLES: With respect to the facilities that you would need to obtain, are all of those facilities currently available to you on a mandated basis by the Commission?

1250 MR. EDORA: We don’t know. We can’t answer that right now. Would you like us to ---

1251 MR. BOWLES: Can you undertake to provide that information, please?

1252 MR. EDORA: Yeah, absolutely.

1253 UNDERTAKING

1254 MR. BOWLES: That would be very helpful.

1255 And in the event that there were facilities that would be required and that are not currently available on a mandated basis, what would you foresee happening if you were unable to negotiate a commercial arrangement to procure those facilities?

1256 MR. EDORA: I just want to make sure I understand the premise of the question. We’re looking for wholesale facilities that are not mandated, they’re not regulated by the Commission, or they’re ---

1257 MR. BOWLES: That the provision of which isn’t mandated.

1258 MR. EDORA: Okay. So there’s wholesale facilities that were previously regulated but now are forborne; is that correct?

1259 MR. BOWLES: Well, I want to make a distinction between regulated and mandated provisioning.

1260 MR. EDORA: Okay.

1261 MR. BOWLES: Right now I’m only talking about mandated provisioning. So if there are facilities out there that you would require, do not have, and that are not available to you on a mandated basis through Commission rules, if you were unable to successfully negotiate commercial arrangements for those facilities what do you foresee happening?

1262 MR. ROMANIUK: One thing that I think would happen is if you are then the carrier of choice, you’d have to then build, place, so that would only increase probably the cost of this national network because it’s not being provided. You can’t negotiate it. So you have to do something so then you have to get into the central office, or you’d have to do something. You’d have to do it yourself if that is part of your service that you’re required to provide to all Canadians across Canada. So it would make the service more expensive, I think is one logical guess.

1263 MR. BOWLES: Thank you. Just a quick follow-up question on the text-based solutions. There was discussions surrounding RTT. Now, currently we have TEXT with 9-1-1 which is distinct from Text-to-9-1-1. Do you have any views on whether it would be appropriate to wait until real-time texting is broadly available through handsets before rolling out a Text-to-9-1-1 service to the general public?

1264 MR. EDORA: I think what we’ve heard from the PSAPs is that the main issue with Text-to-9-1-1 at present is the lack of location information that gets sent via that. And so I think that’s really the critical question, is if location information can be automatically transmitted through any type of text that would become a more viable solution for the PSAPs.

1265 Again, it’s the PSAPs that need to determine what system requirements they have to support any application. And so I think their comments would probably be a lot more of interest to the Commission on what application, what texting applications would be of value for them.

1266 MR. BOWLES: Okay, thank you.

1267 THE CHAIRMAN: And of course that undertaking is for the 24^th of January. Thank you.

1268 Thank you, gentlemen, those are our questions.

1269 Madame la Secrétaire?

1270 THE SECRETARY: Thank you. We will now ask Shaw Telecom to come to the presentation table.

PRESENTATION

1271 MR. COWLING: Good afternoon, Mr. Chairman, Vice-Chairman and Commissioners.

1272 My name is Paul Cowling, Vice-President, Legal and Regulatory Affairs. I am joined by my colleagues. On my right, Damian Poltz, Vice President, Technology Strategy and Networks; and on my left, Esther Snow, Director, Regulatory Affairs.

1273 Developing a robust, next-generation emergency communications system is a critical national issue. All Canadians should have reliable access to emergency services when they need it. Without this, Canadians’ lives are put at risk.

1274 The networks and technologies that support communications services have transformed in recent years through the shift to Internet-Protocol. With the Internet of Things and 5G on the horizon, that change will accelerate. The challenge in this proceeding –- which is similar to others over the past few years –- is to reform our existing regulatory model for emergency services so that it fits within this world of dynamic change.

1275 Meeting the needs of Canadians in today’s intensely competitive communications market, requires constant consumer-driven innovation. We believe this same spirit in innovation should be brought to the redesign of Canada’s emergency services system. The scale of change contemplated by the shift, NG9-1-1, is very significant. And as others have stated, the process will be complex.

1276 However, the guiding goal is clear. We will transition from today’s static legacy system to a modern IP-based 9-1-1 service that is flexible enough to keep pace with evolving and diverse consumer needs for decades to come while achieving the same resilience and reliability that Canadians have come to expect from our current model.

1277 This ambitious reconstruction of the 9-1-1 system starts with casting a new foundation that prioritizes accountability and minimizes the cost burden on consumers. We suggest the following related principles as the bases for assessing the proposals in this hearing in the 9-1-1 system going forward.

1278 Effectiveness. The 9-1-1 system has to be available and easy for Canadians to use. Above all, it has to do the job of responding to Canadians in an emergency without worry of whether a call will be answered or whether someone in need will be found. Effectiveness also depends on keeping up with the ever-accelerating pace of change we see in today’s global internet ecosystem.

1279 Efficiency. The transition to NG9-1-1 will occur over many years and many stages, several of which have not yet been sequenced or designed. This will be complex and costs could quickly escalate without sufficient accountability.

1280 There is very little, if any, evidence on the record of this proceeding showing the costs of the transition to, and operation, of NG9-1-1. In order to be sure that Canadians do not pay more than necessary for emergency services, we propose the creation of a national NG9-1-1 administrator that would run a process to determine the most efficient options. In our view, an effective way to discipline costs is to use this competitive process.

1281 To be sure, 9-1-1 is a unique public good service. That does not mean we should disregard the Commission’s emphasis on competition, market forces, and innovation when designing a new 9-1-1 system. In Shaw’s view, we must embrace these principles.

1282 Transparency. The process to bring next-generation 9-1-1 to fruition must be open and inclusive. The oversight provided by the national NG9-1-1 administrator, coupled with reasonable reporting to, and approvals from, the CRTC, will ensure that all parties and the public have visibility into the transition and new framework. This is essential to ensure that any new models are well-understood and that there is accountability for costs and operations.

1283 A competitive bidding process will also enhance the transparency of the system.

1284 In this proceeding, the ILECs have generally sought a renewal of their existing mandate, as extended to cover NG9-1-1. We agree that the ILECs have done a commendable job of providing reliable legacy 9-1-1 service to Canadians over the past four decades. However, the legacy 9-1-1 system is now obsolete and we no longer live in the monopoly environment in which it was originally developed. Our 9-1-1 system has not been keeping pace with the transformations we’ve seen in the communications industry and the gap is widening.

1285 While the ILECs may ultimately be suitable candidates to operate the next-generation 9-1-1 service, we do not think it would be in the public interest to simply renew their mandate through this proceeding.

1286 As an alternative, we propose a new approach for the Commission’s consideration, one that would better reflect and respond to today’s dynamic market, the complexity of the transition to NG9-1-1, and the innovative potential of NG9-1-1 in the future.

1287 Our proposal starts with a national NG9-1-1 administrator created by the Commission pursuant to section 46.2 of the Act and delegated authority to administer the new NG9-1-1 system. Once the administrator is established, all TSPs would be required to become members pursuant to sections 24 and 24.1 of the Act.

1288 The first tasks of the administrator would be to prepare a plan and budget for establishing the NG9-1-1 system and to select the NG9-1-1 operator or operators pursuant to a competitive bidding process, all of which would be submitted to the Commission for approval.

1289 MR. POLTZ: As Paul described, Shaw supports an entirely new approach to designing the NG9-1-1 system. In particular, designating a national administrator to oversee this complex process will promote the effectiveness, efficiency, and transparency of the system, and enable 9-1-1 services in Canada to keep pace with a rapidly changing global digital economy.

1290 It also follows naturally from the technological evolution of communication networks. IP technologies have broken the traditional ILEC boundaries and are inherently different than the closed, static voice networks from the monopoly era. IP lends itself to a single set of standards and a uniform technical oversight.

1291 At the national level, following the competitive bidding process that Paul described, the administrator would oversee and engage a national Emergency Services IP Network, or ESInet, operator. The national ESInet would act a centralized point of interconnection for global providers as well as domestic TSPs, PSAPs, and future service providers. It will administer a database and routing system that will deliver emergency calls and location information to the appropriate PSAP.

1292 This doesn’t cut off the potential for more regional or local ESInets to develop. In fact, we believe it better facilitates the orderly development of such an ecosystem by providing a uniform set of standards. This will enable a network of networks for 9-1-1 to grow organically and provide a fully interoperable system that can support various media and devices.

1293 This approach reflects the i3 architecture designed by the North American Emergency Numbering Administrator, known as NENA, which has been adopted here in Canada, the U.S., and Europe. Consistent with the dynamic state of communications market today, the NENA i3 architecture contemplates a hierarchy of networks that grows and evolves through a roadmap for a staged transition from legacy 9-1-1 networks to full NG9-1-1.

1294 With NENA i3’s open platform and single standard design, the door is open for a competitive process to determine who the most optimal single operator or multiple operators would be. The ESInet can support many options both for PSAP connectivity and routing functionality.

1295 Many emerging service providers are not currently connected to or have experience with 9-1-1, let alone NG9-1-1. As NG9-1-1 evolves over time, it will be critical to connect all of Canada’s telecommunications providers to the national ESInet, including these emerging providers.

1296 Shaw believes this transition would be easier with a single, national set of interconnection standards that all TSPs could rely on to determine where and how they connect and transit calls to the national ESInet. It avoids the need for multiple and inefficient interconnections and non-uniform databases that characterize the current legacy system.

1297 The transition to NG9-1-1 will be a complex and potentially costly task that we estimate will take three to five years to complete. Coordination and national oversight will require dedicated resources and committed professionals.

1298 While we certainly agree with the CISC Emergency Services Working Group has done an excellent job of guiding us through the previous enhancements to the existing 9-1-1 system, we do not believe it is equipped to oversee the fundamental change to emergency services contemplated here. This does not mean there is no longer a role for ESWG. Given the diverse nature of Canada’s telecommunications market, the ESWG must continue to act as an industry forum to review and resolve specific 9-1-1 technical issues.

1299 The national administrator, with dedicated personnel and a mandate that includes coordination and interconnection, would then successfully implement those technical solutions on a national basis.

1300 MS. SNOW: In addition to overseeing the development of NG 9-1-1 and identifying the relevant operator or operators, we also believe the national NG9-1-1 administrator would drive innovation and ensure that NG9-1-1 is evolving in step with communications developments, which we believe will only accelerate once the transition to IP has been completed; set timelines for transitioning voice services to NG9-1-1 networks, as well as exploring future phases of communications options such as text-based services, apps, and telemetrics; issue regular reports to the Commission on the status of the transition, budgets, reliability, and resiliency of the network; serve as a venue for reviewing 9-1-1 incidents; and monitor international developments, including the emergence of new standards for next-generation 9-1-1, and where appropriate, update the standards for the Canadian system to ensure it keeps pace with best practice internationally.

1301 As Damian mentioned, the transition to next-generation 9-1-1 will be a complex and costly undertaking. The current 9-1-1 network is funded through a combination of charges for 9-1-1 trunks and a per-network-access-service fee for every address entered into the ILEC ALI database. When we transition to NG9-1-1, this model will be obsolete as the new architecture will not include TDM trunking or multiple incumbent databases.

1302 Consistent with Shaw’s approach to the governance and networking of NG9-1-1, we believe that a new approach is also required for funding. In this regard, it is critical that we minimize the cost burden on consumers.

1303 Given that access to emergency services is a matter of fundamental national importance, Shaw concurs with other parties who have submitted it would be appropriate for funding to come from the federal government. The costs of public safety should be covered by the country as a whole.

1304 If this funding is not available, Shaw proposes that the costs of NG9-1-1, including the costs of a national administrator, should be recovered from a fee charged to each TSP based on working telephone numbers capable of placing an outbound emergency call.

1305 As we have heard from the PSAPs in this proceeding, even following the transition to NG9-1-1, access to emergency services will continue to be linked to voice until such time as PSAPs are equipped and ready to handle alternative methods. This is why it remains appropriate to limit the recovery of costs for NG9-1-1 to telephone numbers and not to expand it to include internet revenues at this juncture.

1306 When the network evolves to support emergency calls that are not tied to a voice-calling service, the funding model should be revisited. At this point, it is not clear when that will occur, and it will likely be years away. With the current focus on the transition of voice-to-IP-based 9-1-1 services, it would be premature to impose an NG9-1-1 access fee on internet or other telecom services that do not involve voice, especially when you consider that Canadians will not yet be able to use those services to access 9-1-1.

1307 The mechanism we envision for funding would be through the membership agreement in the national NG9-1-1 administrator. It would be a condition of membership, which would be mandatory as Paul described, for each TSP to contribute in accordance with the number of working telephone numbers active on their network.

1308 Some parties have proposed using the National Contribution Fund as expanded to include a levy on internet revenues. As mentioned, we do not believe that internet revenues should be levied to support the initial transition to NG9-1-1. To the extent that the Commission creates a new fund pursuant to section 46.5 of the Act, or expands the National Contribution Fund to cover NG9-1-1, we believe a separate follow-up proceeding would be required.

1309 We object to proposals to expand industry funding to cover PSAP equipment or operations. It remains the responsibility of provincial governments and municipalities, who have jurisdiction over PSAP operations, to provide funding to PSAPs, including for the deployment and upgrade to NG9-1-1 within their regions.

1310 Finally, we note that the ongoing legacy 9-1-1 payments are significant. Given that there will be some period of time in which the legacy and NG9-1-1 networks will co-exist, we must be vigilant in minimizing the cost burden to consumers. To achieve this, it would be appropriate for the Commission to review the existing 9-1-1 tariffs and assess whether they reflect the costs of a network nearing the end of its life cycle.

1311 MR. COWLING: There is clear consensus that Canada’s 9-1-1 system needs to be re-built. In the view of Shaw, and several others, this represents an opportunity to take a new approach to the regulatory model, one that embraces the competitive dynamic and innovation that the Commission, the industry, and new technologies have brought to the Canadian market.

1312 The current ILEC-focused 9-1-1 system is a legacy of the monopoly era. Several parties to this proceeding argue that we should take a path for NG9-1-1 that closely resembles the current ILEC-focused system. They point to evidence that the legacy system has worked well and the path is familiar. We agree that the current system has been effective. Yet, that does not mean it is the best path for the next generation of emergency services. Taking the familiar path will mean that we forgo the opportunity to examine how we can do things better and more cost-effectively.

1313 For the sake of Canadians, we believe it is worth refashioning the 9-1-1 system so that it can mirror our dynamic and innovative telecommunications ecosystem. Applying the principles of effectiveness, efficiency, and transparency as the metrics, our proposal provides a better fit with IP technologies and the needs of Canadians in the future. Designating a national administrator will better facilitate this complex coordination exercise, while providing independent oversight and thereby enhancing transparency and ensuring effectiveness.

1314 Of critical importance, a competitive bidding process to select the national ESInet providers will drive efficiency and cost discipline.

1315 In a world where modern communication is based on seamless, globally-connected IP networks, we shouldn’t build our new model on a foundation of ILEC landline footprints. Legacy models, developed for a single-service, single-provider era are inappropriate in this new world of multi-platform competition and diversity. Sticking with the status quo may seem easier, but it will limit the flexibility and cost-effectiveness of the new system.

1316 As the Commission has done in many of its recent policy decisions, it’s time to reconsider how we do things and to focus on the future. We must move to a diverse, nationally-relevant, and globally-inclusive 9-1-1 network that can meet the communications demands of Canadians today and tomorrow.

1317 Thank you and we look forward to your questions.

1318 THE CHAIRMAN: Thank you very much. I’ll put you in the hands of Commissioner MacDonald.

1319 COMMISSIONER MacDONALD: Good afternoon and welcome. You’re last up today and I realize I’m the person standing between you and the end of your day. So I promise not to take offence if the response to any of my questions is a simple “yes” or a “no”.

1320 Before I get started, though, I do note that Shaw and Freedom are intervening separately in this proceeding. Can you outline for me the reasons for that? Is it due to some legal separation between your two organizations?

1321 MR. COWLING: The primary reason is one of expertise. And from our perspective we’re capable of talking about our wireline network and our experience with 9-1-1 services from a wireline perspective. And the Freedom team, which currently has -- it operates quite independently from us and has a separate regulatory department -- will be able to speak more effectively to the wireless side of things.

1322 COMMISSIONER MacDONALD: So I shouldn’t assume that any response you may make today would also apply to the Freedom network as well?

1323 MR. COWLING: That’s correct. If you had something you wanted to make absolutely sure that was Freedom’s position on something, we should probably confirm with them.

1324 COMMISSIONER MacDONALD: Okay. When we’re going through the questions, though, if there are particular questions that you are confident would apply to both groups, if you can just please outline that that would be helpful and perhaps save us some time later on in the week.

1325 So you correctly note that there is going to be a lot of coordination that’s going to need to take place between multiple different stakeholders as we move forward towards next-generation 9-1-1. And I’m wondering why you feel a new national body is required. Do you feel that the necessary level of coordination isn’t already happening in the ecosystem today?

1326 MR. COWLING: Yeah, I think there’s technological reasons for our position as well as governance reasons for our position. And I’ll probably speak to the governance piece and then turn it over to Damian to talk about the technology piece.

1327 We’ve noticed over the course of the day that there’s a lot of questions, questions about whether an App would be appropriate; when could we implement Text-to-9-1-1; questions about standards; questions about interconnection. A lot of these questions would be, in our view, dealt with by that national administrator -- timing, deadlines for transition, deadlines for wind down to the legacy system. And we see a lot of efficiency in that because the industry will come together -- there will be representation from PSAPS, potentially accessibility groups and others -- to weigh in on those questions.

1328 There’s a lot of work to do in terms of costing, for example. There’s no evidence on this record of what NG9-1-1 will cost. We would envision the administrator going out through an RFI process and coming up with a straw man definition of what NG9-1-1 means and soliciting input from various providers on costs in order to develop an informed RFP process. And all through the way, the Commission would have visibility into that because they would be approving those steps.

1329 That’s sort of what needs to get done. And we think without a centralized body that has a dedicated staff -- unlike the ESWG today -- we’re concerned that it may not get done in the most efficient way possible. There’s a lot more to say on this so I’ll turn it over to Damian.

1330 MR. POLTZ: Yeah. On the coordination front, we feel that a national approach solves some of the challenges that we might face in the transition to NG9-1-1 and that the existing approach may not be able to deal with as effectively.

1331 Having a very clear set of national standards developed and supported by the administrator we believe will solve many of the interop issues that we’ve heard about other, you know, developments of NG9-1-1 running into the U.S. and other places. And certainly I think we heard it from some of the intervenors today around interop challenges.

1332 Additionally, we think that having a national approach accelerates the evolution. And fundamentally, we believe that NG9-1-1 is a system that will need to evolve very quickly in order to keep up with the rapid pace of change that we already see in the communications ecosystem.

1333 So unless we set something up to enable that evolution, I think that’s going to be a challenge. No matter how good the coordination would be across the different multiple providers, unless you have something driving that evolution I think it will be a challenge.

1334 Thirdly, we think there’s an opportunity to solve some of the complexity challenges we think we’ll run into. Again, we feel that next-generation 9-1-1 is a significant step up in terms of complexity and in terms of the services that you can support. So having a national driver again for that may help us solve some of those challenges. So I think those are some of the key technical benefits of our approach versus the individualized approach.

1335 COMMISSIONER MacDONALD: So given the responsibilities that you envision this new national body having, where do you see the line between what they should be responsible for versus what the CRTC should be responsible for? How do you see the two groups or other potential groups interacting with this new national body?

1336 MR. COWLING: Not dissimilar from the ESWG, this new body which would have a dedicated resource within it -- not people who are effectively volunteering and are representing their various stakeholders as is the case with the ESWG -- would have a very clear mandate, as Esther highlighted in her section of the opening remarks.

1337 And as I mentioned earlier, we would envision particular key steps in which the CRTC would be consulted for approval before there was any proceeding further with the key step.

1338 In our mind, the two big ones would be an RFI process. So the administrator would conduct this RFI where it would effectively design the plan for implementing NG9-1-1 and develop a straw man budget for it, come back to the Commission for approval of that spec so to speak, then run an RFP process, have a winner-candidate, and come back to the Commission for approval of that winner-candidate.

1339 Beyond that, there would have to be a reporting function. So the national administrator would have to table regular reports with the CRTC which is consistent with other delegates of the Commission probably on an annual basis, and that would include budget information, reliability, and resilience information.

1340 And to Damian’s point, which I think is critical, an innovation agenda. So to what extent are we -- so we’ve shifted voice over to IP. That’s going to take three to five years. Beyond that, how are we doing in terms of text-based services, App-based services, other innovations that the Canadian population expects us to get on with sooner rather than later.

1341 COMMISSIONER MacDONALD: So given that time is of the essence and we want to get to the future of next-generation 9-1-1 as quickly as possible -- and there may be cost savings associated with getting there faster versus slower -- do you have any concerns that even the establishment of a new national body may end up delaying the process while we wait for a Commission determination from this proceeding, establish a new national body, appoint members, get them staffed, get them trained properly, issue the RFI, review responses, then go forward with an RFP?

1342 MR. COWLING: Ultimately, if you have a national standard -- so you do start at the top -- I think you’re going to enhance the efficiency and timeliness of implementation. And I think the U.S. experience highlights the risk of doing otherwise, where you don’t have a national standard and you have a bunch of competing standards and potentially interoperability issues.

1343 I think it’s very important that we get this right. It concerns me that we yet still don’t have a handle on what this will cost. So I agree that we want to move with speed, but we also have to move forward prudently. And I think once we have that national standard in place, a lot of the falling pieces will fit within the puzzle.

1344 COMMISSIONER MacDONALD: Some of the ILECs have noted that they have a very strong and long-term relationship with all of the PSAPs across the country, a positive, you know, collaboration between those groups. Are you concerned that by moving to a new body that may or may not have those level of deep relationships that there may be some pushback at the PSAP level or may take longer to move forward with NG9-1-1?

1345 MR. COWLAND: Those may be challenges but I think they can be overcome. The reality is that the ecosystem and the players within the ecosystem will evolve. Just as the current system does engage other TSPs, it will have to engage resellers at some point and will have to engage emerging service providers. The ILECs will be part of the conversation as will the PSAPs.

1346 And it’s clear from the record that when we’re talking about NG9-1-1 and the equipment providers, for example, for the ESInet -- however it’s properly pronounced -- those are new players in the ecosystem. This isn’t something that is part of the legacy system. This is brand new.

1347 So by definition, new relationships will be formed, will have to be formed. And we’re confident that actually the proposal that we have, which is to set up this administrator, is going to facilitate relationships rather than undermine relationships.

1348 COMMISSIONER MacDONALD: In your submission from May, you advocated for the Commission -- I’ll read it here -- “to establish at least one national geo-diverse and redundant ESInet.”

1349 Can you unpack that for me a little bit? Do you view that as being one network owned and managed by one provider, or do you see that as being one network that is created from multiple perhaps more regionally based or provincially based networks?

1350 MR. POLTZ: I think our proposal allows for either scenario. I think if you want to get the efficiency and increase the ability of that network to evolve and to operate, it might be easier with one provider providing that network across the country with multiple geo-redundant cores across the network.

1351 However, if that happens to be two providers because, you know, there’s a desire to have two providers involved for whatever reasons it can certainly be that as well. And we would envision that happening as those providers have their geo-diverse cores. However, all TSPs or anyone who wants to connect to one of the two, or preferably it would be both of them, is able to connect to both of them in a very resilient fashion. So we think that might even -- you know, that might potentially another alternative.

1352 The two networks then would be able to cover for each other so to speak. They would each be authoritative, you may say, for some part of the country, but they would be able to provide services nationally as well when it comes to interconnection and when it comes to the delivery of those 9-1-1 calls to cover for each other. So I think either scenario is possible.

1353 However, if you go beyond two we would advocate that you might -- well, you would lose many of the efficiencies that we talk about here around interoperability, economies of scale, clear national standards, improving resiliency, reducing complexity, et cetera.

1354 COMMISSIONER MacDONALD: As a networking expert, maybe you can help me understand. Obviously even just with one provider, a number of steps can be taken to ensure that backups are in place and the reliability and the resiliency is there be it to diverse fiber routes, be it homing back to different COs or head-ins.

1355 Can the required amount of reliability and resiliency be accomplished having these services on one network or is it better to have two totally diverse and separate networks operated by two providers that are then interconnected?

1356 MR. POLTZ: Well, it’s our opinion that generally a shift to IP -- and I think we actually heard this earlier today brought up some of the intervenors, but a shift to IP absolutely should increase their resiliency of the network by allowing the network to flow around the different issues and to deal with network outages.

1357 The NENA i3 Standard, itself, is -- you know, resiliency and reliability is at the core of that standard and any proposal that would go forward, we would envision, will have very geo -- very well-separated core infrastructure that would be highly resilient, even in the event of a large, potentially provincial, outage, many of which, you know, we’ve been exposed to, certainly in Alberta.

1358 So we think that the resiliency piece could actually potentially be improved by this shift and that having a national approach to it, as long as the standards are clear and that mandate is set up front, is -- could be a very effective way of meeting that requirement.

1359 COMMISSIONER MacDONALD: Can you unpack for me a little bit why you’re of the opinion that one or maybe two providers, if they’re consolidated into a smaller number of ESInet providers, will lower the costs? I mean I get that, you know, there would be some economies of scale, you know, back-end support maybe simplified, but no one provider in the country will be able to, at least on their own facilities, reach all of the PSAPs, for example, so there’ll be a significant third-party component in there which I would think would drive up the cost to deliver some of those services, especially in the last mile of connectivity.

1360 So can you share your thoughts on why you think the costs would actually be reduced?

1361 MR. POLTZ: Sure. Well, I can speak to the core components; I’m not sure if I can speak to the network infrastructure pieces and the costs involved there. But certainly our belief is that the deployment of next-generation core services is going to be quite costly. And if you’re talking about replicating that four or five times and each time having very diverse core infrastructure, that cost is going to significantly increase, right.

1362 So the reduction in the number of core sites, we believe, would be the most optimal path forward, especially because, in our understanding, the next-gen 9-1-1 infrastructure that’s available today is able to scale significantly; and the more you scale it, the more cost effective it becomes. So that’s one aspect that we think is quite critical.

1363 Secondly, the interoperability efforts and the costs of setting up the processes within each of those ESInets would be, you know, again reduced. If you only have to do one ESInet, or maybe two, then you don’t have to replicate all that process effort because there’s a ton of process and database construction and effort that goes into the building of this infrastructure. And then beyond that, the maintenance of that infrastructure as well, you have to replicate, again, all those teams and all those people and all those processes to enable that.

1364 So we believe that shrinking and consolidating our effort is -- could be an effective way to reduce the cost and to, furthermore, evolve the network more quickly. So when it comes time to evolve and to deploy the next iteration, again you’d have to repeat that across all those ESInets and again incur significant interop costs and everything else to make sure it’s successful.

1365 On the network infrastructure fronts ---

1366 MR. COWLING: I was just going to follow up on the next-generation prospect. There’s a -- at some point we have to start talking about emerging service providers and them joining this ecosystem. And that’s not going to be an easy task; they’re not familiar with 9-1-1 system. There have been questions about trusted partners and maybe not trusted partners but I think regardless of what occurs, there’s going to have to be some education.

1367 So if this is done at a centralized -- in a centralized way, that education process will be quicker and more accessible to those emerging access -- emerging network providers -- emerging access providers.

1368 And then if we also think about the education of the public -- and I think it’s -- several parties made this point today, and I think it was Telus that commented on the need for this to be habitual. In order for that to be ingrained in the Canadian psyche, there’s going to have to be a fairly rigorous campaign around these things.

1369 And again, I think you’re going to have efficiencies if you can start with a national campaign that’s talking about a national standard and can -- obviously, a huge part of it is going to be local but you start with the national. Our proposition would be that that will yield more efficiencies than the converse.

1370 COMMISSIONER MacDONALD: So if cost efficiencies can be found, does that type of model also -- or have the -- does it create -- have the potential to create problems from a network-support standpoint.

1371 If I’m thinking of one national provider, they may be contracting or purchasing last-mile access from Bell and Bell Aliant and Rogers and Telus and yourselves, just depending on who has network where in the country.

1372 Notwithstanding there are carrier-to-carrier arrangements to manage those types of arrangements, does it create a problem in supporting or detecting a failure on the network, or the scenario we heard about from one of the PSAPs earlier today where the backhoe digs up the pipe going in -- or the conduit going into a PSAP centre and causes an unplanned outage?

1373 MR. POLTZ: I certainly think that having that centralized and having, you know, the opportunity to have -- the beauty about the next-gen 9-1-1 system is that now we can have multiple links into that call centre. So not only can you have a fibre feeding it but you can also back that up with some kind of wireless solution. So just that alone, I think, will solve many of the challenges that PSAPs face today, just having that functionality.

1374 And does having a particular operator deliver both of those solutions in a footprint; does that make the cost significantly higher? I don’t know. I don’t think so.

1375 I think the resiliency and the protection of wireless, or whatever technology you choose, that’s really what’s going to improve the effectiveness of those next-gen 9-1-1 systems. So I see it as a -- not necessarily a challenge but certainly an opportunity to further advance the system.

1376 MR. COWLING: And in terms of the network connectivity, I think the biggest challenge of next-generation 9-1-1 is the core. The network connectivity exists; it may need to be upgraded for purposes of resiliency and reliability and security but we’re not talking about builds.

1377 And ultimately, the right answer will come through the RFP process. You will have bidders who can do the job most efficiently, taking into account the specs, the needs, what we expect the standard to be for consumers, and that will answer the question, we think.

1378 COMMISSIONER MacDONALD: With respect to the RFP, I mean, obviously you’re advocating that we don’t just expand the mandate of the ILECs that are currently providing 9-1-1 services to then upgrade to include next-generation 9-1-1. You would not see a problem, though, if one or more of those existing ILECs that are providing the service responded to, and won, such an RFP, would you?

1379 MR. COWLING: No, we would expect them to be there and, as we said in the opening remarks, they may be the most suitable candidate.

1380 COMMISSIONER MacDONALD: Do you have any concern that -- I mean RFPs are great, especially when multiple people -- multiple parties have an interest in providing the service. Are you at all concerned that at the end of the day we may go through this lengthy process and only one bid is received, or only a couple of bids are received?

1381 MR. COWLING: No, and I think there’s health in the process. I think the process will yield a lot of information about costs, standards, what the specs should be.

1382 And I think the process will also inherently have a drive for innovation and that’s why we’re -- why we feel so passionately about the national NG9-1-1 administrator is they will be overseeing that process and ensuring that once we complete the transition, which is -- it sounds simple but it’s not, transitioning Voice over to IP -- then we can start talking about the more ambitious goal of apps, Text-to-9-1-1, et cetera.

1383 So I think this is going to be a helpful, healthy process.

1384 MR. POLTZ: And I'll just add just to that, to Paul's comments, by saying that in our experience, a well-organized and efficient and effectively implemented RFI and RFP really helps articulate what options we have and helps articulate what priorities we're going to want to pursue in the development of that network, the timeline involved, and the final state of where we want to end up in the short and long term.

1385 So in our experience, it's always been a very beneficial thing to do to clearly articulate, for us, where we're going and what it's going to cost and add that transparency as well.

1386 COMMISSIONER MacDONALD: There was a time when one of the most dangerous places on the east coast was standing between me and an RFP that had just hit the street, so I see value in the RFP, but what recourse would this national body have if only one bid was received? Where does that leave us?

1387 MR. COWLING: If one bid is received, again, I think you're ---

1388 COMMISSIONER MacDONALD: Which may or may not be competitive.

1389 MR. COWLING: Which may or may not be competitive, but it's -- I think that's why the RFI process is critical as well. And based on what we've learned in terms of vendors and other potential participants, we think there's potential for other bidders. And the structure of the industry is a little bit -- I query whether TELUS or Bell would want to be national providers. I don't know, but there could be competition there as well.

1390 COMMISSIONER MacDONALD: You have extensive conversations with other industry players. Are you aware of any other groups, other than the current ILECs, that would be interested in responding to that RFI or RFP?

1391 MR. POLTZ: Well, we certainly know of groups who would be significantly participating or be willing to respond and provide pieces of the infrastructure, like the next-gen core services. Those are typically provided by existing players in the market today, so those guys, I'm sure, would be willing to come to the market.

1392 And in other places, in other markets, we have seen non-ILEC bidders come in and bid on the construction of ESInets, albeit regional ESInets. However -- so we think that may happen as well.

1393 But again, you know, we're certainly not against the idea of the ILECs bidding and for having one or multiple ESInets as well. We still see that as an opportunity as well.

1394 COMMISSIONER MacDONALD: I know you're with Shaw's regulatory team, not their business development team, but do you believe Shaw would have any interest in playing in this field and becoming either a regional or national ESInet provider?

1395 MR. POLTZ: Well, I am actually on the network side, so I can tell you that Shaw is definitely a connectivity company, right? We provide connectivity and we provide great reliable networks, so certainly, if it comes to providing connectivity pieces for this kind of infrastructure, I think that's certainly something we would be willing to participate in with someone else.

1396 However, currently, we don’t have the business model to really support the -- what it takes to support a 9-1-1 infrastructure, the services of that infrastructure, right, the core services that we're talking about here. So that would be something I couldn't answer myself.

1397 MR. COWLING: I would say we wouldn't see ourselves as strong candidates to bid on the SEnet or ESInet functionality. That's not our expertise, so it's unlikely. The connectivity piece is one thing, but the core systems that we're talking about here, I think it's unlikely that we would be putting our names in the hat.

1398 COMMISSIONER MacDONALD: How much of a deterrent is it for companies and organizations coming forward to respond to such an RFI or an RFP? How much of a deterrent is it that the cost to failure is so significant? If a call is dropped, if there's a network outage, it has the potential to do tremendous damage to a company's brand if they were to step up and then drop the ball. Do you think that would be a significant deterrent for companies to respond to the RFP?

1399 MR. COWLING: I think it separates the wheat from the chaff. And the other party that would be accountable in this case is the administrator. I think we would expect the administrator to have some oversight of that to make sure that there's sufficient resiliency of the liability to substantially mitigate that risk.

1400 COMMISSIONER MacDONALD: Okay. Again, in your May submission, you state that we should establish a national location verification database containing the master street address guide for all regions of Canada. What benefits are there to having one database containing all of that information? Are the benefits strictly financial?

1401 MS. SNOW: I think when we looked at this, we looked at the various ILECs and the various location verification addresses or the SAG, the MSAG information that they have, and we looked at the NENA i3 architecture and the location verification functionality that happens during that call process or before carriers update their location information servers. It just -- it seemed that it would be better to have that as a national database that carriers or TSPs could check their reliability or their information before putting it into their LAS. It just seemed that it would be more appropriate to have that as a national centralized function rather than having to query multiple databases based on ILEC footprints.

1402 MR. COWLING: And under the current legacy model, there's different standards, so this would be a uniform standard, which, to your point, would enhance efficiency but also enhance effectiveness.

1403 COMMISSIONER MacDONALD: You mentioned earlier, obviously, starting with the transition of voice calls over to an IP next generation network, once that's accomplished, do you have any thoughts on where the focus should be, on what new forms of communication you should enable? You obviously communicate with your customer base through multiple different platforms. What are you seeing from them? How do Canadians want to interact today and where should our focus be?

1404 MR. COWLING: I think we have thoughts on that that Damian will talk to, but I will say that that would -- that question would be one that would be beautifully handled, in our view, by the national NG9-1-1 administrator once we're done with transition of voice at -- and that will not be a short process. We'll do it as quickly as we can, but then what's the priority and as technology changes, are we making sure that we're keeping up with those changes, but ---

1405 MR. POLTZ: Yeah, I completely agree with Paul. I think potentially several wireless operators may be in a position to -- those that have IMS, IP-enabled infrastructure deployed -- may be in a position to add multi media into calls very quickly, things that were discussed around pictures and messaging and potentially things like RTT.

1406 However, we're not in a position really to say which should be the priority, what should be next, which will be the most feasible to do, which will add the most value. That is exactly, I would agree with Paul, why we are proposing a national administrator to help drive that to see what is going to provide the most value for Canadians and what makes the most sense to deliver from a technology perspective as well.

1407 COMMISSIONER MacDONALD: You mentioned a couple of minutes ago that obviously Shaw is a networking company. From your experience, because you would have transitioned many customers from your older platforms to newer platforms; you bring people onto your network from other service providers. Perhaps at times even some customers may choose to move away from you to another provider so they're exiting your network.

1408 When you're doing these upgrades, and when you're trying to migrate services, is it easier or less expensive to migrate services when they're staying -- when the end user is staying on the same service provider's network? Does it create any efficiencies if you're migrating from a legacy platform to a next-generation platform on the same service provider versus transitioning to a whole new provider?

1409 MR. POLTZ: Well, it certainly, in my experience, the transition of customers from different platforms, from legacy to new, even within our own infrastructure, is quite challenging, because you have to be very, very careful in how you do things like that. I mean, customers have a low -- a sensitivity for you breaking their services or you know, messing things up. And when it comes to next-gen 9-1-1, that's -- it's just not an option, right, so you absolutely do have to be very careful and mindful of it, which is again, one of the reasons why we believe that things like a centralized location verification function and centralized GIS approach and a national standard would help avoid some of the issues that I think we experience even today.

1410 So then not to put words in your mouth, but you would be of the view that it is easier and faster and more efficient to build a new network and then transition customers to it than it would be for the same provider to try and support those users while also deploying next-gen services?

1411 MR. POLTZ: That’s a tough one. I’m not sure I can comment on that.

1412 COMMISSIONER MacDONALD: Maybe you want to think about it and ---

1413 MR. POLTZ: Yeah.

1414 COMMISSIONER MacDONALD: --- come back to us?

1415 MR. POLTZ: I don’t know. Do you guys have any thoughts?

1416 MR. COWLING: I was just going to say yeah, certainly what we’re envisioning here is a new build from a next-generation 9-1-1 perspective and we don’t -- this is inferring a few things, but we don’t see any efficiencies and leveraging off of the legacy model given that we’re talking about a static circuit-switch-based platform versus an IP-based platform. And that might be assuming something in your question, but ---

1417 COMMISSIONER MacDONALD: Yeah. Well, if we are talking about a network that doesn’t leverage any of the current infrastructure that’s in place, for example, does that reduce the risk of an outage, as an example, if it’s a new network versus trying to upgrade and leverage infrastructure that may already be in place?

1418 MR. POLTZ: I’m not sure we can answer that question. I think it would really depend. Certainly we see a lot of improvements with the NENA i3 standard in terms of, you know, data consistency and data management and having one approach. So I think overall the migration to that infrastructure will improve the customer experience when it comes to emergency services. Whether that infrastructure leverages existing core services -- I’m not sure how much of that exists today. I don’t think we’re in a position to answer that since we do not ourselves host those existing core services today.

1419 COMMISSIONER MacDONALD: Okay, fair enough.

1420 Bell noted in their intervention that because they already have connections in place at all of the PSAPs that they could be improved upon to deliver NG9-1-1 services and are upgradeable if and when demand warrants it. You don’t necessarily see that as a huge advantage in the grand scheme of things, then?

1421 MR. COWLING: Well, it depends on what we’re talking about. It’s unclear about what those facilities actually are. If they’re IP-based facilities then obviously they should be leveraged for the new system. But that’s a little bit of a mystery to us as to how those were paid for, whether they were paid for under the current tariffs or what have you. But if they are IP facilities that can handle the security, resiliency, and reliability standards for the next-generation 9-1-1 model that we’re contemplating, then absolutely they should be leveraged. But those aren’t legacy facilities if that’s the case.

1422 COMMISSIONER MacDONALD: But I mean, they’ve upgraded multiple facilities to be able to operate in a text environment. So that’s where that suggestion originally came from.

1423 But I guess that touches on an interesting point that I was going to get to a little bit later and it’s around leveraging existing facilities. What happens at the end of an RFP? You select a vendor for 5 years, 10 years, whatever the term may be. What happens to all of that infrastructure at the end of the contract term? Does the national body then go out for another RFP? Should that infrastructure that’s been put in place continue to be leveraged?

1424 If it’s own by Shaw, for example, and you don’t win the next RFP, should that infrastructure automatically be leveraged by the future provider? How do you see that working?

1425 MR. COWLING: There is both the core service, which involves database and routing, not connectivity per se, and then there’s connectivity. And with respect to the former, the ESInet provider, the core function of the ESInet provider, we would envision that the administrator would have to have some residual ability to take control of those assets for a variety of reasons, not just the RFP ending. But if something happens to the ESInet provider, for example, they would have to be able to assume control over those assets.

1426 On the connectivity side, a lot of those facilities will be procured either through leases or they will be the ESInet providers. If it is the ILEC that’s bidding, then they will have their own facilities that the administrator would again have to have recourse to be able to use it. But I think we see that as probably a lease -- could be a lease. It doesn’t necessarily have to be ownership over that connectivity infrastructure.

1427 COMMISSIONER MacDONALD: Okay. We’ll get back to that in a few minutes.

1428 Under the current 9-1-1 framework, the Commission has established trusted entities that can connect directly into 9-1-1 networks. Moving forward I think it’s fair to assume there will be many more entities that want to connect to next-generation 9-1-1. Do you see us or a national body -- or a new national body rather -- dictating what that list of -- who’s on that list of trusted parties? And are there any non-trustworthy parties that should automatically be not included in that list once it’s established?

1429 MR. COWLING: Yes. The national administrator or the CRTC would need to vet that list and approve that list. I don’t think there’s any parties today that we would see as non-trusted, but most parties beyond the scope of TSPs, PSAPs are not educated on 9-1-1, let along next-generation 9-1-1. So there would have to be an education process before they are brought into the fold.

1430 MR. POLTZ: I would add to that just by saying yeah, we agree that security is a critical component to this and the NENA i3 architecture has many provisions for this kind of thing with, you know, border control points and DMZs dictating how to enable connectivity between ESInet and between different providers who wish to provide data into that network.

1431 So I think certainly making sure that’s part of the national standards I think would be critical. And then of course the administrator might be able to assist in determining, you know, which trusted providers of data can also bring information in.

1432 However, I do believe, and I think I heard it this morning, that some PSAPs may wish to go and obtain their own data from local data sources outside of the ESInet. And if that occurs, that’s another option for them to obtain it as well.

1433 COMMISSIONER MacDONALD: You mentioned security. Obviously that’s a huge component. Are there other criteria that perhaps should be included when evaluating who should be on that trusted list? Does Canadian ownership matter? Does the fact that the entity wanting to connect, should they perhaps need to have a minimum number of subscribers in the country? What are your thoughts on other criteria that could come into play?

1434 MR. COWLING: Security would be primary. But again, I think it would go back to the platform that we’re talking about and whether that platform meets the habitual standard. I don’t think we want to rush ourselves into allowing for access to 9-1-1 for a platform that isn’t well known and well-tested. So that’s certainly another element that would have to be satisfied before those new parties could be brought into the fold.

1435 COMMISSIONER MacDONALD: So that sort of answers my next question. But when do you think those policies should be established? You said they could either be established by the Commission or by this new national coordinating body. Do you see those policies being established as a result of the RFI responses that come back? Do you see them working their way into the RFP? Do you see us coming out of this proceeding, when we issue our decision, having set some of those policies?

1436 MR. COWLING: The sequence would be we need to get voice transitioned over to IP. That’s the first task. And that would be the first task of the administrator through the RFI and RFP process. So I think we see this down the line.

1437 It could certainly be part of the RFI and RFP process how do we -- once we’ve done X, then how do we get these other emerging providers onto the network as soon as we can but, yes, I see it done through the iterative process that the administrator gets engaged in.

1438 COMMISSIONER MacDONALD: Obviously the standard today is that 9-1-1 network providers must take all reasonable measures to ensure that their 9-1-1 networks are reliable, resilient to the maximum extent feasible. Do you see that provision being adequate as we move forward into an IP-based next-generation 9-1-1, or do you think that additional measures or language will need to be adopted? And if so, what?

1439 MR. COWLING: The appeal of that standard is it’s flexible, and I think it does apply to NG9-1-1. There’s also room for adding some specifications there to what that means. And we’ve talked a lot about this RFI and developing a spec for what we mean by NG9-1-1. That could be part of putting some additional detail around that standard through that process; it’s something we would support.

1440 But, again, I would just echo the thought I had earlier. It isn’t a bad standard, and it would be helpful in an NG9-1-1 environment.

1441 COMMISSIONER MacDONALD: Do you envision that standard only being imposed on the 9-1-1 network providers, or should it be imposed more broadly perhaps to entities looking to connect to 9-1-1 or to the 9-1-1 network or to other bodies?

1442 MR. COWLING: It would apply to the accountability, and I think the accountability would lie with the NG9-1-1 provider so that would be the scope of its application.

1443 COMMISSIONER MacDONALD: Okay, thanks.

1444 A lot of the cable companies have raised concerns with respect to the costs associated with the current ILEC-provided 9-1-1 network, and other intervenors have expressed concerns around a lack of transparency with respect to some of those rates and other measures.

1445 In Shaw’s view, are the current tariffed rates that are being charged too high?

1446 MR. COWLING: As we said in our opening remarks, we think they should be reviewed. I don’t think we can say confidently whether they’re too high or they’re -- they need to be reviewed. They seem high to us given that they were talking about obsolete equipment. And we’re not aware of what costs are driving this level of funding so they need to be reviewed.

1447 But I guess the short answer to your question is, yes, we think they’re too high.

1448 COMMISSIONER MacDONALD: So just so I’m clear, many of your concerns would be alleviated if new cost studies were done and a full new costing exercise was undertaken with respect to the current system?

1449 MS. SNOW: I think it would definitely alleviate some of our cost concerns, but ultimately our concerns with respect to NG9-1-1 go beyond cost. We’re concerned with giving any sort of model for ILECs or sticking within the footprints of the ILECs. We also raised concerns about including innovation and evolving the network.

1450 So it goes beyond just concerns that we might have about costs. So a review of the costs would be helpful, but again we wouldn’t agree that that would alleviate all of our concerns about the ILEC model for NG9-1-1.

1451 COMMISSIONER MacDONALD: I understand everyone is very hesitant to put any type of cost associated with this network out there because largely we don’t know what it’s going to look like. We don’t know what the end state is going to be. But if you had to guess, can you put it in a zone for me? Fifty (50) percent more than the -- will next-generation 9-1-1 cost 50 percent more than the current system, 100 percent more?

1452 MR. COWLING: Well, we’re talking about two types of costs; capital costs to build the core system, and then the ongoing operational costs. I would expect the -- and Damian as the network expert will correct me if I’m wrong, but I would expect the operational costs to be lower and I would expect the capital costs to be -- and I’m talking about the current annual aggregate payments -- and I would expect the capital costs to be lower than any single year’s aggregate annual payments, if you follow me.

1453 COMMISSIONER MacDONALD: Okay. That being the case, what are going to be the biggest cost drivers from a capital standpoint?

1454 MR. POLTZ: So from our understanding, we believe that it’s the construction of those next-generation core services. So again, it’s the cores and the construction of those cores. And the population of them with data, and the deployment of them geographically across the country that is likely going to be the largest capital expense.

1455 We do hope, and we spoke to it a little bit here, that the network infrastructure will be -- might be available already to many of the PSAPs. And hopefully that will be able to be leveraged, potentially with some upgrades as well. So really when we’re talking about the costing, I think it’s that core infrastructure that needs to be upgraded. And hopefully the underlying network is already of sufficient quality that it will be close to meeting the NENA i3 specification for the ESInet.

1456 COMMISSIONER MacDONALD: With respect to costs, some may struggle with the thought that costs will necessarily go down if we go with the national consortium national body issuing an RFP, because if someone is responding to an RFP, one would assume that they’re doing it to turn a profit whereas the current system really isn’t structured in such a way that anyone really looks -- I don’t think -- at providing 9-1-1 service as a cash cow.

1457 So are you concerned that by going the route of an RFP that costs may not actually be reduced?

1458 MR. COWLING: No. I think there are candidates in the ecosystem who will want to do this service, and there is -- and whether they’re the ILECs or someone else, and there is an interest from the ILECs in doing this, then we’ll see that reflected in the RFP.

1459 COMMISSIONER MacDONALD: Does it raise concerns that when whoever is responding to the RFP that they’re going to put a price tag on this network without outlining what their costs actually are to provide the solution? Does that create a concern for you with respect to transparency? Because there’s a certain FUD factor in all of this -- fear, uncertainty, and doubt -- and that often leads to higher price points.

1460 MR. COWLING: There’s considerable flexibility within the administrator to define the requirements of the RFP, and you could get quite transparent in terms of what bidders are required to submit. And one of the reasons why the RFI is going to be helpful is because you can test the appetite of the market to participate in the RFP and you can get a preliminary sense of those costs.

1461 If you’re concerned about transparency and you’re concerned about whether you’re getting good value, you can design an RFP process that addresses those concerns.

1462 COMMISSIONER MacDONALD: And you would say that dependent on how that RFP is designed that that may actually add to the level of transparency versus, for example, the current costing process that’s in place?

1463 MR. COWLING: Yes.

1464 COMMISSIONER MacDONALD: If as a requirement of the RFP that costing information had to be provided to the national body, would you see that group holding that costing information in confidence or would you see them making that costing information public?

1465 MR. COWLING: I don’t think it would be necessary to enhance the transparency of the system in order to make it public. It’s competitively sensitive information. You have a body there that’s assessing the RFP, and it’s required this additional costing information. They’re going to have competing bids hopefully, as many, you know, as will come forward.

1466 And I do think you have -- you still have a transparency element there because you have oversight by a body, and the RFP process and the requirements of it will also be transparent.

1467 COMMISSIONER MacDONALD: How could or should the RFP be structured to avoid future scope creep? I'm thinking it’s the long-term RFP, 10 years; there may be a new form of communication that right now is still in its infancy and not on our radar, but conceivably next-generation 9-1-1 may want to expand at some point in the future to be able to accept that form of communication.

1468 How do you envision whatever the body is or bodies that are selected to provide the networks coming back and requesting more money as their networks are augmented to provide interconnections with new forms of communication?

1469 MR. COWLING: Yeah, I think when we were envisioning the mandate of the administrator as having this drive to innovate, one of the accountabilities of the administrator will to be -- will be to require actually the opposite. So you've done your RFP, you've scoped out the ESInet core, you've costed it, you’ve done that, and layered on top of that, I would expect the administrator to then have requirements to innovate beyond that. So I'm not sure we would envision this as a scope creep, an ALI coming back for more money to do more things, as let's do more with what you’ve already got.

1470 COMMISSIONER MacDONALD: Okay. In your opening remarks, you agreed with other parties that it would be appropriate for funding to come from the federal government to fund the move to NG9-1-1. Let's assume that's not going to happen, for the purposes of this conversation. How and when do you see providers needing to contribute?

1471 Obviously, any provider that, you know, on their network that you can make a 9-1-1 call today probably should be in there. How do you see us moving forward into a situation where no one -- where someone trying to connect to 9-1-1 may not make a traditional telephone call at all; they may Skype into a PSAP, for example, via their internet connection.

1472 MS. SNOW: Right. So as we said in our opening remarks, our initial transition phase we view as being voice focused. And I want to clarify, when we're talking about voice focused at this point in time, we're not leaving out, you know, the Text-to-9-1-1 accessibility options. That is included in anything tied to a telephone number right now is what we're envisioning to be included in the transitional period.

1473 After that, we thing the NG9-1-1 administrator would look at new services: video calling or over the top, an App, those sorts of communications. And it would be then that we would see maybe the funding model would have to be revisited if we're going to allow thing or communication types that are not tied to a telephone number, then we need to look at how do we include that and how do we fund for that?

1474 So it would be after the transition period and when we're looking at those new types of communications methods that we would look at the funding model again.

1475 COMMISSIONER MacDONALD: How would that be captured from a billing standpoint? And I think about a scenario where my home phone may be provided by Bell Aliant, just to use the local carrier where I live, and I would be paying a 9-1-1 fee to be able to call in, but my internet connection may be through Xplornet, and those providers would have no visibility into what other services were going into that house. Under that type of scenario, would I be charged twice for connecting into 9-1-1, because in that example, Xplornet would have no idea that I also have the ability to make a traditional call into 9-1-1.

1476 MS. SNOW: Yes, it would work that way. If the funding model were to include internet revenues, then yes, you would probably be charged twice in that case. And if you think about it in a way of at one point in time, you may make an emergency call over your landline phone or you may be at home and on your WiFi connection through Xplornet or somebody else in your home is using that connection and they choose to make an emergency call on that, then they're using your internet connection.

1477 So when we get into that world where there is a new communication method that might use an internet service like that, then it would be reasonable for Canadians to probably pay through both platforms. But as we've said in our opening remarks, right now it is tied just to working telephone numbers, so we're not looking at that funding model at this juncture.

1478 COMMISSIONER MacDONALD: Just to stay on that topic, you know, if we do, in the future, move forward with PSAPs receiving notification or emergency responders receiving notification through telematics, how would you see that being funded? My -- I crash my car in the middle of the night. My airbags deploy. The PSAP gets notification. How would you see that cost structure working?

1479 MS. SNOW: Under our proposal with the consortium behind the administrator, where TSPs are members of the consortium and pay in on working telephone numbers and possibly internet, when we get there, we also envision a different class of membership in that consortium, which would be alternative telemetrics providers, for example. So in that case, they would be a membership in the consortium and they would pay a membership fee for being part of the ecosystem of 9-1-1. So there would be some sort of an annual or monthly fee for that shareholder type in the consortium, and that funding would go towards the next-generation 9-1-1 system.

1480 COMMISSIONER MacDONALD: Forgive my ignorance, but is Shaw active in the machine-to-machine business today or is that -- would that fall more under Freedom?

1481 MR. POLTZ: I think the correct answer here is today that we don’t offer a significant number of machine-to-machine services by any service that I'm aware of. That would fall into that kind of in other things category, other than, of course, our broadband service today. And I don’t think Freedom offers that today as well.

1482 Now, certainly, we do have many different kinds of business services, but I don’t believe one specifically targeted at machine-to-machine is part of our offering.

1483 COMMISSIONER MacDONALD: Okay. So I'll skip over my next couple of questions on that front.

1484 I wonder if you'd like to comment on the flow of information that may one day be received through the internet of things. I mention notification that my air bags have been deployed. Another one may be that smoke alarms are going off in my house while I'm sitting here talking to you. What are your thoughts on -- in those types of situations, the PSAP being bypassed totally, and in the case of the car crash, the ambulance is automatically notified or in the case of a fire alarm going off, skip the PSAP and go directly to the fire department?

1485 Are there any concerns or benefits that could be derived from that type of structure?

1486 MS. SNOW: I think we heard earlier today the City of Calgary discussed this. And when they spoke about -- I think it was OnStar and they said, you know, only one percent of the calls after they're triaged actually go to the PSAPs. I think that there would be a level of concern if those floodgates were opened and all calls were suddenly being triaged by the PSAPs. So there would be that concern.

1487 It would only be those calls -- or I think we envision that it would only be those calls that would be directly attributed to being -- to requiring emergency assistance that would actually ever bypass and go directly to the PSAP. I don't think we would want to see them triaging every car accident or flat tire situation.

1488 COMMISSIONER MacDONALD: Yeah. In Rogers' intervention, they suggested the service providers not be required to undertake the upgrades to support NG9-1-1 services until the PSAPs are actually ready to operate and are connected into the NG9-1-1 environment. Can you comment on that and perhaps for my own education, provide a bit of a timeline, if the PSAP was ready, how long it would take a company like Shaw to perform the necessary upgrades on your end to help facilitate those calls?

1489 I’m going to turn it over to Damian to talk about our own readiness. I think the PSAP readiness is going to be the gating item -- in particular, IP capability -- as I think we’re -- from Shaw’s end, I’ll turn it over to Damian but I think we’re the most (off-mic).

1490 MR. POLTZ: Yeah, absolutely. So we are certainly keen to look at and transition our systems to next-generation 9-1-1. On the wireline side, I’m speaking to here. On the wireline side we do have a system that is possible to upgrade to NG9-1-1, being an IP system. So that kind of effort, based on our internal research -- now, we haven’t fully costed it and scoped it out but if the ESInet is ready to take our connection, it would probably take us about 12 to 24 months to migrate our infrastructure over to it.

1491 Now, that includes everything from, you know, doing the RFP, if required; upgrading our software; making sure the hardware’s ready; doing all the interop testing because significant interop testing is required between us, the ESInet, and the PSAP; and making sure everything flows, making sure our processes, our internal processes on how to verify addresses -- everything is ready; all to the actually migration of customers to make sure that they go to that next-gen 9-1-1 service.

1492 So 12 to 24 months based on our current estimation without, of course, doing a deep dive into it because it requires several components that still aren’t there to be ready.

1493 COMMISSIONER MacDONALD: So in your mind, then, some type of coordination, perhaps through the national body, would need to be done to ensure that, you know, if we wanted to avoid the situation whereby service providers are waiting on PSAPs to upgrade, we also want to make that the coordination is happening to make sure PSAPs aren’t on the other end waiting for service providers to perform their necessary upgrades?

1494 MR. POLTZ: Absolutely, and I think that just reinforces the whole statement around why national coordination is so important. Because if we can see a clear roadmap nationally of where things are going and how the standards are going to align, we can start the work early and start looking at what it will take to make our systems ready, and budget the capital it will take to upgrade out infrastructure, and aim for a standard.

1495 If we know that that’s exactly what the PSAPs are doing and, you know, we’re all marching in the same direction, I think it’s a very valuable thing.

1496 COMMISSIONER MacDONALD: Our ability is obviously very limited to nudge PSAPs along into moving towards a next-generation 9-1-1. We don’t control their budgets; that’s up to other levels of government.

1497 With that said, do you have any thoughts on when we should be looking to, or if we should be looking to, set a sunset date on the existing 9-1-1 platform?

1498 MR. COWLING: Yeah, I think -- we’ve thought -- we’ve considered three to five years for the transition, so the sunset would follow soon after that. There would be no reason for it to stick around beyond that.

1499 There was talk earlier today of perhaps, this translation mechanism, the LNG -- or LNP, depending on whether you’re going to the PSAP or the TSP -- that would be a service that would have to be made available, and perhaps the costing of that could reflect an incentive for the PSAPs to shift over to IP and next-generation.

1500 COMMISSIONER MacDONALD: With respect to privacy, obviously next-gen 9-1-1 has the potential to harness and provide and manage a lot more information than the current environment does, potentially health records, for example, or other sensitive material.

1501 Do you think there’s certain types of information that the end-user should have to give their explicit consent to for that information to be stored and used by PSAPs and first responders?

1502 MR. COWLING: Yeah, I think anything beyond what we have in place today -- name, address, phone number -- would require explicit consent.

1503 COMMISSIONER MacDONALD: And should end-users have an opt-in or opt-out of any information that may be provided?

1504 MR. COWLING: Should the consent be on an opt-in or opt-out basis?

1505 COMMISSIONER MacDONALD: M’hm.

1506 MR. COWLING: Well, I think there’s a practical issue here, too. I mean, the delivery of that information is likely to be activated by the end-user, perhaps not necessarily. But I think if there’s -- either the end-user is deciding to send the video or whatever it may be or it should be on an opt-in basis. I don’t think we have strong views on that, whether it’s opt-in or opt-out, but some form of consent would be required.

1507 COMMISSIONER MacDONALD: Okay. And just one final question before I turn you back over to my colleagues. Do you have any experience with inclusive design of your products and services to meet the unique needs of Canadians with disabilities that you think would be useful information to have as we move forward and design a 9-1-1 -- NG9-1-1 network with the unique needs of Canadians with disabilities in mind?

1508 MS. SNOW: The great thing about the NG9-1-1 design set out by NENA i3 -- or the NENA i3 design -- is that it is inclusive of multiple communications types. It is flexible enough to evolve and we’ve seen so many different diverse communications, applications, and services that have come out in the last few years for persons with disabilities.

1509 I don’t think that we need to look at any particular drive. We just need to make sure that the NG9-1-1 system and platform that we put in place is inclusive and flexible and can include those innovations as we move forward so that nobody, regardless of their communications-type, is left behind as we transition to this new platform.

1510 COMMISSIONER MacDONALD: Perfect. Thank you very much. Those are my questions.

1511 THE CHAIRMAN: I don’t believe there are any other questions from my colleagues but I have a few before I turn you to legal.

1512 You mentioned that all TSPs should be required to be members of the new NG9-1-1 administrator. What about PSAPs; would they have to be also -- what would their role be with respect to that administrator?

1513 MR. COWLING: Yeah, we considered this. We would obviously want them at the table; we would invite to the table. We don’t see a mechanism for the Commission to compel them to come to the table but if this is the industry voice for next-generation 9-1-1, we think they would come to the table the same way that they came to the table when we designed Legacy 9-1-1.

1514 I mean there’s no jurisdictional mechanism to get them to cooperate with us today, just like there will not be in the next-generation world, so we would hope actually, it’s attractive to have this centralized body that they can -- that they can work with and that that would bring them to that table.

1515 THE CHAIRMAN: Would you see them on a Board of Directors as well?

1516 MR. COWLING: Yes.

1517 THE CHAIRMAN: Doesn’t that create inherent conflict-of-interest situations?

1518 MR. COWLING: Well, I think we do need to manage ---

1519 THE CHAIRMAN: Having been on the Canadian Television Fund where everybody was in a conflict, and sometimes a Board of 21, we were two in the room actually making decisions.

1520 MR. COWLING: The industry representation on the Board would also create a potential conflict of interest, and we did toss that around internally as well. We would have to have a Board that was representative of industry and other stakeholders, including PSAPs. And like any good Board, we would have governance principles that would require people to recuse themselves when they had material, apparent or actual conflicts of interest.

1521 COMMISSIONER MacDONALD: Right, although the Commission in the VRS proceeding -- or the follow-up one -- was particularly concerned about that potential conflict and did exclude certain people from even being considered as potential Board members. So isn’t that quite similar here when there are that many potential conflicts of interest that one has to stickhandle -- that at one point it becomes completely ineffective to add people to the Board?

1522 MR. COWLING: We’d have to go through an analysis on a case-by-case basis but I think, you know, there wouldn’t -- on the industry side, query how many of the industry members would actually come forward, for example, with bids in the RFP. I don’t know how many there would be so I think you’d get proper industry representation.

1523 And from a PSAP perspective, we’re talking about a (inaudible), perhaps, or, hopefully, one centralized voice, or -- from the PSAPs and whether or not they would have a veto or not. I would say they wouldn’t. So that would probably eliminate a conflict of interest there. We’d also want representation from accessibility groups to have a voice at the Board table as well.

1524 THE CHAIRMAN: In your presentation a little earlier you referred to section 46(2) of the Act?

1525 MR. COWLING: M’hm.

1526 THE CHAIRMAN: To my knowledge that might have been the first time that that provision was raised. Am I correct in that assumption?

1527 MR. COWLING: By us, yes, that’s correct.

1528 THE CHAIRMAN: Yes. So 46(2) is of course fed by section 46.1. I was wondering if you could help us, perhaps through an undertaking, better understand or try to demonstrate to what extent the proposed consortium would serve to facilitate the, and here I quote, “Interoperation of Canadian telecommunication networks,” which is a condition present in 46.1, as well as to demonstrate that the task that will be accomplished by this proposed consortium would amount to administration of operational systems relating to the functioning of telecommunication networks? Can you undertake to do that?

1529 MR. COWLING: Well, we’d like to do that through an undertaking if that’s okay?

1530 THE CHAIRMAN: Yeah, the 24^th of January?

1531 MR. COWLING: Yeah.

1532 UNDERTAKING

1533 THE CHAIRMAN: Thank you. Great.

1534 I’m going to bring you to another matter. And I asked earlier this question about burdens of proof. And you know, I often was thinking about the proceeding we had back last end of January, early February, on the future of the community channel. And of course in that proceeding there were parties that were questioning the historic stewardship of the community channels by BDUs -- well, cable companies mostly but let’s say BDUs for now. Some described that proposal as a radical solution.

1535 And back then Shaw provided evidence, and specifically at paragraph -- it was a long proceeding -- paragraph 10,914, I think it was in Volume 7. Mr. Elliot made a few comments about the fact that intervenors were proposing some radical solution. And then I’m quoting here:

1536 “Our view is that intervenors [that] have the burden of demonstrating that regulatory solutions and the creation of new funds are necessary or superior to the current balance…”

1537 Then he went on at paragraph 10,915:

1538 “Respectfully, the burden of justifying a new approach that serves the needs of Canadians has not been met.”

1539 That testimony was given on February 2^nd, Groundhog Day. I guess this isn’t Groundhog Day because you’re not taking the same position here? Or are you?

1540 Who has the burden of proving that the traditional ILEC-centric model for the network components is not the one to be addressed in the future and that we should go for what might be a change of course that is radical?

1541 MR. COWLING: Yeah, I’m not sure I agree that given that we are dealing with a brand new model -- and as we’ve said throughout our testimony, other than to the extent that we’re talking about IP-based facilities -- we’re not going to be leveraging the legacy TDM model for this new being. I’m not sure I fully agree that the burden of proof lies with us. I think our case would be that the burden of proof lies with the ILECs to demonstrate to Canadians that they are the best candidates to be the stewards for the next-generation 9-1-1 service, which in our view is very different from the legacy service.

1542 And that’s precisely why we’ve proposed the mechanisms we have, the RFI, the RFP. There’s process there. There’s some rigour to that process. We would like to see the transparency enhanced and we would like to see what options are available for Canadians. And through that process they may meet that burden of proof. That’s certainly possible. It’s probably likely. But we think that’s in the public interest given the nature of the change and the extent of the change and the complexity of the transition.

1543 THE CHAIRMAN: But there is a status quo ante, which there is as well, relationships, business practices, I mean, all of the sorts of things that don’t exist in manuals but very much exist in real life. So I put it to you that you’re in fact asking for a more fundamental change of the status quo than merely extending an ILEC-centric model.

1544 MR. COWLING: And we don’t dismiss the value of relationships. But we think there are new relationships that will develop through this next-generation model. And as we’ve discussed, the very fact that we’re going to have to create an ESInet core likely means the introduction of new relationships to the equation.

1545 THE CHAIRMAN: Okay, thank you.

1546 I think Legal has some questions.

1547 MR. BOWLES: Yes, thank you, Chair.

1548 Under your proposal you envisaged the consortium, amongst other tasks, selecting an NG9-1-1 provider or providers through an RFP process. And as you’re aware, the CRTC is tasked under the Telecom Act with ensuring that the rates charged for services are just and reasonable. And the Telecom Act further prohibits any carrier from providing a service to the public otherwise and in accordance with a tariff that’s been filed and approved by the Commission.

1549 Can you explain how your proposal is consistent with those statutory requirements?

1550 MR. COWLING: It has to do with whether or not we’re talking about connectivity or providing -- or whether we’re talking about the core system. To the extent we’re talking about the core system, database, routing functionality, the operating system that supports the interconnection networks, I’m not sure that’s the provision of telecommunications services by a telecommunications carrier for purposes of that rate provision. To the extent that we’re talking about connectivity, then we agree that section 25 would be engaged.

1551 MR. BOWLES: So with respect to the core aspects, to just be clear, are you suggesting that those elements satisfy the definition of “exempt transmission apparatus”?

1552 MR. COWLING: Yes. And I think we’ve said that on the record of the proceeding.

1553 MR. BOWLES: Okay. If I can move along.

1554 There was a discussion earlier with Commission MacDonald about adding new functionalities to -- or having the NG9-1-1 network being capable of supporting new functionalities. And that, if I understood you correctly, was sort of addressed by saying, “Well, the RFP and the eventual contractor would be assigned -- would be structured in such a way as to essentially attempt to preclude that.”

1555 But let’s just pause it for discussion purposes, that the CRTC mandates that TSPs provide their end-users with the ability to reach PSAPs through means of communication X. And that was not contemplated at all in the contract that is signed through the consortium with the retained NG9-1-1 provider.

1556 How would that change in the network that would be mandated, be dealt with with respect to a financing perspective? How would the consortium interact with the NG9-1-1 provider who one would assume would like to recover the costs associated with that new functionality that has to be installed?

1557 MR. COWLING: So are we talking about the connection between the TSPs and the ESInet provider? Is that ---

1558 MR. BOWLES: Well, at this point it’s a very hypothetical question. You can answer it both ways, I guess, if we’re just talking about the connection and the if we’re talking about the core aspects.

1559 MR. COWLING: Okay. So if we’re talking about the connections between the TSPs and the ESInet provider, you’re saying the CRTC may mandate those interconnections. So those costs presumably would be borne by the TSPs.

1560 MR. BOWLES: Okay.

1561 MR. COWLING: So the ESInet database and routing functionality, those costs would be recovered through the funding mechanism that we’ve described, which would essentially be an industry consortium funding mechanism. And then in the post-transition era, I’m not sure how that would change. Because I’m not sure we would envision new connectivity being required between the TSPs and the ESInet provider. But I may be missing a piece of the question.

1562 MR. BOWLES: No, no, that’s quite all right. But if changes were required to the ESInet components, how ---

1563 MR. COWLING: Well, then I think we’re into the ESInet provider world and that’s the industry funding mechanism. So to the extent we need to upgrade that core system for whatever reason, whether it’s through an innovation drive or for whatever reason we need -- say there’s a glitch that we need to repair -- then that would have to be dealt with in the contractual arrangements with the ESInet provider.

1564 And the costs, whether they’re inside or outside the scope of the RFP, would be borne by the industry consortium. It would be resolved contractually I suppose is what I’m saying there.

1565 MR. BOWLES: Would you not be stuck though with negotiating with a single partner?

1566 MR. COWLING: You could but, again, you’d probably want to scope out what’s in and what’s out from a reasonable incremental cost perspective. And if we’re talking about an ambitious new thing that wasn’t contemplated at the time of the RFI or the RFP, then probably the ESInet provider is within its rights to seek compensation for that.

1567 MR. BOWLES: Okay. Another question that touches a little bit on the funding. Reference was made to section 46.2 and therefore to 46.1. Now, to the best of my knowledge, the concept of funding is not at least explicitly dealt with in those sections. But the consortium that you’re discussing has a lot of funding-related tasks.

1568 If the Commission were to adopt that model, would that not require the Commission designating the consortium as a fund administrator under 46.5? And if not, why not?

1569 MR. COWLING: Well, I think -- and we’ll respond to this in the undertaking -- I think there’s some also some 46.3. And with respect to 46.5, it’s not as though we’re opposed to using 46.5. We’ve been very clear on the record that this would require -- in our opening remarks -- this would require the creation of a new fund, and that would require a follow on proceeding. We don’t think we have sufficient record on this proceeding to do that.

1570 And as Esther explained, we feel quite strongly that in the initial stages anyway that fund should be constituted based on levies on voice as opposed to Internet revenues generally.

1571 MR. BOWLES: Could you not ---

1572 MR. COWLING: That’s maybe more than you wanted.

1573 MR. BOWLES: The way I understand your proposal is TSPs would be required to remit certain funds to the consortium. Could one not establish a fund essentially on that basis, the same contribution mechanism that you contemplate for ---

1574 MR. COWLING: Through Section 46.5?

1575 MR. BOWLES: Yeah.

1576 MR. COWLING: Yeah, that would be possible.

1577 MR. BOWLES: Just one last small question on my part. It has to do with ensuring that all PSAPs transition to the NG9-1-1 (inaudible). It’s one thing to ensure that the primary PSAPs are transitioned. It’s potentially a more burdensome operation to ensure that the secondary PSAPs are fully on board. So actually a two-part question.

1578 First, is it a requirement for all PSAPs both primary and secondary to be transitioned before one can completely decommission the Legacy network? And the second question, which is somewhat related, is to the extent that one wants to get all PSAPs onto the NG9-1-1 network, who should be responsible for the costs relating to connecting the secondary PSAPs to the primary PSAPs in NG?

1579 MR. COWLING: On the first question about whether it’s necessary, eventually yes it’s necessary, but the interim measure would be through this translator, the LNG or the LNP. So without some form of sunset, that could live on indefinitely, which we would hopefully try and get away from.

1580 On the other question about direct interconnections ---

1581 MR. BOWLES: It’s about who should be responsible for the costs of connecting the secondary PSAPs to the primary PSAPs in a manner that supports their capability to function in the NG9-1-1 network environment.

1582 MR. COWLING: I don’t think we’ve thought about that. We’ve thought about the interconnections between the PSAPs and the ESInet provider. I don’t think we’ve thought about the secondary PSAPs. So could we take that one in an undertaking?

1583 MR. BOWLES: Yeah. On the same date, please.

1584 MR. COWLING: Okay, thanks.

1585 UNDERTAKING

1586 MR. BOWLES: Thank you. Those are all my questions.

1587 THE CHAIRMAN: That was a long day. Okay, good, thank you very much for all that.

1588 We’re adjourned until nine o’clock tomorrow morning.

--- Upon adjourning at 6:19 p.m.

REPORTERS

Sean Prouse

Mathieu Bastien-Marcil

Lyne Charbonneau

Julie Payette

Ian Schryer

Kathy Poirier

Karen Noganosh

Krisa Campbell

Renée Vaive

Mathieu Philippe

Date modified:

2017-01-16