Transcript, Hearing January 17, 2017
Location: Gatineau, Quebec
Date: January 17, 2017
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Attendees and Location
Terrasses de la Chaudière
- 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
--- Upon commencing on Tuesday, January 17, 2017 at 9:04 a.m.
1589 THE CHAIRMAN: À l’ordre, s’il vous plaît. Order, please.
1590 Alors, madame la secrétaire, s’il vous plaît.
1591 MS. ROY: Good morning. We’ll now start with the presentation from the National Pensioners Federation, Council of Senior Citizens’ Organizations of B.C., and Public Interest Advocacy Centre. Please introduce yourself and your colleagues and you have 20 minutes for your presentation.
1592 MS. LAU: Thank you, Madam Chair. Good morning Mr. Chair, Commissioners, and Commission staff. Thank you for the opportunity to appear today to represent the interests of the National Pensioners Federation, Council of Senior Citizens’ Organizations of B.C., and Public Interest Advocacy Centre -- together “NPF-COSCO-PIAC” -- in the Commission’s establishment of a regulatory framework for next-generation 9-1-1 services in Canada.
1593 My name is Alysia Lau, Legal Counsel at PIAC, and it is my pleasure to introduce you to John Lawford beside me, Executive Director and General Counsel to PIAC; and next to him, Herb John, President of the National Pensioners Federation; as well as Ben Segel-Brown in the second table, articling student.
1594 Our not-for-profit organizations represent the interests of Canadian consumers, many of whom are familiar with and at times have needed to use 9-1-1 emergency services. Our coalition members have no direct economic stake in the telecom industry, but seek to ensure the public interest of a next-gen 9-1-1 system which serves all Canadians, established in accordance with the telecommunications policy objectives, can be achieved.
1595 Today we are here to share the high-level positions which we believe represent consumer interests in this proceeding and which the Commission should consider in reaching its determinations. Notably, we believe the consumer interest in 9-1-1 lies in access, funding, and transparency. Public safety is non-negotiable. Consumers expect consistent and reliable access to 9-1-1 through any communications technology they use. They expect the delivery of emergency services to be efficient, straightforward, and universal. And they want to know where their money is going. Funding must be transparent and equitable.
1596 We believe our remarks today will effectively encapsulate these consumer views on the issues raised in this proceeding. Herb will start us off.
1597 MR. JOHN: Canadians, including seniors, expect 9-1-1 service to be reliable and accessible everywhere in Canada no matter the technology. Public safety is non-negotiable. As thousands of Canadians cross the age 60 threshold every year, NPF recognizes that 9-1-1 services will change by utilizing the available technologies. Just as these new technologies have provided incredible improvements in other communication venues, we know that 9-1-1 communications will be no exception. As we address the results of living longer with complex medical conditions, 9-1-1 must continue to provide the reliable contact with emergency services in all rural and urban communities across Canada.
1598 In Telecom Regulatory Policy 2016-165, the Commission found that:
1599 “Overall, the 9-1-1 networks in Canada are reliable and resilient.”
1600 However, there is still work to be done. In some parts of northern Canada and across some technologies such as VoIP, 9-1-1 calls are not automated. And in some cases, Canadians must dial a seven-digit number or 9-1-1 service requires an intermediary agent.
1601 Similarly, the rollout of TEXT with 9-1-1, which we’re sure will be addressed by accessibility advocates later this week, has created some confusion about its availability and use. Wireless caller location, which will not be directly addressed by the Commission in this hearing, continues to pose challenges for PSAPs and emergency responders.
1602 Today, Canadians are used to calling 9-1-1 through a regular voice call. However, we agree that the Commission should begin to lay a foundation for future 9-1-1 service, especially over IP networks. In this case, consumer point of view is critical. As consumers adopt and rely on different means of communications, they will expect and at times assume emergency services will be available through those means. A balanced next-gen 9-1-1 framework will promote both public awareness and the rollout of advanced emergency services which do not fall behind consumer use of technology.
1603 MS. LAU: While NPF-COSCO-PIAC recognize concerns expressed by emergency responders wary of receiving an overload of data regarding an emergency, we believe that 9-1-1 emergency service must continue to evolve to become more inclusive and innovative. Notably, we believe that texting and video calls should be prioritized as new means of communication, as they would assist many Canadians, including seniors, children, individuals with a disability, and other Canadians who may be in dangerous circumstances preventing verbal communication, to contact 9-1-1. We also support the development of a Canadian online 9-1-1 application for communication and other forms of data shared by consumers.
1605 MR. LAWFORD: Canadian consumers care about where funding for 9-1-1 is going. They want to understand how 9-1-1 funding is allocated and be assured there is enough funding distributed to the right areas. Therefore, funding raises two primary issues. The first is data and the second is sufficient and equitable funding.
1606 In 2013, then-Commissioner Timothy Denton published a comprehensive report on the provision of 9-1-1 service in Canada. Following requests for disclosure made by NPF-COSCO-PIAC and Rogers Communications in this proceeding, the Commission also released additional information on aggregated 9-1-1 revenues collected from Canadian telecom subscribers in 2015.
1607 However, some ILECs have suggested that these single snapshots of 9-1-1 funding are sufficient to guide the Commission’s long-term findings on regulation, operation, and funding of a next-gen 9-1-1 network.
1608 We strongly disagree. While these responses provide helpful information, they say nothing about the way 9-1-1 funding has changed historically or is projected to change in the future if the next-gen 9-1-1 network is funded, as proposed by some parties, by a tariffed model. The current data also gives almost no information as to how current 9-1-1 funding is distributed, in essence, “where the money goes” and how it is “divvied up” by individual ILECs.
1609 The ILECs have no interest in voluntarily disclosing this information and will continue to claim it is competitively sensitive and warranting confidential treatment. We believe this is no longer appropriate moving forward. Rather, this is the opportune moment for the Commission to re-examine the way that 9-1-1, a public interest service, is funded and reported.
1610 We believe the most efficient and transparent way of funding next-gen 9-1-1 would be to incorporate 9-1-1 funding into the National Contribution Fund financed by contributions from telecom service providers.
1611 In the Commission’s recently issued framework for modern telecommunications services (2016-496), the Commission decided to include retail internet access and texting services as contribution-eligible revenues for a new broadband funding mechanism. This proceeding, which examines next-gen 9-1-1 and future means of communicating with emergency responders, naturally complements that decision. It would be logical to incorporate funding for emergency services into the NCF. As such, all TSPs would be required, based on a long-established formula, to contribute to next-gen 9-1-1 funding.
1612 Incorporating 9-1-1 funding into the NCF would also create greater transparency and equity, as an independent administrator could report regularly on the funding collected and how it is allocated, whether for day-to-day operations or for maintenance and upgrades. A national administrator could also ensure that funding is allocated equitably and that underserved areas may be prioritized for upgrades or improvements.
1613 I’ll allow Alysia to further elaborate on the next-gen 9-1-1 administrator.
1614 MS. LAU: In order to ensure a next-gen 9-1-1 network will deliver reliable access, efficient and equitable funding, and transparency, we believe it should be administered by one national entity.
1615 NPF-COSCO-PIAC have followed the record of this proceeding, throughout which the Commission and parties have attempted to delineate the role and make-up of the next-gen 9-1-1 administrator, as well as its relationship with the next-gen 9-1-1 operator or operators, the providers of the service.
1616 While it is impossible at this time to clearly define what the next-gen 9-1-1 administrator would look like, we will endeavour to present here what we believe to be the most important aspects of national next-gen 9-1-1 administration from the vantage point of the consumer.
1617 In our view, there are several main outcomes of a national 9-1-1 administration -- of national 9-1-1 administration which would benefit Canadians: transparent and equitable funding, efficient administration, and consistent and reliable service. We believe these outcomes would benefit Canadian consumers and citizens and further the policy objectives set out in the Telecommunications Act.
1618 Therefore, we believe the next-gen 9-1-1 administrator could and should have a role in implementing reliability and quality of service standards, privacy rules, and other obligations. It could undertake inspections and audits on reliability or the need for service improvements in specific markets or regions.
1619 It should have a role in managing allocation of next-gen 9-1-1 funding. The administrator could prepare a budget or approve budgets and applications for funding made by the next-gen 9-1-1 operator or operators.
1620 And it should have a role in acting as the main next-gen 9-1-1 point of contact and coordinator for TSPs, PSAPs, public agencies, and emergency responders. Other parties have also emphasized the need for a central, independent entity dedicated to 9-1-1 administration, albeit perhaps with different functions or mandates.
1621 Regarding governance, we note the Board of the Canadian Administrator of VRS is composed of directors selected by deaf and hard-of-hearing stakeholders, TSPs, and independent directors. We would, at this stage, support a similar constitution of the Board of a national next-gen 9-1-1 administrator.
1622 As consumer advocates, we are less concerned about how next-gen 9-1-1 service is delivered; in other words, whether there should be one designated next-gen 9-1-1 operator or several regional operators.
1623 We recognize that next-gen 9-1-1 service would likely continue in large part to make use of the ILECs’ networks. However, a national operator selected through a bidding process could also create greater efficiency and simplicity in the day-to-day operation of 9-1-1 service.
1624 In sum, Canadians rely on 9-1-1. They recognize its importance and expect it to be accessible and reliable across the country. As the Commission contemplates establishing a framework for next-gen 9-1-1, we urge it to consider how to make service and funding more efficient, transparent, and equitable in order to ensure next-gen 9-1-1 is future proof and meets consumers’ needs and expectations
1625 Some PSAPs have expressed concerns about their own abilities to accommodate the means of communication and service a next-gen 9-1-1 network could provide.
1626 NPF-COSCO-PIAC agree with the Commission that the scope of this proceeding is limited to the 9-1-1 network and providers. Therefore, regardless of whether PSAPs are ready, we believe the Commission should ensure that telecom service providers move forward in their preparation and will be able to provide next-gen 9-1-1 service at whatever time is ultimately decided. This would fall in line with the Commission’s recent policy on modernizing telecommunications services.
1627 Thank you for the opportunity to present to you this morning. We would be pleased to answer your questions.
1628 THE CHAIRMAN: Thank you very much.
1629 Commissioner Vennard will start us off.
1630 COMMISSIONER VENNARD: Good morning and thank you for coming to talk to us today. I know that you just finished stating that it is impossible to, at this point, clearly define what the next-gen 9-1-1 administrator would look like but in my mind, before we start to get into the funding and the governance and so on, we need to have some sense of what that -- I need to have some sense of what that would actually look like and how far your thinking is on that. Those are all matters that are quite intricately related.
1631 So I guess what I’d like you to ---
1632 MS. LAU: Certainly, we’ll do our best to help you out there.
1633 COMMISSIONER VENNARD: Sure. I guess what I’d like you to do is, first of all, explain to us what -- kind of flesh out what would this administrator look like? Who would it be? Where would this body come from? How would it be created?
1634 MS. LAU: Sure. So there were questions about this in the interrogatories which were asked of us, I think, in -- probably in July or November.
1635 But our view is that if 9-1-1 funding is to be rolled into the NCF -- and access to emergency services is already designated as a basic service objective -- that if there were a fund for 9-1-1 that there would -- the Commission would therefore also designate an administrator, as it has done in other cases including the VRS and, of course, the NCF administrator. That would be under Section 46.5 of the Telecommunications Act. So that’s where the authority for creating a next-gen 9-1-1 administrator would come from.
1636 In terms of what the entity would look like, our view is that it would be a independent -- one independent national administrator. And the Board could be -- we did rely on -- we did point to the VRS example in this case but it could be a multi-stakeholder Board, so where the directors were elected by various stakeholders.
1637 And then in terms of what the administrator would be responsible for, we’ve tried to flesh that out a little bit in our remarks. One of our primary goals in this hearing and proceeding is to talk about 9-1-1 funding, of course, because we found that to be very challenging, challenging to get information on in this proceeding and not very transparent, the current model, in terms of how funding is allocated.
1638 So funding, I think, would be one of the key responsibilities of the national administrator as well as implementing, could be, certain policies related to privacy -- certain polices related to privacy or other technical requirements, quality of service.
1639 COMMISSIONER VENNARD: So it ---
1640 MS. LAU: But I’m going to start with that and ---
1641 COMMISSIONER VENNARD: Sure. So you visualize this as being a Board?
1642 MS. LAU: Yes, certainly, it could be.
1643 COMMISSIONER VENNARD: Comprised of whom, because at one point in your -- I think it was in your August 23rd response you mentioned that the administrator should not be a TSP.
1644 And so in my mind I’m wondering how do those -- how do those things match up? Who would have that level of expertise and knowledge to be able to manage the transition and make some of these very important decisions with respect to managing the network, building out the network, allocating funds, and so on if they didn’t have really, really intimate knowledge of the industry?
1645 MS. LAU: M’hm. So first let me distinguish -- John might have something to add ---
1646 COMMISSIONER VENNARD: Sure.
1647 MS. LAU: --- but let me distinguish between the administrator and the operators. So the operator could perhaps -- would likely, I think, be a TSP.
1648 COMMISSIONER VENNARD: So you’re imagining two different things? That’s another thing that I found rather confusing in your submission; sometimes it seemed as though you were referring to one party and then at other times it was two parties. So you’re looking at somebody who would be administrator of the fund and then an operational administrator; is that ---
1649 MS. LAU: Well, there would be -- so in our initial submission we had talked about the importance of having a national administrator which would deal ---
1650 COMMISSIONER VENNARD: Right.
1651 MS. LAU: --- yeah, with the funding and with the policies and, yeah, could and -- could undertake audits or investigations of reliability and so forth.
1652 In the interrogatories which were asked of us and other parties, the Commission actually started to try and distinguish between what might be the administrator and what might be the actual operator, so who would actually provide the service. And so we took that and tried to think more about that, about what the distinction could be and what the relationship between the two entities would be.
1653 Our primary concern is about administration, because we have concerns about funding and also ensuring that there's equity and that all areas are able to kind of catch up, I guess, as opposed to relying on ILECs being responsible for their individual territories at this point.
1654 COMMISSIONER VENNARD: So do you see two administrators, then; one of operations and one of funding or one or what?
1655 MS. LAU: We see one 9-1-1 administrator, which ---
1656 COMMISSIONER VENNARD: Okay.
1657 MS. LAU: --- would be interacting with the operator, which could be selected through an RFP process, which was discussed yesterday, or could be several regional operators.
1658 COMMISSIONER VENNARD: Okay.
1659 MR. LAWFORD: I just want to add one thing. I mean, the operator or operators would work very closely, very hand in glove with the administrator, but the administrator is a policy-level body, and it's meant to be permanent. And then the operator or operators could change. There could be a process where you have a 10-year contract or whatever it is and then they switch to someone else. But there would be standards that they would meet that would be set out by the administrator, and that way the -- that way they would know what they were getting into.
1660 The actual day-to-day operation of the thing is not something that the administrator would be -- the technical details would not be the administrator's job. That would be the operator's job, day to day.
1661 COMMISSIONER VENNARD: Okay, so you're conceptualizing the administrator of operations, basically, and then one of strategic direction and funding and so on?
1662 MR. LAWFORD: Well, it really depends on what you -- how much the national administrator wants to get into specifying the requirements for day to day. It's just really semantics about calling the operator an administrative -- calling the operator an administrator, if you will, of the technical parts of the system.
1663 COMMISSIONER VENNARD: M'hm.
1664 MR. LAWFORD: I think I'll just stop there. There's a line and I think we've done our best to answer that question.
1665 COMMISSIONER VENNARD: Okay, so I still don’t have your -- I still don’t understand what it is that you're talking about, though. Are you talking about one administrator or are you talking about two?
1666 MS. LAU: We're talking about one.
1667 COMMISSIONER VENNARD: One?
1668 MS. LAU: Yes.
1669 COMMISSIONER VENNARD: Okay, and who would that be if not a TSP?
1670 MS. LAU: Right, so we pointed to the VRS administrator as an example, but it would be an independent administrator whose board could constitute directors which were elected by various stakeholders. So we could point to the VRS one, which -- where I believe there are three directors appointed by deaf and hard of hearing stakeholders, two by TSPs, and I believe either two or three independent directors.
1671 COMMISSIONER VENNARD: Okay, so how would -- in your scheme, how would people be appointed? Would they be appointed, would they be elected? How?
1672 MS. LAU: They would typically be elected by those stakeholder groups.
1673 COMMISSIONER VENNARD: Okay, and the -- who would the stakeholder groups be?
1674 MS. LAU: Yeah, that's a good question, and we might take it back for further thinking at this point, but presumably, there might be TSP stakeholders, PSAPs, public interest and consumer stakeholders, so that would include consumer groups and also accessibility groups.
1675 I think some of the other parties might have other ideas, in terms -- emergency responders of the stakeholders they -- you know, that they believe should have a say on the board or should have a director on the board. But that would be a basic preliminary list of the types of stakeholders which would be included.
1676 COMMISSIONER VENNARD: Okay. What about the -- at a provincial and municipal level? Do you see people -- do you consider those to be stakeholders within the scheme that you're talking about as well?
1677 MS. LAU: Certainly, and we were listening to the Coalition of the Willing yesterday, and I think they would say yes, they are stakeholders in this system. I think they would probably actually be in the better position to speak to that in terms of how they would want to organize amongst themselves which of their groups would constitute stakeholders appointing or electing directors. But in our view, yes, they are part of the system.
1678 COMMISSIONER VENNARD: How large would this group be? Like, how do you -- have you thought about that, how large that would be?
1679 MS. LAU: Well ---
1680 COMMISSIONER VENNARD: If it's national, I mean, we're a very big country, so if it's national, then you know, we -- you would want to have representation from across the country and some sort of representation from stakeholders in it, because everybody does have an interest in 9-1-1.
1681 MS. LAU: And I think those are factors the Commission should take into consideration. I think current boards such as the VRS or the CCTS currently have, you know, about 9 to 12 directors, so that would be something that we would put -- I think we would put further thought into this as this process develops. At this point, we're still discussing whether there should be ---
1682 COMMISSIONER VENNARD: Sure.
1683 MS. LAU: --- a national 9-1-1 administrators, so -- but if you would like, we could try to think about that a little bit more and come back to you.
1684 COMMISSIONER VENNARD: Yeah, I think it would be very useful to have a few more details on what that would look like, and the reason being, of course, is because we do not have jurisdiction over some people that may be -- or some groups that might need to or want to be part of this. So -- and also funding ---
1685 MS. LAU: M'hm.
1686 COMMISSIONER VENNARD: --- when it comes to the funding, because the funding for this network could come from a variety of different places, some of which we have absolutely no jurisdiction over. So when we're looking at a national model, we have to take into consideration all these other pieces that would fit into it as well.
1687 So if you could maybe think about that a little bit more and give us some -- you know, put some edges around it a little -- in a -- in that sense a little bit more, including even possibly outlining the different roles and responsibilities to a greater extent.
1688 Like, for example, would you think that the -- because we have to think about the role that the CRTC plays in this as well, and sometimes we can't play any role at all.
1689 MS. LAU: Yeah, certainly, we'll take that away. I will say that we do believe the Commission has the authority under the Telecommunications Act to create an administrator which would administer the funding collected from the TSPs, so that pot of funding is, we believe, within the Commission's mandate and jurisdiction to administer or to delegate and administer -- an administrator to allocate and distribute.
1690 So we think -- so we're not suggesting, I don’t think, that funding provided by municipalities and provincial governments that the CRTC should be prescribing how that funding should be allocated, but certainly, the funding collected from TSPs would be within the CRTC's jurisdiction to.
1691 COMMISSIONER VENNARD: How would you see funding and the decision-making -- of course, we're moving into the area of -- really of governance here. How do you see the decision-making working? Like, who would be -- make the decision on some of the things that you suggest: the build-out of the network, possibly upgrading of it, and so on? And you can see how this relates quite closely to the sort of structure that you're suggesting, because those pieces have to fit together in some way.
1692 MS. LAU: Yeah. Our view is that the Commission is here to establish a regulatory framework and could therefore provide direction and guidance in its ultimate policy. There was discussion yesterday about -- in relation to more specific rules or policies such as privacy or otherwise ---
1693 COMMISSIONER VENNARD: Sure.
1694 MS. LAU: --- that a national entity might -- a multi-stakeholder national entity might be in a better position to develop together. We're not necessarily opposed to that, although we do believe the Commission could provide direction as to, for instance, in regards to privacy, the types of privacy protections it believes are -- would be appropriate in a next-gen 9-1-1 system.
1695 COMMISSIONER VENNARD: Yeah, I know there's a lot of moving parts to the whole thing, and some of them seem to fit, some don't. And of course, that's exactly what we're trying to look at here.
1696 MS. LAU: Yeah, we understand.
1697 COMMISSIONER VENNARD: So what parties do you think should be involved in decision-making processes?
1698 MR. LAWFORD: Well, if there's a multi-stakeholder structure, then I -- we are presuming that there would be a committee-type approach there, and that whatever structure that national administrator decided to set up and the Commission approved, it would likely be a committee-type structure where decisions were made in committee and then brought to an executive committee and then voted on by the whole group.
1699 It's difficult to get into exactly how that would work. Other -- as Alysia has pointed out -- other regulatory oversight bodies like CCTS and VRS have set up their own rules to do that. We just presume that there would be some democratic elements and some efficiency elements in there that would -- they'd come to a compromise and we would feel our way through it.
1700 COMMISSIONER VENNARD: Yeah, all of these things are a work in progress. I mean, I, you know, understand that.
1701 MR. LAWFORD: Yeah.
1702 COMMISSIONER VENNARD: And usually, we notice what we have to focus on once we really start to think about it. I mean, I get that.
1703 Now, the national administrator would also be responsible for the rolling out of the network, as I understand it?
1704 MS. LAU: Yeah, I think -- yes.
1705 COMMISSIONER VENNARD: Oversight or allocation of funding and so on.
1706 MS. LAU: Oversight and implementation, I think, of the Commission’s decision, yes.
1707 COMMISSIONER VENNARD: Okay. And that would include funding for -- leaving apart for the moment where the funds would come from, but how would they be allocated? Like, what role would that -- I’m going back to the role of the administrator. How would they make decisions on how to allocate funds?
1708 MS. LAU: Sure. So the way funding is currently allocated under the NCF -- so there are different processes. So it’s different from the NCF; it’s different for the VRS. Ultimately, I think the administrator takes a lot of direction from the Commission in terms of how it should be allocating the funding and in terms of the policy that it would be implementing.
1709 In this case we could look to -- in Australia, for instance, there is a -- the 9-1-1 service -- although in that case, Telstra also operates the PSAPs, I believe. But in that case there is a cap in the universal service fund in terms of the budget which Telstra is able to submit for funding to operate the emergency services in that country. So I believe that the cap is currently close to about 20 million a year. And so that could be one way of doing it.
1710 So the Commission could decide that -- could impose reasonable cap on funding for the operation of 9-1-1 every year. And then on top of that, the administrator could also, for instance, receive applications from the operator or operators if they want to do maintenance or they have specific projects and they want to upgrade parts of their network. The administrator could review those applications with the Commission’s policy in mind and approve them or deny them as well. So those are different options which are available.
1711 COMMISSIONER VENNARD: Okay. I didn’t really hear an answer to my question, which is really how would these decisions be made and how would funds be allocated? Who would establish a criteria?
1712 MS. LAU: Our view is that the criteria would first be established by the Commission.
1713 COMMISSIONER VENNARD: Okay. And then that would be -- we would convey that to the national administrator who ---
1714 MS. LAU: Yes, that’s right.
1715 COMMISSIONER VENNARD: --- would administer the ---
1716 MS. LAU: Yeah, in accordance with section 46.5.
1717 COMMISSIONER VENNARD: Okay. In a kind of a related vein there, who would determine whether facilities actually need to be built out? It’s a variation of the question I just asked you.
1718 MS. LAU: So one example we might point to -- there was just a quiet discussion -- is, for instance -- so in the Commission’s recent policy on modern telecommunications services, the Commission decided to create this new broadband funding mechanism and kind of create a framework for the types of areas which might be prioritized for funding first.
1719 And so we could see something similar happening on the next-gen 9-1-1 side where the Commission could say, “These are the specific areas that we think would need -- should be prioritized or would need upgrades first.” And the administrator would, therefore, kind of implement that or receive applications for that for project funding and so forth.
1720 COMMISSIONER VENNARD: So you see something like possibly a Commission proceeding or hearing to a public consultation along the same line?
1721 MS. LAU: Yeah, I think if the Commission finds that it needs more information regarding where, kind of, a transition or an upgrade to the infrastructure in order to allow for next-gen 9-1-1 service is most critical, then it could definitely do that in a follow-up proceeding.
1722 COMMISSIONER VENNARD: Okay. Now, still staying with the idea of the national administrator, which is a work in progress, you submitted a list of responsibilities for that and you mention that:
1723 “Overseeing operation of the next-generation 9-1-1 network and communications should be included.”
1724 And can you please explain what that would entail?
1725 MS. LAU: I’m sorry; could you point us to the -- in the oral remarks, is this?
1726 COMMISSIONER VENNARD: No, this is just in ---
1727 MS. LAU: In our introduction?
1728 COMMISSIONER VENNARD: --- a general compilation of your submissions and so on. You submitted a list of responsibilities for the national administrator. I believe if you look at -- I think it’s your August 23rd responses.
1729 MS. LAU: Okay.
1730 COMMISSIONER VENNARD: If you’d like I’ll find it? Yes, it’s your August 23rd response.
1731 MS. LAU: Second question?
1732 COMMISSIONER VENNARD: You’ve got it? Yeah.
1733 MS. LAU: Okay.
1734 COMMISSIONER VENNARD: Question 4.
1735 MS. LAU: Oh, question 4.
1736 COMMISSIONER VENNARD: And the one I asked about was:
1737 “Overseeing operation of next-generation 9-1-1 network and communications should be included.”
1738 And can you explain what that might entail?
1739 MS. LAU: I think we view that to be just implementing Commission policy. And as we stated in our oral remarks, it could undertake certain audits or investigations of whether there might be problems with reliability in certain areas. So those might be examples.
1740 COMMISSIONER VENNARD: Okay. So you see that as being basically carrying out Commission decisions? Would that be a fair ---
1741 MR. LAWFORD: Well, not quite. I mean, as the national administrator grows in experience, I think there will be a natural transition of the Commission doing less babysitting and the national administrator doing more of the work. And so this bullet point points out that, you know, once things are operating smoothly and we’re been through the initial transition zone to this new scheme, that at a certain point the national administrator will be doing problem-solving or troubleshooting at those levels because they’ll have the expertise. And we won’t have to go back to the Commission each time and say, “Give us a new decision. Let’s do another whole proceeding,” and so on and so forth. That’s the vision. Getting there is the mission so we’ll see.
1742 COMMISSIONER VENNARD: Everything changes as people’s role mature and things unroll; that’s for sure. And I think you’ve just answered what I was going to ask you, ask you next, so thank you for that.
1743 So you indicated that while the national administrator would oversee the day-to-day operations of the network, the CRTC would continue to act as a final enforcement authority. And that’s the way that you see this?
1744 MR. LAWFORD: Yes. Yes, sorry.
1745 COMMISSIONER VENNARD: Okay. Can you please clarify whether you intend the CRTC to intervene in the relationship between the national administrator, the owners of the facilities forming part of the network, and the various entities? Do you see us intervening in those relationships?
1746 MS. LAU: Yes, we believe where there might be a dispute or problems with non-compliance or where there might be a high-level policy issue which parties are not able to agree on, that they could apply to the Commission for guidance in relation, of course, to the next-gen 9-1-1 network. So matters within the Commission’s jurisdiction.
1747 COMMISSIONER VENNARD: Okay. And what sort of enforcement mechanisms for that would you see us having?
1748 MR. LAWFORD: The Commission has a number of enforcement tools that it already uses for a variety of other enforcement needs, as in anti-spam and that sort of thing.
1749 MS. LAU: As well as guidelines. We have guidelines.
1750 MR. LAWFORD: The best way to start is of the graduated spectrum where you speak to people and you issue guidelines and then you have to get into decisions, and so on and so forth, that have cease and desists or do this or do that requirements. You can certainly do that. And then at the end of the day if there’s a necessity to fine someone -- there’s general AMPs power now, but we would hope that Commission never gets to that stage in this kind of environment. And I don’t think that you would have to.
1751 COMMISSIONER VENNARD: Okay. So you see the CRTC’s role as developing guidelines to follow?
1752 MR. LAWFORD: It would depend on the nature of the application you receive. I believe if you had one where there was simply a dispute between two carriers as to interconnection of 9-1-1 for some reason, I mean, that’s squarely within jurisdiction; it’s just a decision from the Commission, “Do this.” That’s the end of the story.
1753 If it’s we have a policy of, you know, informing both the police services and the fire services in this type of 9-1-1 contact and some people think that’s a wasteful way to approach it, the Commission may say, “Well, we don’t really want to start splitting the baby here, but here’s some guidelines that, you know, might help you in the future to decide whether to contact two services or one,” yes.
1754 COMMISSIONER VENNARD: Okay.
1755 Now, could you please -- I’m just going to move into the idea of the central fund administrator again, which might be a different part of one administrator. We’re not really sure about that yet.
1756 Could you please clarify whether your proposal contemplates a national administrator that is separate from the central fund administrator, or is that the same?
1757 MS. LAU: I think initially we had thought that it could be the same, but as the proceeding has developed and new issues have arisen -- and there are also issues to be decided -- today I think we would say the next-gen 9-1-1 administrator would probably would be separate.
1758 COMMISSIONER VENNARD: Would be separate, okay.
1759 And that central fund administrator would be -- who would that be, what would that be?
1760 MS. LAU: I’m sorry, I didn’t hear your question.
1761 COMMISSIONER VENNARD: Who or what would that be? Where would that administrator come from? Who would that be?
1762 MS. LAU: It would be the national 9-1-1 administrator which we’ve been discussing.
1763 COMMISSIONER VENNARD: Also administer the central fund?
1764 MS. LAU: They would be, yeah. So in our submissions, one of our key concerns was funding so it was be that national 9-1-1 administrator.
1765 COMMISSIONER VENNARD: So they’re the same person?
1766 MS. LAU: The same.
1767 MR. LAWFORD: So is your concern the fiscal, like, who’s looking after the money and whether it’s separated from the National Contribution Fund money administration?
1768 COMMISSIONER VENNARD: Yeah, I’m wondering how you conceptualize it to work. And again, I’m looking at here the role of the administrator. So you’ve got an administrator for the rollout to oversee the rollout of the network, you’ve got an administrator for the fund, and we haven’t even gotten to the part yet where the money comes from somewhere. So who would be doing that, are they the same entity?
1769 MS. LAU: They would be the same because it’s the same funding. So it’s the funding that’s coming from the TSPs.
1770 COMMISSIONER VENNARD: Okay. Because that was not clear in your submission, and your response is where you ended up landing on that one.
1771 MS. LAU: Okay. Well, thank you for the opportunity to clarify that.
1772 COMMISSIONER VENNARD: Yeah, okay. Thank you.
1773 So we’ve got just one administrator then, okay.
1774 So could you also please explain why it would be important to have consumer organizations as members of the board of this organization, and how representatives would be chosen?
1775 MR. LAWFORD: It’s important because -- for the same reason why we’re here today -- because the user’s perspective is always key. And having contact with individual Canadians is always -- it’s problematic for boards, as you see in your work. And so having an institutional representation from groups that claim to and actually do represent consumers and individuals is absolutely key.
1776 The second part of the question was how to pick them, how this is going to work. Well, we do it already for the CCTS. That initially was groups that were identified by the Commission as having a stake and who put up their hands, and since then that group has been joined by others. It appears to be functioning properly. And they elect their directors and they bring them forth in the usual course. So there’s some familiarity with that approach already with the CCTS, and we would expect to do the same.
1777 And VRS is also -- you see that that’s happening there with the folks who are responsible for disabled rights who are bringing directors forward. So they’re comfortable with that too.
1778 COMMISSIONER VENNARD: Okay. And then in terms of decision-making, do you conceptualize a voting structure of some kind or how does that work; how does that part work?
1779 MS. LAU: Yes, similar to the boards of other entities. They are different for different administrators. We of course have had disagreements with the way the CCTS voting structure currently works. But, yes, long story short there would be a voting structure.
1780 COMMISSIONER VENNARD: Okay.
1781 MS. LAU: Which would be defined under the bylaws.
1782 COMMISSIONER VENNARD: Okay. And would it be based on the creation on shareholder member classes and so on; how do you see that part working?
1783 MR. LAWFORD: I don’t know that you need to get that complicated. It’s really something that -- again, I hate to say work-in-progress but we didn’t actually know with CCTS how it was going to come out until it came out, until the lawyers went through and did their consultating documents.
1784 It doesn’t need to be overcomplicated. There is going to be decisions that are made that are -- sorry, operational -- are policy ones, and you want to make sure everybody has a voice. But the exact details of how the voting structure is going to work and how many directors there are is a little past our horizon, I believe.
1785 MS. LAU: We can say that currently in the CCTS the directors are the members, I think.
1786 MR. LAWFORD: [off mic].
1787 MS. LAU: Yeah, so it’s quite simple that way.
1788 COMMISSIONER VENNARD: Okay. So it sounds like maybe you’re suggesting that there should be an exploratory phase to even see what the structure of this would be like. I mean, you did say that you’re dealing with it at a high-level so I get that.
1789 MS. LAU: Right, that ---
1790 COMMISSIONER VENNARD: That this might be more detailed than what you thought of.
1791 MS. LAU: Right. That’s how the VRS administrator was ultimately kind of determined, and so we believe there would be a follow-up process.
1792 COMMISSIONER VENNARD: Okay, sure.
1793 Okay, so now there would be decisions made this board and decisions made by the national administrator. If the national administrator is not able to read consensus on certain issues, on possibly any issues, funding issues, allocation, criteria for allocation, or any issues like that, how would those issues be resolved?
1794 MS. LAU: At the end of the day, probably they would make an application to the Commission and the Commission would have kind of the final say in that matter.
1795 COMMISSIONER VENNARD: Okay.
1796 Now, I want to move into the area right now of interconnection. And I know you were probably following along yesterday and have read most of the submissions and so on. And one of the issues there is to determine what entities should be permitted to connect to the next-generation 9-1-1 network. What are your thoughts on that?
1797 MS. LAU: By entities I believe you mean probably outside of TSPs?
1798 COMMISSIONER VENNARD: Yeah.
1799 MS. LAU: The discussion was around I think Internet of Things, was it, yesterday?
1800 COMMISSIONER VENNARD: Yeah, expanding ---
1801 MS. LAU: Or that was the main concern.
1802 COMMISSIONER VENNARD: --- it out from, you know, the current arrangement and past TSPs into other parties. What are your thoughts on that?
1803 MS. LAU: Right. We may take that away and come back to you because we haven’t put as much thought into kind of the technical aspects of who should interconnect. I think we can say our view is that TSPs should be able to interconnect. And in terms of other devices, we’re not sure at this point whether they should just be able to call 9-1-1 in the same way than a regular caller would or whether they would be directly interconnected with 9-1-1. I’m not sure we’d be able to comment on that at this point.
1804 COMMISSIONER VENNARD: Okay.
1805 MS. LAU: We’d probably prefer the former.
1806 COMMISSIONER VENNARD: Yeah. It actually seems like -- I’m not even going to ask you to undertake on that one because I think that might be a little past the horizon that you’ve contemplated in your submission.
1807 MS. LAU: Yeah, I think so at this point. Yeah.
1808 COMMISSIONER VENNARD: Sure. Sure, although we might come back to that after we talk a little bit more.
1809 But again, it is relevant. And the reason that we even brought it up is because it is relevant to funding and who should actually pay, where should the money go. So who is using the network is one thing, it’s for everybody, but who should actually contribute is the reason why I even brought it up. But as I say, if you’re not that far along in your thinking, you know, that’s fine too. That’s no big deal.
1810 Okay, so let’s now move to the funding because we’re not really sure how that it would be allocated. But let’s have a look at where the funding would come from. And first of all, when it comes to a tariff-based model you submitted that the current ILEC based mechanism of funding the 9-1-1 network is “…inefficient, inequitable, and opaque, and no longer makes sense for nationally connected NG9-1-1 network.” Okay.
1811 So what aspect of that current rate-setting model could be changed that you would suggest would be useful or appropriate?
1812 MS. LAU: If we were to stick with a tariff-based model?
1813 COMMISSIONER VENNARD: Yeah.
1814 MS. LAU: I think one of our main concerns in this proceeding is transparency.
1815 COMMISSIONER VENNARD: Okay.
1816 MS. LAU: And so the way in which the tariff works, I mean, one could say that that’s transparent, although not necessarily accessible to the individual consumer or readily available to them. But our concern -- one of the challenges we really found in this proceeding was understanding where the funding was going and how it was being allocated. And so if the ILECs, for instance, are collecting that money, then they should report transparently on how they are spending it.
1817 COMMISSIONER VENNARD: Okay, so you think there should be absolute 100 percent transparency on where the money is coming from and where it’s going?
1818 MS. LAU: For a public-interest service which is heavily relied on by Canadians, yes.
1819 COMMISSIONER VENNARD: Okay. So to increase that transparency and make it publicly available would be an improvement, in your mind?
1820 MS. LAU: It would be an improvement, yes.
1821 COMMISSIONER VENNARD: Okay. Do you have any comments about the amounts? Do you think there should be new cost studies? Do you have any comments on that -- if we were to stick with the tariffed-based model?
1822 MR. LAWFORD: I think if you’re going to greatly expand the functionality of 9-1-1 to include new services, yes, you have to go to costing. It’s necessary to set a baseline for a just and reasonable rate, so you have to go there ---
1823 COMMISSIONER VENNARD: Yeah.
1824 MR. LAWFORD: --- unfortunately.
1825 COMMISSIONER VENNARD: And that’s a difficult one because, as we’ve heard already, it’s kind of a chicken and egg situation because you can’t really do the cost until you know what it you’re costing, and you can’t -- and you don’t really know what it’s going to cost until you start ---
1826 MR. LAWFORD: Well, those are ---
1827 MS. LAU: We would agree with that ---
1828 MR. LAWFORD: Yes.
1829 MS. LAU: --- entirely.
1830 COMMISSIONER VENNARD: Yeah. Yeah, so definitely a little bit of a challenge there, I think.
1831 But would you suggest that a new cost study, to the best -- to the most detail possible at this point would be something that would improve the tariffed-based model?
1832 MS. LAU: Certainly the Commission does have to, in some way, land on a number, so ---
1833 COMMISSIONER VENNARD: Yeah.
1834 MS. LAU: --- yes.
1835 COMMISSIONER VENNARD: Okay. Could you provide your views on the revenue-neutral formula used to determine the tariffed rates for ILECs wholesale NG9-1-1 network access service? So the revenue-neutral formula, do you have any views on that?
1836 MS. LAU: No. I think if you would like us to comment on that, we’d have to take it away, I think.
1837 COMMISSIONER VENNARD: I actually would like you to do that, if you wouldn’t mind undertaking to do that. I’d be interested in your comments on that. I believe it’s ---
1838 MR. LAWFORD: Yes, we’ll do that.
1839 COMMISSIONER VENNARD: --- January 24th?
1840 THE CHAIRMAN: Yeah.
1841 COMMISSIONER VENNARD: Yeah.
1842 THE CHAIRMAN: For the 24th of January, is that okay?
1843 MR. LAWFORD: Yes.
1844 THE CHAIRMAN: Thanks.
1846 COMMISSIONER VENNARD: So why do you think that your proposed approach, based on a central fund, overseen by a national administrator would result in NG9-1-1 serviceS being provided to TSPs in a more economically efficient manner?
1847 MS. LAU: I think that would be based on our understanding of there just being efficiencies saved from having one national administrator rather than four different network providers deciding individually how they would allocate 9-1-1 funding.
1848 In our minds, the two main advantages of a centralized 9-1-1 funding model would be equity and so therefore the administrator would be able to determine which areas would be in the most need of funding and be able to allocate that appropriately; and transparency, so being able to report regularly on the funding that’s coming in and how it’s going out.
1849 MR. LAWFORD: I just might add there’ll be economies of scale and scope. You put it together -- this is a huge undertaking; we realize that ---
1850 COMMISSIONER VENNARD: Yeah.
1851 MR. LAWFORD: --- to move the system from ILEC to this thing, this national system. So -- but putting -- one of the advantages is, of putting it all together -- “We have a problem; let’s all work on the video problem.” So we come up with the video solution, or the Skype solution, or whatever it is.
1852 COMMISSIONER VENNARD: M’hm.
1853 MR. LAWFORD: It’s more efficient to have one solution for the -- nation-wide that can be implemented by the operator or operators rather than, as Alysia pointed, four different people working on the video problem.
1854 COMMISSIONER VENNARD: Okay. So you obviously think that that would be a more economical way of providing the service, too, to have some sort of standardization and ---
1855 MR. LAWFORD: It makes sense from, sort of, a high-level economic point of view. We haven’t -- you know, don’t have any economics expert here to prove it, but yes.
1856 COMMISSIONER VENNARD: Okay. So how would your proposed model make the process to determine the cost for NG9-1-1 more transparent while respecting the need for confidentiality of information? Or do you think that the confidentiality of the information and the numbers and so on should be out there for public viewing?
1857 MR. LAWFORD: Well, there would be less confidentiality under the new system. So there would be more that’s in the public domain. Does that help answer the question? I guess -- I’m sorry; I’ve lost the thread of the start of your question if you could say it again.
1858 COMMISSIONER VENNARD: Yeah. Yeah. Yeah, I was asking about the, you know, economically-efficient manner and how would your proposed model balance off the confidentiality. But you’ve stated that you don’t think there should be confidentiality when it comes to the numbers of this.
1859 MS. LAU: That’s right. We think it’s a public-interest service and so therefore the funding as being funnelled to the NCF; then it would be reported on ---
1860 COMMISSIONER VENNARD: Okay.
1861 MS. LAU: --- transparently, or be made publicly available.
1862 COMMISSIONER VENNARD: Okay. I would -- I want to move now into the issue of privacy. But prior to moving into that area, I think it would be useful to put some edges around our conversation and talk a little bit about the different methods of communication and the different kinds of information that might give us a little more, you know, sort of, something to focus on.
1863 Now, there’s been -- we’ve noticed in the -- that there seems to be consensus around the idea of moving forward into new ways of communication, that the first one would be Voice on -- over IP and moving on into text -- or Text-to-9-1-1.
1864 You seem to take a different view of that and you seem to think that the video streaming is something that should be a prime focus. Is that accurate?
1865 MS. LAU: We also believe that texting is an important method of communication. And yes, and also video calls would be very helpful. Just within our consultations, that was what was decided in particular, for NPF members as well.
1866 COMMISSIONER VENNARD: Okay. How would you prioritize those, because I saw two different things within your submissions? Would you say that the video streaming is -- the video calls are most important?
1867 MS. LAU: I think at this point, after having discussed it and listened to the presentations yesterday, we would probably say texting is more important at this point ---
1868 COMMISSIONER VENNARD: Yeah.
1869 MS. LAU: --- and then video calls.
1870 COMMISSIONER VENNARD: Okay, so texting and then video?
1871 MS. LAU: Yes.
1872 COMMISSIONER VENNARD: Okay. Okay, so given that those are the two things that you are -- that, in your view, are the most important things that should be rolled out in some sort of fashion, we can then talk a little bit about some of the issues that might come up in a more concrete way with some of these. So what issues do you see coming up that would cause privacy concerns or any other concerns?
1873 MS. LAU: I think if a caller is contacting 9-1-1 and they send -- and data is shared, which they have consented to, and so they’ve decided to share that information and that information is used by PSAPs and emergency responders, I don’t think we foresee a specific problem with that.
1874 It’s kind of the follow-up kind of implication. So how is that data that’s been shared -- how will that then used afterwards? Would that be disclosed to any other parties; and would that be done with the caller’s consent or not? I don’t know if, yeah, that’s a good summary.
1875 COMMISSIONER VENNARD: Okay. So in your view -- and I believe I read it within your submissions or your responses that any communication to do with emergency should be within this private network. So would I be correct in assuming that social media, for example, doesn’t form part of what you’re -- of your scheme?
1876 MS. LAU: When we’re talking about 9-1-1 service at the moment, yes, it would not; social media would not for part of that communication.
1877 COMMISSIONER VENNARD: Okay. So in your view, then, that should just not even be part of the discussion, just leave it as a private network and that’s that?
1878 MR. LAWFORD: Well, I believe that at this point, as far as our horizon is again, yeah, that it should not be, but we would imagine that the national administrator would immediately begin work on whether there are platforms, social -- we call them social media but people use them just like ---
1879 COMMISSIONER VENNARD: Sure.
1880 MR. LAWFORD: --- regular communications. Obviously, Facebook Messenger and these sorts of things, you know, WhatsApp, there would be a lot of studies starting right away on those, whether that could be the next phase, but we don’t see it in this first phase.
1881 COMMISSIONER VENNARD: M’hm.
1882 MR. LAWFORD: We see more the texting that we’re familiar with, and then video calls and that sort of thing as the next steps.
1883 COMMISSIONER VENNARD: Okay. So you see those two different things as rolling out in sequence, or maybe simultaneously?
1884 MR. LAWFORD: Hard to say but I believe the national administrator would do it in that order, or your decision would recommend that it be done in that order, yes.
1885 COMMISSIONER VENNARD: Okay. Do you think that the rollout should occur -- we’ve heard many times that rollout of anything should occur when PSAPs are ready for it. How do you view the rollout? Would you agree with that? They’re the ones who have to use it.
1886 MR. LAWFORD: Alysia will add.
1887 COMMISSIONER VENNARD: Sure.
1888 MR. LAWFORD: We did discuss this. We’ve been discussing this for a while. It’s also in our oral remarks. There has to be some -- as far as the Commission can go with its jurisdiction and who it’s overseeing, there has to be some movement, pressure to go forward. And we hesitated to say whether the PSAPs are ready or not because of course that’s silly; they have to be ready.
1889 But if you build it they will come. If there’s a functionality and if they’re included in the process, the PSAPs -- “Look what you can get if you just upgrade. Look what you can --” and it’s organized, then we believe the PSAPs will come to the party and be eager and willing, when they see it’s organized and there’s steps laid out, that they will start looking at how to fund it, how to participate.
1890 No, you can’t tell them that they’re going to be using this service. But if it’s there, it’s available, and the carriers can use TextNow and they’re ready to do video, then we would hope the PSAPs would start jumping aboard.
1891 COMMISSIONER VENNARD: Providing that they had ---
1892 MR. LAWFORD: You’re not going to be holding the whole thing up because two PSAPs in, you know, Fredericton can’t do this. It’s not sensible to wait for the last PSAP to be ready to jump into the new world.
1893 COMMISSIONER VENNARD: Yeah. But there could easily be a problem there with respect to funding too because they may be ready, willing, but not able.
1894 MR. LAWFORD: Yeah, that could be a problem where a certain province has a less robust view of what’s needed for 9-1-1 and maybe doesn’t understand the decision. But we’re hopeful that the national administrator, with, you know, a very solid policy decision from the Commission, will, you know, start talking about this and will have interactions with the provinces and regular contacts; and they will understand what the Commission is trying to do, and that they will prioritize it.
1895 Now, there’s always a problem with budget, so on and so forth, and you can’t control provincial budget-making. But it’s kind of like the Canada Health Act. The federal government sets, “Here’s what we want for healthcare in Canada” and provinces go away and do it.
1896 If at some point there’s a political issue with not enough money in the provinces to do what the federal government is kind of saying to do, then politics has to get involved and there has to be -- you know, whether it’s a transfer payment for national 9-1-1 services or whatever, that could happen. But we’re just not there yet.
1897 MS. LAU: We recognize that the Commission’s reach is limited. But what the Commission does have jurisdiction over, which is the 9-1-1 network, we believe the Commission should push to move forward to transition to next-gen. And whether the PSAPs are ready or not, that is outside of the Commission’s control. They are factors that the Commission can consider, certainly, but what the Commission can control, which is the rollout of the network, it should.
1898 COMMISSIONER VENNARD: Okay. Point taken.
1899 Now, what about the privacy issues, also the retention, the use of additional information, different kinds of information, IP-based? What are your thoughts on that? What sort of issues do you see coming from that? What are your thoughts on that?
1900 I know that you mentioned maybe something like an opt-in for some sensitive information. Maybe just expand without me asking a question. Just give us your thoughts on that, the issues that come up and potential solutions.
1901 MS. LAU: So in our intervention we set out three broad concerns. One was consent, yes, from the caller, not necessarily when they’re making that first contact, but how their personal information might be used afterwards. So where there is opt-in consent or express consent, that’s okay. The problem is where that information might be used or disclosed without their consent.
1902 COMMISSIONER VENNARD: Right.
1903 MS. LAU: The second concern was disclosure to third parties. We didn’t think that that would be appropriate outside of the purpose of providing emergency services. So that would be another concern.
1904 And the third was just -- not just, but security breaches. And so that’s something we know all parties are thinking about and making sure they have the right safeguards in place to prevent breaches, and also processes in place where data breaches do occur.
1905 COMMISSIONER VENNARD: Okay. I just want to focus for a moment on the opt-in and the opt-out. How do you see something like this working when it comes to this information?
1906 MR. LAWFORD: Well, we’ll perhaps give an example in a moment.
1907 COMMISSIONER VENNARD: Sure.
1908 MR. LAWFORD: But to the extent that Canadians can be ready to use 9-1-1 and whether it’s through an App or whether it’s through a -- you know, whether it’s through a dedicated App that we’ve been talking about in this hearing or whether it’s through other Apps that will transmit the information, to the extent that they can think about it beforehand and give consent beforehand -- like writing their medical information into a program that sends it when they call 9-1-1 -- there’s no problem there. And I believe -- you want to give your example?
1909 MR. JOHN: Yeah. I, for example, have an Apple App on my phone where I can put in whatever medications and medical conditions I have. And that App is accessible. If I end up in an ambulance they can access that information. So by putting that information in there I’m kind of already giving my approval for that information to be available to a service provider.
1910 COMMISSIONER VENNARD: So do you see an expansion of that sort of thing, particularly when it comes to sensitive information like -- and here I’m thinking of medical information. I mean, it’s one thing building schematics and so on; that is a different level of sensitivity. But personally sensitive ---
1911 MR. LAWFORD: Yeah, when you get into health information, obviously the highest level of confidentiality and privacy protection is required. In some of the provinces there are even dedicated health information statutes so you have to be mindful of that.
1912 The thinking is not to have whole databases of health information transmitted to emergency responders so that they know the profile of everybody’s health information in the entire village. The idea is that if consumers or users of 9-1-1 citizens know that 9-1-1 can use it and they wish beforehand to pre-provide that or at the time have an App that sends it on the moment, that’s a more privacy-protective way of setting up the system.
1913 There would be concerns once the health information is inside the PSAP and the emergency responders, what they’re going to do with it. And that’s something that has to be thought of. Would there be retention schedules, for example, of, you know, 30 days, 1 year, 2 years? Would it matter whether the consumer or the individual wanted them to keep it longer? Should they keep it longer whether the individual wanted to or not?
1914 Those are questions I believe the national administrator would deal with in tackling the privacy issue. They’re hard questions and they’re ones that come up in, you know, data management all the time and personal information protection. So we don’t have all the answers but that’s a sketch.
1915 COMMISSIONER VENNARD: Yeah. Yeah, they are really hard -- they are very hard questions, that’s for sure.
1916 What are your thoughts on an NG9-1-1 App? You mentioned you have an App on the phone for health information and so on. Do you see ---
1917 MS. LAU: Yes, I think we would support the development of a specific 9-1-1 application which could perhaps include functions where an individual would enter information they would like to share with emergency responders. But we would certainly support conceptually the development of that App.
1918 COMMISSIONER VENNARD: Okay. And would that App contain the information or contain the consent to get into, say, a health database? How would you see that working?
1919 MR. LAWFORD: I believe that we initially conceptualized it as quite a simple App without a direct pipeline, say, to, you know, the regional hospital that would have your entire medical records, probably because we thought that’s many years down the road or some years down the road and probably because we saw the potential for privacy leaks, so to speak. So we conceptualized it as a simple thing.
1920 As Herb mentioned with his App, “I have these three medical conditions. I’m taking these two drugs.” And when I set up the App it says, you know, with full consent, “Would you like to have this information automatically sent to providers when you hit 9-1-1 or text 9-1-1?”
1921 You say, “Yes, with full consent.” You can change the consent at any time; it’s just a setting in the App. But we’re not talking about this thing will connect to the local hospital the second it’s used, not now. Maybe in the future, but we’d have to get over some other privacy humps, then, too.
1922 COMMISSIONER VENNARD: It does seem like it might be useful to have it there because oftentimes we call 9-1-1 for other people, not for ourselves. So it would be very useful if people knew how to access somebody else’s health information or get their consent instead of your own. But time for another discussion, I guess.
1923 MS. LAU: Yeah, I think there might be some challenges in terms of being able to consent for other people or accessing other -- another person's information, but yeah, this could be further discussed later.
1924 COMMISSIONER VENNARD: But you know, when you think about it, that could happen. Like, if I saw somebody out in the hallway, for example, I'd probably pick up my cell phone and start -- and call 9-1-1. But it's not for me, so getting information on me and so on and who's calling and that might be useful in some ways, but actually, what's really useful is about the person who needs the help. But that's something different.
1925 Let me see if -- what else I have here.
1926 So what measures, if any, do you see that should be established to limit the collection and retention of information that may be required during an emergency?
1927 MR. LAWFORD: The general principles in privacy legislation are to collect only what's needed and to keep it for only as long as you need. It would depend on the emergency. It would -- if it's a health thing and it's directly related to certain conditions, then those conditions would be involved.
1928 It's hard to say out front if we could set clear limits, but we would go back to principles because it's just too amorphous to grab onto and say, "Limit collection to what's necessary. Keep it for only as long as you need to and don’t further disseminate it without express consent." And that's the best answer we can give.
1929 COMMISSIONER VENNARD: Yeah. What about the storage and the management of that -- of the data? You provided a fairly large and quite comprehensive appendix of legislation, and in your view, do you think that there's adequate protection, given that you’ve clearly reviewed the legislation?
1930 MR. LAWFORD: Well, there -- I mean, privacy legislation is something that we look at a lot and I guess, the view so far is that data breaches happen, unfortunately, and/or things get hacked on purpose. So to -- the larger treasure trove of more sensitive information you have, the more problems there are.
1931 So how do you protect that? One of the best practices that's not required by legislation is encryption. So I would hope that the Commission would encourage -- or the national administrator would encourage encryption of this information, and I don’t know the costs or the difficulty of doing so, but I don’t believe it's prohibitive or impossible. So encryption would be one easy answer.
1932 Limiting access to only those who should have it, logging and auditing who's looked at the information, you know, binding contractors to follow the same principles as anyone else in dealing with the information. There's lots of guidance from the Privacy Commissioner of Canada on these sorts of things, so we would follow that. But encryption is the first step.
1933 COMMISSIONER VENNARD: Okay. I just -- just one final thing I would like you to comment on, and that would be, we've heard yesterday from several parties, and we've certainly seen it in the interventions, that there's a bit of a disconnect between the expectations of the public and what can actually be delivered and how things actually work.
1934 In your view, who should try and manage those expectations, public awareness of what is actually available, or does anything need to be managed, in your -- from your point of view?
1935 MS. LAU: I think public awareness and education definitely is a critical component of the rollout of next-gen 9-1-1. Hopefully, the administrator would be in a good position with input from various stakeholders in terms of how -- regarding how to coordinate that. I think one of -- I was reading through some of the interventions filed by accessibility groups in particular, and some of the challenges which have arisen from Text-with-9-1-1, consumers being confused about where it is available and also technically how to access it, so actually having to initiate a voice call rather than text -- than initiating the communication via text.
1936 I think the Commission would probably have a role in that and the TSPs as well, but I think the key -- and as well as PSAPs and public agencies, the missing piece, I think, was really coordination and just making sure that the Commission's news releases, for instance, tend to be national, and so there is sometimes an assumption that this new function would just suddenly be available across the county, which is not true. In fact, 9-1-1 is not available across the country, so I think coordination would be one of the key pieces there.
1937 COMMISSIONER VENNARD: Okay. Those are all my questions. I'm wondering if you have any final comments that any of you would like to make?
1938 MR. LAWFORD: I'll just do one on that last point. We ---
1939 COMMISSIONER VENNARD: Sure.
1940 MR. LAWFORD: In terms of the Commission's role in letting people know, yeah, it's important to be clear but cautious when doing your public awareness, to the extent we'd see some at the end of this decision.
1941 The trouble with consumers is they play broken telephone, so if some -- if the Commission says something about texting with 9-1-1, people will say, "Did you know you can now text 9-1-1?" And so you'll have to be really careful about that, and be clear to put out information.
1942 I thought that the stuff for the TV transition that was done with the five charts and stuff was really clear and good, and so if something similar like that could come out contemporaneously with the decision, it would be really helpful, because to the extent that there's a technical decision that comes out that says stuff that people don’t understand and then the materials coming out telling you what it really means are separate, that broken telephone could start to happen and people will get the wrong idea. That would be my only caution.
1943 MS. LAU: I just got a note from the back there just wanting to clarify that we are asking for one national administrator which would oversee implementation of the Commission's policies and allocation of funding, which would be separate from the operator of the 9-1-1 service which would actually provide the service.
1944 COMMISSIONER VENNARD: Okay. Thank you for that clarification.
1945 MS. LAU: Thank you.
1946 COMMISSIONER VENNARD: And thanks again for coming to talk to us today.
1947 MS. LAU: Thank you.
1948 THE CHAIRMAN: Do you have any advice on how we might collectively -- because it's not just the Commission's responsibility -- but collectively get perhaps older Canadians that are less text savvy -- I hesitate, because I've -- that's not necessarily the case, but there might be groups in that population, a higher percentage of them that are not as familiar with some of the functionalities.
1949 How do we get them to be comfortable in a next-generation 9-1-1 environment?
1950 MR. JOHN: Well, I think there is a broad range of response from aging Canadians to new technology. Some don’t want to have anything to do with it and probably never will. Many of them -- and that's why in my comments I said that as thousands of Canadians across the age 60 threshold that is something that will continuously grow in the future, that involvement with new technology.
1951 So how to motivate and incentivize seniors to get involved with that, they are doing that. To what degree, I don't know that anybody's done any substantial studies to determine that, but for video conferencing, a lot of seniors use that. Texting is probably the most common. But there will have to still be regular phone. Voice communication will -- you know, depending on the age group.
1952 THE CHAIRMAN: And then, of course, you're right, but even if add additional data points, functionalities, the voice communication -- traditional voice communication, remains.
1953 With respect to your proposal of a more national consortium approach, I get the feeling part of your concern is, in part, around the costing elements of the ILECs traditional costing approach. And you seem to be advocating for greater transparency.
1954 Assume for a moment that you have managed to convince us to go down, and we go towards a more traditional ILEC model. One of the challenges we have in the costing and rate-setting exercise with respect to transparency is, some of the elements of the communication network are also used for competitive purposes.
1955 And therefore, when we do our job in figuring out what is just and reasonable we’re faced with the fact that there’s a dual purpose to some of these assets and some of the costs associated with the cost-setting exercise.
1956 So do you have any thoughts about how we could -- assuming we aren’t going down your model -- and you’ll probably say something like, “That’s one of the reasons why we want to go down this other route”. But let’s assume that you haven’t managed to persuade us. How could we improve the current system for greater transparency?
1957 MR. LAWFORD: Yeah, the common elements problem is one. I mean, you have a switch and it does 9-1-1 and it does regular switching, right? And the same wires are used between two things and there’s lots of common elements. And the Commission deals with that in wholesale stuff all the time.
1958 There’s a level of transparency that’s necessary too for an average citizen to check-up on is my money being well spent? And I think that’s where we’re trying to get to. Not to -- I don’t really care whether they have a Cisco switch that’s gold-plated or not, but I want to know if they’re generally gold plating or if they’re not providing service, and if my $0.17 or whatever it is per month is actually going somewhere. That’s the level we’re trying to get to.
1959 So in this proceeding so far, I mean, we had to kind of squeeze out how much money is even being spent on 9-1-1 in the first place. That’s pretty high-level still. So, you know, we’d like to move down to how much money does Bell get for this stuff and how many calls do they take, and where is the money going generally? At least to that level.
1960 And then when you start to dig into whether it’s, you know, an IP-based system and how it’s switched and so on and so forth, I can see where they’d start to get antsy. And the Commission will have to draw the line you do with other wholesale things. These elements are necessary for competitors to understand what’s going on and see whether the rate is fair. Same thing. Now consumers need to see that the rate is fair at roughly that level. But I’m afraid I can’t help you more than that.
1961 THE CHAIRMAN: Right. But there’s a certain degree of acceptance that for non-9-1-1 services that are competitive the window into that costing information is limited to yourselves and others, and you have to in a sense sort of trust that the Commission’s expert costing folks and the Commission itself is doing its job to make sure that the rates are just and reasonable. So why is this area different?
1962 MR. LAWFORD: Because -- I think we said it a couple of times -- it’s a public-interest service. It always has been. I find it interesting because as you switch to talking about next-gen 9-1-1 and the additional functionality, it looks less and less like a telecom service, less and less like a formal rate-regulated thing, and it could be delivered by many different ways. We just don’t know yet. It’s tethered to the ILEC system because that’s what works for sure and we need it to work for sure, but it may change in the future.
1963 Those other elements that are not traditional ILEC elements have less sort of hard-coded costing; let’s put it around that. And there may be room to let some more information out. It may be that there could be more efficient providers delivering part of this network. We don’t know. But we’ll never know if all of it is hidden forever. So that’s why we’re asking to go a little deeper on transparency from your point-of-view to just understand that. That it’s a public-interest service, it could be improved by public knowledge of what’s going on.
1964 And, yes, there will be a point at which no it’s no appropriate for the public or competitors to know how Bell’s network is architected but we do trust your judgement in those calls.
1965 THE CHAIRMAN: Okay, thank you. I believe legal has a few questions.
1966 MR. BOWLES: Yes, Chair. I have a few questions for you.
1967 First off, I’m just going to start off with a high-level question. And I’d like to provide you with the opportunity to sort of highlight the differences that you perceive between your administrator proposal and the consortium proposal put on the record by some of the other parties.
1968 MS. LAU: So I believe similar to ours, the consortium model has also kind of evolved maybe a little bit throughout this proceeding. My understanding is that the membership of the consortium would be primarily industry-based. Shaw might have changed that over the last couple of months to a more multi-stakeholder board. But our concern is of course that it should be independent and that all parties and all stakeholders should be represented.
1969 And the consortium model also presents a different means of funding 9-1-1, and so our view is that all TSPs should contribute to 9-1-1 funding and that it should be ruled into the NCF with an administrator. I believe Shaw yesterday said that the funding would be collected based on -- was it the number of outgoing calls or something? I’m not entirely sure, sorry. Yeah, we could find that in the transcript. But that would be a difference as well in terms of how funding is calculated and how it is collected.
1970 We’re not sure what to add maybe at this point, but we could come to you in an undertaking if you’d like a more detailed analysis.
1971 MR. BOWLES: Could you undertake to provide that by the 24th of January?
1972 MS. LAU: Yes.
1973 MR. BOWLES: Yes.
1975 MR. BOWLES: While we’re on the topic of funding, there was a discussion between yourselves and Commissioner Vennard on this earlier but I just want to be absolutely clear.
1976 Under your proposal, you contemplate the funding coming from a National Contribution Fund which has its own fund administrator and then there’s this NG9-1-1 administrator. Help us understand the interactions between those two administrators with respect to the funding aspects.
1977 MR. LAWFORD: Alysia will correct me if I get this wrong. There will at least a notional separation of the two funds so that you’re not dipping into NCF that’s meant for broadband to fund 9-1-1. There will an accounting split. Is that what you’re asking about, whether the funds will co-mingled or whether there’s two administrators and how they dip in?
1978 MR. BOWLES: Well, are there two separate administrators essentially administrating the National Contribution Fund or does the NG9-1-1 administrator somehow have to interact with the existing NCF administrator?
1979 MR. LAWFORD: I don’t know that we got that deep in our submissions. And I might get the hook at any point, but I think that there would again be a notional accounting difference. And the national administrator for 9-1-1 would be responsible for that chunk of NCF that is earmarked for their service where the NCF, regular NCF administrator does what they do in the same old way.
1980 You know, I’m not a fiscal expert but sometimes when you put a whole bunch of funds together in one big fund you can make better investments and get more money. And they may wish to put it all together, or may wish to keep it separately, notionally, whatever. But who writes the cheques is the 9-1-1 administrator writes it from their account and the NCF administrator doesn’t write cheques for the 9-1-1 people.
1981 Does that help?
1982 MR. BOWLES: Okay, yes.
1983 In parts of your submission you indicate that it’s likely that the NG9-1-1 network would make use of existing ILEC facilities. Can you just clarify whether the ILEC would be compensated for the use of those facilities through contribution fund?
1984 MS. LAU: Yes, we would consider that to be 9-1-1 operations. Yeah.
1985 MR. BOWLES: And in your view, would that require the ILECs to file new tariffs that account for funding to be provided through the NCF at least for certain uses of those facilities and services?
1986 MS. LAU: Yes, that could be one way of doing it. Or the administrator could also in itself decide how it would -- what it would believe to be reasonable on a year-by-year basis and allocate the funding appropriately.
1987 MR. BOWLES: Okay. Earlier there was a discussion about confidentiality and disclosure, and what I heard -- correct me if I’m wrong -- was that under the administrator approach nothing, or at least a lot less, would be confidential. Can you explain how that would be so? How is it that the administrator would ensure that information -- sorry, how would the public get access to more information?
1988 MS. LAU: Well, there would be more regular reporting from the administrator itself, which would be publicly available.
1989 MR. LAWFORD: Yeah, that’s basically it. That there would be an annual report with here’s what everybody got, and at the back lots of tables if you really want to dig through that stuff. And at the front end there would be a high-level sort of here’s how much we funded to Western Canada, here’s how much we did in Eastern Canada, here’s how much PSAPs were transferred if they do that, here’s how much we spent on video upgrades and that sort of thing.
1990 Does that answer the question?
1991 MR. BOWLES: I think so. But it would be more on expenditures and less on costs the information that would be obtained, disclosed?
1992 MR. LAWFORD: Yeah, and it depends on how -- I don't know how the Commission's going to go with this, whether it's going to be all regulated up and down with costing or not, or whether there's going be a price cap kind of approach. So it depends. I mean, there may have to be some information on costing, if that's the approach the Commission takes and yeah, it could get messy, but it would be a big work, but yes, I guess the costing would have to be in there as well if you were to require all the costing.
1993 MR. BOWLES: Moving to privacy, the existing -- under the existing regime, the ILECs are subjected to certain Commission-imposed privacy obligations to -- that only provide information -- certain information to PSAPs on a confidential basis and only to be used for the purposes of responding to the emergency for which that information is being transmitted. It's my understanding that there are agreements in place between the 9-1-1 operators and the PSAPs that further reflect these same obligations.
1994 Given that, is -- I'm struggling to understand the need for this opt-in/opt-out if the information is already subject to restrictions that it can only be used to respond to the emergency that triggered the transmittal of that information.
1995 MS. LAU: How the Commission implements those principles is not necessarily as important to us, but we wanted to make sure, in contemplating next-gen 9-1-1 and the types of data which could be shared in -- over that system, that the principle of consent, the requirement for consent is considered in the Commission's establishment of this framework.
1996 MR. LAWFORD: And I just add, you know, what we're talking about is feeding new information in from the start of the pipe, from the individual, because you make a 9-1-1 call now, it's about me calling from my home, I have this emergency, and that gets all transmitted down the line. And you're right, it's confidential all the way and it stops at a certain point and they don’t aggregate it and so on.
1997 But if I start enriching that with my new App or you know, and know they can take the information, I'm the source of this new personal information, so I get to have the consent over whether it goes into the system. That's what we're saying.
1998 Our concern is just that there's not -- and we've seen this with emergency alerting -- there's been calls for, you know, people to -- "oh, well, we have a database of everybody who has asthma in this region, so let's just send it to the national -- into the emergency coordinators." And then they'll -- if I call and they see that I'm an asthma person, they send somebody with extra oxygen in the ambulance.
1999 We're trying to keep that out. We're trying to say that when there's new personal information, new health information that gets added by the individual, that has to be with consent. That's what we're trying to get at.
2000 MR. BOWLES: But you consider that the existing obligations don’t cover that or guard against that mischief, if you want ---
2001 MR. LAWFORD: I guess they guard against it, but perhaps we're doing belt and suspenders here, but we don’t know where -- it's just the best practice when you're asking for new information at the front end you get consent. That's the principle.
2002 MR. BOWLES: Now, just two more questions, and then I want to go back to what seemed like the beginning of an undertaking.
2003 You talked about one of the benefits of having this administrator would be establishing standards, so rather than having four people working on -- I believe you spoke of the video solution as a hypothetical example. Would the Commission not be able to establish those standards?
2004 MR. LAWFORD: Yes, the Commission could. It depends on how much day-to-day the Commission wants to get into this. So once you set up a national administrator and you say, "Go forth and do this," I mean, to some extent, the Commission doesn’t want to babysit. It's only when it comes back, somebody says, "We cannot agree on the standard for video. Can you guys finally decide?" That would be the Commission's role there, so yes, that's how we envision that.
2005 MR. BOWLES: Okay. One ---
2006 MS. LAU: And ---
2007 MR. BOWLES: Sorry?
2008 MS. LAU: Yeah, and the relationship or interaction could be somewhat similar to the Commission's interaction with ESWG today, so ---
2009 MR. BOWLES: Okay. And one last question before moving on to the undertaking.
2010 You spoke at length about the funding responsibilities of your proposed administrator and made reference to 46.5 of the act as the basis for permitting this, but your proposal also contemplates a broader set of responsibility to the administrator. How would the Commission go about providing those responsibilities to your proposed administrator?
2011 MR. LAWFORD: You mean jurisdictionally?
2012 MR. BOWLES: Yes.
2013 MR. LAWFORD: Well, let's go down the list. Forty-six point five (46.5), if it's a basic service, there's all that stuff. Forty-six point one (46.1), there's a lot you can tie onto the fact that you're using 9-1-1 in the databases that go onto it there.
2014 Okay, and then you're going through section 47 and you have to, you know, look at the policy objectives in section 7, so you're doing that, so then you can set conditions. Now you're setting conditions on people as operating TSPs in Canada. They have to be involved with the 9-1-1 administrator.
2015 I don't know. What else do we check in there? I think that's about all I can think of at the moment. But that's a lot of pegs to hang your jurisdictional hat on.
2016 MR. BOWLES: But putting aside the funding aspects ---
2017 MR. LAWFORD: Yeah.
2018 MR. BOWLES: --- how does the Commission issue directives to the administrator, should it feel the need to issue directives?
2019 MR. LAWFORD: My understanding is -- I don't know how it's done mechanically with the National Contribution Fund or the VRS right now, but I understand the Commission could always, on its own motion, take that initiative. But normally, it's done through a public process or some sort of process first.
2020 You wanted to say something?
2021 MS. LAU: Yeah, and other interrogatories with the Commission, the Commission's also asked about delegation powers and so forth, so we believe that's also available.
2022 MR. LAWFORD: Yeah, and as a delegate, they get to oversee the delegate. And then I also forgot reporting. I presume the Commission would ask for at least an annual report every year, and if there was something in the reporting that mentioned that they wanted guidance or if there was something that caught the Commission's interest in reporting, they could certainly inquire after it, yeah.
2023 MR. BOWLES: Okay. You referenced -- in one of the responses to your interrogatories you reference sort of in passing -- I think it's at the end of your -- one of your responses -- you make a reference to 46.1 and 46.2 of the Act. An undertaking was asked by the panel yesterday of Shaw to better explain how it is that their proposed consortium fit the conditions present in 46.1 that the body be established to facilitate the interoperability of networks and also how the consortium that they contemplated was one that would administer operational aspects relating to Canadian telecommunication networks.
2024 Can we get you to undertake to do the same exercise with respect to your proposal?
2025 MR. LAWFORD: Yes, and we look forward to doing that.
2026 MR. BOWLES: Okay.
2028 MR. BOWLES: My last one was, I -- at some point in your conversation with Commissioner Vennard, there seemed to be the beginning of an undertaking having to do with, I guess, the board of governance of your administrator, who would be the members, the size of the board and its composition, how it would reflect a geographic diversity.
2029 I'm not sure if the Panel still wants that as an undertaking, but if they do, can we undertake that for the record, can we get your undertaking to provide that information?
2030 MS. LAU: Yes, we will, and I'll probably clarify with legal counsel after our appearance.
2032 MR. BOWLES: Okay, thank you. That's all.
2033 THE CHAIRMAN: You got more homework there at the end than you probably were hoping for, but there we are.
2034 Thank you very much for your participation at this phase of the hearing, and we will adjourn til 10:55 to do the next intervenor. Thank you.
--- Upon recessing at 10:42 a.m.
--- Upon resuming at 10:57 a.m.
2035 THE CHAIRMAN: À l'ordre, s'il vous plaît. Order, please.
2036 Madame la Secrétaire
2037 THE SECRETARY: Thank you. We'll now hear the presentation of E-Comm 911. Please introduce yourself and your colleague, and you have 20 minutes for your presentation.
2038 MR. WEBB: Thank you. Good morning, Mr. Chair, Mr. Vice-Chair, Commissioners, and Commission staff.
2039 My name is Michael Webb. I am Vice-President of Technology Services for E-Comm, Emergency Communications for British Columbia. I am accompanied by Naomi Arita, who is a Senior Technology Service Delivery Manager with E-Comm.
2040 We are honoured to be here today as representatives of E-Comm and on behalf of a significant number of municipal governments, regional districts and emergency response agencies in British Columbia that are stakeholders in E-Comm.
2041 I would like to clarify that E-Comm is participating as an intervener in this consultation as both a primary and secondary Public-Safety Answer Point (PSAP).
2042 Our submissions with respect to the establishment of a regulatory framework for next-generation 9-1-1 in Canada draw from our experience as a PSAP and also as a provider of mission-critical technology services that support the operations of PSAPs and first responders in the field.
2043 We are the largest 9-1-1 PSAP in British Columbia. We provide primary PSAP functions for 88 percent of the province’s 9-1-1 call volume. That equates to approximately 1.35 million calls annually.
2044 Our role is to answer and triage emergency calls directly from the public -- that is the primary PSAP function -- and then transfer those calls to the appropriate secondary PSAP, which may be another work group within E-Comm or operate external to E-Comm in another geographic location within the province.
2045 In addition to primary PSAP service, we also provide integrated emergency and non-emergency call-taking and dispatch services for 35 police and fire departments within southwestern British Columbia, where we operate as the secondary PSAP for these response agencies.
2046 When we provide secondary PSAP functions, we process calls according to the policies set out by the response agency for which the call is destined. We collect and log information relevant to the event, including the call audio. We dispatch the required resources and hand-off the on-scene and investigative response to the ERA, the response agency.
2047 E-Comm also provides a variety of secure, mission-critical technology services that support our PSAP operations and those of our public safety partners, the agencies that we dispatch.
2048 E-Comm was established in 1997 under unique provincial legislation, the Emergency Communications Corporations Act in B.C. We are owned and funded by the jurisdictions and public safety agencies we provide services for.
2049 As we indicated in our intervention and associated request for information responses, E-Comm supports the submissions made by the Province of B.C., the Coalition of the Willing, the Consolidated PSAP and CITIG as part of this consultation.
2050 I would like to speak to seven of the main points we made in our intervention, all of which directly contribute to E-Comm’s view of the actions the Commission should take as outcomes of this consultation process.
2051 As with our written submission, I will use the term “NG9-1-1 network infrastructure” to describe the underpinning i3 Emergency Services IP Net, ESInet, that provides NG9-1-1 network services. I will also use the term “NG9-1-1 capabilities” to describe the new or enhanced forms of information exchange and the channels of communication such as text messaging and other forms of multimedia content delivery to PSAPs.
2052 Point number one. E-Comm respectfully submits that the Commission should establish a regulatory framework for NG9-1-1 that preserves the effectiveness of today’s 9-1-1 services and enables gradual, phased transition to NG9-1-1 network Infrastructure and enables the development of NG9-1-1 capabilities by PSAPs.
2053 While we firmly believe the evolution of 9-1-1 services in Canada to NG9-1-1 is required, this transition presents many yet-to-be-answered questions and concerns for all stakeholders. It could take up to a decade or more to complete, with legacy 9-1-1 networks needing to coexist with NG9-1-1 network infrastructure until all services and operations can be transitioned.
2054 It is imperative that rollout plans for NG9-1-1 capabilities, by PSAPs, across the country be harmonized in order to ensure Canadians maintain a consistent expectation and understanding of NG9-1-1 services. Similarly, primary and secondary PSAPs and response agencies across Canada will need to work together to address the challenges they will face during this transition.
2055 Point number two. E-Comm respectfully submits that the Commission should take action to ensure NG9-1-1 network infrastructure continues to be provided as a service by Incumbent Local Exchange Carriers and regulated by the CRTC as an evolution of the current practice for 9-1-1 network services.
2056 E-Comm believes this type of service delivery model is preferred in order to ensure stability, sustainability, and reliability of the network infrastructure and ensure that the service is provided on a consistent and universal basis.
2057 Under this service model, NG9-1-1 network infrastructure should continue to be funded through wholesale access tariffs on landline and wireless devices, but with applicability to additional devices and network access services that are capable of initiating PSAP contact in an NG9-1-1 environment. This would be an extension of the tariff regime, or something similar, that currently exists for 9-1-1 network services today.
2058 The current 9-1-1 network service delivery model with the ILEC -- in our case TELUS -- serving most of British Columbia works well for us, for E-Comm, and we do not wish to see it significantly changed as part of an evolution towards NG9-1-1.
2059 Beneficial aspects of the current model are consistency, reliability, resiliency and universality of the service across the province; clear accountability for the 9-1-1 network service and a single point of contact for PSAPs in the province related to operational support of the service; and finally, availability of a high level of capability, knowledge and expertise, borne from history, and experience related to various aspects of the 9-1-1 infrastructure and service.
2060 I would also like to mention a service provider that is heavily invested in the community and therefore very much accountable to the citizens of British Columbia and putting at risk its reputation as it provides these types of services.
2061 However, as described in our written intervention, we would like to see enhancements related to service management for the NG9-1-1 network infrastructure in the areas of network design standards, service level agreements, outage notification and service reporting. The goal should be national harmonization and consistency in these aspects of the NG9-1-1 network infrastructure service.
2062 Point number three. E-Comm respectfully submits that the Commission should take action to ensure NG9-1-1 network infrastructure is consistent, harmonized, and integrated across Canada while being provided by multiple service providers.
2063 Although the i3 architecture defined for NG9-1-1 includes significant redundancy, E-Comm submits there is merit in having multiple NG9-1-1 network infrastructure service providers, each providing infrastructure and services in different parts of the country.
2064 If correctly designed and implemented, the resulting ESInet would operate as a single, integrated national network with geographic diversity and redundancy addressing infrastructure failure situations and enabling load balancing and sharing for relevant ESInet functions.
2065 An added benefit of having multiple service providers is the ability for the Commission to assess multiple perspectives on the costs and best practices associated with the NG9-1-1 network infrastructure, the required service metrics, and the design practices to achieve those service levels.
2066 Point number four. E-Comm respectfully submits that the Commission should direct the development of NG9-1-1 network infrastructure in a manner that prioritizes mitigation and resolution of operational issues associated with today’s current 9-1-1 services.
2067 Today, certain types of interactions between the public and PSAPs must be manually processed as they either do not route through the 9-1-1 network or do not provide appropriate location or subscriber information. These include, but are not limited to: Voice over IP services that require 9-1-1 services to be triaged by a third-party service provider; alarm monitoring and automatic collision notification calls; and calls from PBX’s just distributed over multiple locations.
2068 These types of calls present numerous issues that negatively affect PSAP operations because the normal call handling process does not apply and subscriber identification and location information is not appropriately transmitted. The net result is slower call handling and unavoidable delays in emergency response and also inefficiencies in the use of emergency response personnel.
2069 We can cite many examples of these issues. A common one in our jurisdiction is calls to 9-1-1 from a large metro hospital, which consists of multiple buildings spread over a large campus. Invariably, the lack of ANI/ALI provided by the hospital’s PBX causes great delay in emergency response and unnecessarily consumes a large amount of call-taker and police time in trying to locate the caller.
2070 E-Comm hopes that the Commission will act to cause these issues to be universally addressed and resolved through early introduction of NG9-1-1 network infrastructure. In addition, we support and applaud the ongoing efforts of the CRTC and the Emergency Services Working Group that is aimed at delivery of highly accurate location and dispatch address information to all PSAPs for all types of 9-1-1 calls.
2071 Point number five. E-Comm respectfully submits that the Commission should ensure that its regulatory policy and framework for NG9-1-1 network infrastructure specifically addresses the responsibilities, needs and, concerns of secondary PSAPs and the emergency response agencies -- police, fire, and ambulance services in particular -- related to development of NG9-1-1 capabilities.
2072 I’d like to point out that for the purpose of Telecom Regulatory Policy 2016-165, the Commission defined the 9-1-1 network as beginning at the point of interconnection between the originating networks and the 9-1-1 network, and ending at the demarcation point between the 9-1-1 network and the primary PSAP. By implication, therefore, connections to secondary PSAPs and emergency response agencies were deemed or determined to be outside the scope of the 9-1-1 network. We believe this viewpoint must change as we transition to NG9-1-1.
2073 E-Comm submits that there is such a thing as too much information from the perspective of a primary PSAP. Voice will always be the most efficient and fastest method for a call-taker at a primary PSAP to communicate with callers, except in situations where a caller is unable to speak. And there, of course, are other approaches that may be quite valid in that situation.
2074 In addition, the call-taker must receive accurate caller identification and location information in order to do their job.
2075 Primary PSAPs, as we currently operate, do not require additional information on the caller or details of the emergency event in order to perform this function. This will remain the case through the transition to NG9-1-1 unless the primary PSAP function were in some way to be superseded in the future, which is a possibility, we believe.
2076 It is our view, therefore, that secondary PSAPs and emergency response agencies will be the primary recipients and beneficiaries of multimedia content and information provided through NG9-1-1 capabilities. And, for this reason, NG9-1-1 regulatory policy and framework needs to consider these entities as users of the network infrastructure, of the NG9-1-1 network, with service providers being obligated to serve them according to tariff or such other regulatory regime that may exist.
2077 A very good illustration of the real-world challenge we commonly face as a secondary PSAP occurs in situations where the caller has a photo that would be beneficial to the response, for example, picture of robbery suspect, missing child, etcetera.
2078 There is currently no simple or consistent method for the caller to transmit that photo to the PSAP and forward to the responding police member. Usually the member needs to meet with the caller and they arrange a direct electronic transfer after having met. In addition to being cumbersome and slow, this process doesn't always preserve the photo for use as evidence or enable it to be appropriately accessed and controlled.
2079 Point number six. E-Comm respectfully submits that the Commission should ensure that its regulatory policy and framework for NG9-1-1 network infrastructure enables agencies providing services in support of 9-1-1 to utilize services provided by the NG9-1-1 network infrastructure, whether that’s at origination or termination.
2080 All TSPs, ISPs, and providers of internet-based multi-media communications services, along with all agencies that receive calls for service from the public, from PSAPs or from emergency response agencies, should be able to forward or receive traffic via the NG9-1-1 network infrastructure with full interoperability and information exchange, for example, or i.e., location and subscriber information and whatever the multimedia content is that’s associated with the call.
2081 This should include public service and public safety answer points such as crisis lines; 8-1-1 health lines, poison control centres; joint-rescue coordination centres; provincial emergency response and fire response centres; and municipal information lines such as 3-1-1. National and international connectivity should also be supported.
2082 In our operating area, it is very common for us have to transfer calls to the joint-rescue coordination centre and act as an intermediary for transfer of ANI/ALI information provided by the 9-1-1 network because the JRCC is not on the 9-1-1 network, as well as handling multiple call-backs because callers in remote areas needing rescue will often hang up to preserve cell-phone battery life and they are unable to contact JRCC directly.
2083 Point number seven. E-Comm respectfully submits that the Commission should support, enable and facilitate a collective, national approach to the development and introduction of NG9-1-1 capabilities. These are operational capabilities as implemented by the PSAPs.
2084 E-Comm submits that it is of utmost importance to the PSAPs and the public that uniform NG9-1-1 capabilities be introduced in a coordinated fashion across Canada.
2085 In order to achieve a consistent service offering, a national coordinating entity needs to be created to provide oversight and guidance on new capabilities, policies, standard operating procedures, and service levels on behalf of all PSAPs and emergency response agencies in Canada. A further mandate should be to ensure coordinated rollout of these new capabilities within a reasonable timeframe.
2086 From our perspective, a lack of national coordination made the rollout of T9-1-1 for deaf and hard-of-hearing across Canada a difficult experience both for the users of the service and for the PSAPs providing the service.
2087 We introduced it in March of 2014 but today, nearly 3 years later, T9-1-1 is still not fully rolled out by primary and secondary PSAPs and the awareness and utilization of the service is also quite low as a result of fragmented and uncoordinated efforts at public communication and also because of certain limitations with the service.
2088 While we recognize that coordinating the operational development of NG9-1-1 capabilities is not within the Commission's mandate or responsibility, the Commission can work with all stakeholders, including the telecommunications service providers it regulates, to establish and support a national coordination -- a national organization that would assume this responsibility.
2089 At this point, I’m going to turn it over to Naomi and ask her to speak to some issues and challenges that PSAPs face in the transition to NG9-1-1.
2090 MS. ARITA: Thanks, Mike.
2091 Before I wrap up, we would like to touch on several of the points we made in our intervention regarding the issues and challenges that will be encountered by PSAPs during the transition to NG9-1-1 in Canada.
2092 E-Comm believes the overall transition to NG9-1-1 presents many yet-to-be-answered questions and concerns for primary and secondary PSAPs and other stakeholders including ERAs, emergency response agencies, and the public.
2093 Ensuring benefits to emergency responders, there will need to be significant consultation with ERAs to ensure the introduction of NG9-1-1 capabilities primarily benefits and doesn't hinder their operations.
2094 NG9-1-1 enables potential benefits to ERAs as a result of new modes of communication or information exchange. This includes better dispatch-location information and delivery of supplementary information such as photos or videos that enhance the ability to respond to an incident and undertake post-incident investigation or follow-up.
2095 However, challenges will be experienced in processing new types of information received, both in terms of new operational procedures and policies and the efficient handling of large amounts of incident-related electronic information received at PSAPs. There are also significant privacy and confidentiality issues that need to be addressed as identified in our written intervention.
2096 We believe that spearheading the necessary consultation and working to define the set of NG9-1-1 capabilities that should be implemented, including the appropriate timelines, is a very important role for a national coordination -- coordinating entity.
2097 Impacts to PSAP staff and operations. Major consideration must be given to the impacts of NG9-1-1 on PSAP staff including training, recruitment, and their overall well-being.
2098 There are significant potential pitfalls in the following areas. Text-to-9-1-1 and other forms of non-audible communication may result in the loss of critical information for PSAP operators currently available via human voice interaction. Receipt of graphic depictions of emergency situations through images and videos will increase the level of trauma among call-takers and dispatchers. As additional forms of information are received, the complexity of the work and the mental demands on PSAP staff will increase.
2099 New forms of communication and content should not automatically be pushed to a call-taker, dispatcher, or operational analyst but should be selectively viewed or pulled. The preferred operational process is an issue that would be best addressed by a national PSAP operating organization.
2100 Funding. There is an expectation that the costs and resource requirements of NG9-1-1 will be substantial and public sector organizations will have a challenge in addressing those pressures.
2101 Increase in funding will be required for PSAPs and ERAs to support technology upgrades, increased PSAP staffing levels, and increasing recruitment, training, and quality assurance expenses.
2102 Although NG9-1-1 will be introduced, in part, to respond to increased demands from the public, significant education will need to be jurisdictional -- will be needed by jurisdictional authorities -- municipalities, provincial governments -- to educate the public on the demands and costs associated with NG9-1-1.
2103 Timing and national coordination. Harmonizing policies, standards, and operating protocols and delivery of NG9-1-1 capabilities is an expected challenge.
2104 In the same way as the current 9-1-1 service or "brand" is universally understood, meaning the public knows how to make a 9-1-1 call and what to expect when doing so, the NG9-1-1 service must be similarly universally understood at least across Canada, preferably across North America and, ideally, globally, both by the PSAPs and the public. This level of harmonization is going to take a significant amount of time to achieve.
2105 Transition to NG9-1-1 will also be constrained by how quickly telecom infrastructure owners enable and upgrade their networks once the necessary regulatory enablers are in place.
2106 E-Comm believes that the Commission will need to apply its regulatory powers to ensure telecom service providers establish and adhere to their respective time projections.
2107 In parallel with the implementation of the NG9-1-1 network infrastructure, PSAPs will have to implement a number of technological upgrades in order to receive and process traffic from the i3-based ESInet. This will require funding, resources, and time to procure equipment, implement, test, and verify.
2108 There is further dependency on vendors of PSAP technology systems, including telephony and call centre management systems, computer-aided dispatch systems, and media logging system to upgrade their products to the new standards before PSAPs can procure and implement those upgrades.
2109 MR. WEBB: So I’ll just wrap up, then, by summarizing our views into three key themes.
2110 Number one, the regulatory approach for NG9-1-1 needs to be evolutionary and build on the strengths of the current framework.
2111 Number two, the first priority is addressing limitations with current 9-1-1 services, followed by gradual introduction of new capabilities.
2112 And number three, national coordination is a critical requirement both at the operational side and, as has been discussed by other intervenors, with respect to the provision of network infrastructure.
2113 So I’d like to thank you for your time and attention, and for providing E-Comm and our stakeholders the opportunity to express our views on this important matter. I welcome any questions you may have.
2114 THE CHAIRMAN: So thank you for your presentation. I’m just going to have a few questions on an assorted number of areas so bear with me.
2115 MR. WEBB: Okay.
2116 THE CHAIRMAN: Certainly one of the basic issues that we’ll be tackling with is what’s the best delivery approach for the network components. And you are advocating a continuation, I guess, of the status quo through an ILEC-delivered model. But others are suggesting the creation of a national consortium, although there’s variations on exactly how that would look like.
2117 Now, in your presentation and elsewhere, you’ve obviously gone through the benefits of keeping the ILEC approach. I wouldn’t mind getting your perspective, including from a secondary PSAP perspective if that’s different, with respect to the creation of a national consortium and what you see as the downsides of going down that route.
2118 MR. WEBB: So when you say national consortium you’re talking about a national consortium to operate the ---
2119 THE CHAIRMAN: Yes.
2120 MR. WEBB: --- NG9-1-1 network, right?
2121 THE CHAIRMAN: Network, yes.
2122 MR. WEBB: Right, yeah.
2123 I think one of the downsides to that approach would be with respect to the relationships that PSAPs and, you know, primary and secondary PSAPs would or could have with that national provider, right. One of the reasons we advocate continuation of the ILEC model is because we have a very close working relationship, you know, and that’s down to individual, personal relationships as well as, you know, that our ILEC provides in terms of the position it has in the community and how invested it is in the community.
2124 And I think if that function were to be provided by a national provider, we would be very concerned that, you know, the unique attributes of how we operate, the unique concerns that we have in British Columbia -- and our model is a little bit different in terms of how 9-1-1 is provided and how it’s governed and even funded -- that that would be creating a disconnect, I think, between what our needs are or the ability for, you know, our needs to be addressed by that service provider.
2125 I think the other point that I would raise here is that we also need a turnkey service to be provided, and we need that service to be measurable, to obviously have, you know, some form of service-level target or service-level agreements that go with it and, you know, because it’s something that today we don’t worry a lot about.
2126 We have enough issues to deal with in terms of operating our own infrastructure, operating our PSAP, operating our systems, managing the information that we maintain, that having to worry about putting multiple pieces of the 9-1-1 network service together, doing that level of integration that’s just something that we’re not ready at this point, or capable really, or even funded to take on at this point.
2127 THE CHAIRMAN: Are those insurmountable problems?
2128 MR. WEBB: I don’t know that they’re insurmountable in the, you know, in the long run. I think for us, resourcing and funding would be major concerns. And as has been discussed many times through this consultation, you know, funding is the domain of municipal and provincial governments, well, funding for PSAPs. And that includes funding for the systems and technologies that we use.
2129 So for us it would be probably a fairly difficult and fairly long process to convince our stakeholders that we may need to step up, you know, resourcing the funding that we have because we’re no longer getting the same level of service or the same completeness of the service from the network service provider if that were to be the case.
2130 Now, there probably are models that involve national service providers where, you know, that end-to-end responsibility would be provided by the service provider. But I would be concerned that, you know, that we would still potentially have issues to deal with. Okay, what is required in B.C. and how might it differ from what is required in Ontario or what have you? And goes to the point of coordination at the national level.
2131 THE CHAIRMAN: Right. I mean, at this point we’re not making decisions, we’re trying to build a record.
2132 MR. WEBB: Yeah.
2133 THE CHAIRMAN: So you’ve mentioned the relationship aspect as being, I think, one of your major challenges. At first blush, that doesn’t seem like to be an insurmountable issue that ---
2134 MR. WEBB: I don’t think it’s insurmountable.
2135 THE CHAIRMAN: It’s a question of ---
2136 MR. WEBB: As I said, I think it will take time and it could make the transition more challenging.
2137 THE CHAIRMAN: Okay. What impact would it have, in your view, on the quality, reliability of the mission critical aspect of it? And that’s delivering 9-1-1 capabilities.
2138 MR. WEBB: The impact from my perspective, and from I think those of our stakeholders, would be to do with are we asking additional risk, right, related to the ongoing operation of, you know, a mission critical life safety service, right?
2139 Dealing with new technology vendors that you’re not used to dealing with is always fraught with risk, risk of service interruption, risk of things that don’t work the way you thought they were going to work, you know, those sorts of things. Now, there are solutions to those issues. And again, it comes back to time and resources to test and to validate.
2140 THE CHAIRMAN: But presumable it’s an iterative process.
2141 MR. WEBB: Yeah.
2142 THE CHAIRMAN: You don’t switch the entire country’s switch overnight.
2143 MR. WEBB: Right, that’s right.
2144 THE CHAIRMAN: You only do that in Phoenix.
2145 MR. WEBB: Yeah.
2146 THE CHAIRMAN: You do testing, you do analysis part by part, and you make course corrections based on that.
2147 MR. WEBB: Yeah, and that’s the process we would follow. As I said, we are very risk-averse, you know, in terms of changes that we make to our technology infrastructure. I would say that from our perspective in having to deal with multiple service providers for some extended period of time through a transition, from today’s network infrastructure to whatever the future is if it’s a different service provider, that would also complicate matters.
2148 And really at the end of the day it’s about resource and time, right, to ensure that risk has been retired in this transition process.
2149 THE CHAIRMAN: Right. To what extent did that complexity of a changing environment become a driver to the consolidation that’s occurred through E-Comm over time?
2150 MR. WEBB: I think it very much has been. The consolidation of primary PSAP services in B.C has for the most part been driven by financial and economic factors on behalf of the regional districts that were previously getting their services from another service provider, and we were able to provide a service that met the same level of service at a lower cost-point.
2151 But I think many of them did factor into their decision-making that they don’t know where 9-1-1 is going. They anticipate that there are going to be cost increases. That if they’re already seeing escalation, you know, with their incumbent provider as they were what’s going to happen when NG9-1-1 capabilities come along, both in terms of costs of technology but also what are the operating costs that are going to be passed on? So very much it was a factor, I think, that drove the primary PSAP consolidation.
2152 I think there’s different issues that are driving our secondary PSAP, growth in our secondary PSAP business.
2153 THE CHAIRMAN: Right. Despite you not being a fan of the national consortium, in point 7 you still make the point that there’s a need for coordination.
2154 MR. WEBB: Yeah.
2155 THE CHAIRMAN: And there’s a couple of models floating around. I’d like to have your views on them. I think you’re generally supportive of the position of the Coalition of the Willing ---
2156 MR. WEBB: Yeah.
2157 THE CHAIRMAN: --- which seem to suggest that there should be some sort of coordinating body.
2158 MR. WEBB: Correct, yeah.
2159 THE CHAIRMAN: There’s others that have advocated that the SOREM model would be another venue to advance some of this coordination.
2160 And you today of course have reiterated the ESWG as the more appropriate model. And I’d like to see what your views are on each one of those, and do they have perhaps parallel coordinating function?
2161 MR. WEBB: Yeah, I think they do. I think there are different functions here, right. What we’re talking about when we reference the Coalition it’s really about coordination of the development of these services as provided by PSAPs and how those services are actually delivered. So that for the most part is operational. Coordination it’s best practices. It’s best practices around training, around management of information or on public education; those types of things.
2162 I think there are parallel tracks related to coordination of the network services or network infrastructure capabilities. And part of that, you know, relates to the Commission’s role as a regulator but part of it is just related to technical coordination and the coordination related to timing and rollout of those types of services. I think those are distinct functions.
2163 I don’t know that we are making -- taking a position that how the network service provider is to be governed or regulated particularly is of concern to us. I think we are saying that we like and we see benefits in the current ILEC model.
2164 But I think there are different coordinating and, you know, consortium of what have you type models that may apply there, and I’m not sure we’re taking a particular position about which of those -- or even whether, you know, the access tariff model needs to continue or whether there are alternate funding models as well.
2165 So I think I’ll summarize that by saying there are these different roles that these coordinating functions that do need to be established and need to take on.
2166 THE CHAIRMAN: Right. So let me put it to you that -- would it be appropriate for us to use the emergency services working group to play that coordinating function with respect to the network aspect to it? That’s the stuff that falls clearly within our jurisdiction.
2167 And yet there’s another component that’s more dealing with the PSAPs and their operations. And do you agree with the Coalition of the Willing that we should nudge along some sort of time-limited coordinating body that would deal with that aspect just to make sure that it would occur?
2168 MR. WEBB: Yes. Yeah, we do.
2169 THE CHAIRMAN: And that is a better -- creating new venue is better than using SOREM?
2170 MR. WEBB: Yeah, I believe so. I think there will be challenges with ---
2171 THE CHAIRMAN: Why do you believe that?
2172 MR. WEBB: Pardon me?
2173 THE CHAIRMAN: Why do you believe that?
2174 MR. WEBB: I think there will be challenges with getting SOREM to take on the operational coordination role. I don’t think it fits the purpose of that organization or that structure. And that’s mainly because the provision of 9-1-1 PSAP services is primarily done at a municipal or regional and, in some cases, provincial level. But it -- I don’t think it fits with the mandate of SOREM very particularly well.
2175 However, I do think at a policy level there is a role for SOREM to play to ensure that there is coordination done at a national level. But I don’t know down in the -- actually doing the work fits in that organization’s mandate.
2176 THE CHAIRMAN: Hence the need for a coordinating function ---
2177 MR. WEBB: Yes.
2178 THE CHAIRMAN: --- similar to what we have for number portability.
2179 MR. WEBB: Right.
2180 THE CHAIRMAN: Right. That’s the proposal of the Coalition.
2181 MR. WEBB: Yeah, the numbering administrator, I think, is what the Coalition has advocated, yeah.
2182 THE CHAIRMAN: Now, again with respect to network design, in a sense, in point three you make the argument today that you like -- well, in addition to the ILEC model, you like the multiple service providers as opposed to one national service provider.
2183 I’m just trying to understand. Do you mean that we should keep the current regional distribution of ILECs, which could include Bell, Telus, MPSS?
2184 MR. WEBB: That is what’s behind point about multiple service providers ---
2185 THE CHAIRMAN: Right.
2186 MR. WEBB: --- is we like the regional focus of the organization that we deal with ---
2187 THE CHAIRMAN: Right.
2188 MR. WEBB: --- its local presence and its local capabilities and resources. And so if this were to be consolidated -- as I said a minute ago, if it were to be consolidated at a national level, we feel that we would lose that capability, or lose that benefit.
2189 THE CHAIRMAN: Is it just a question of local knowledge, you know, and relationships, or does it also go to reliability, redundancy, security, scalability?
2190 MR. WEBB: I think it covers all of those things.
2191 THE CHAIRMAN: How so?
2192 MR. WEBB: Well, I’ll give you an example. Our primary operating building in Vancouver, it actually sits on the boundary between two Telus central offices, and so we do have diverse facilities from both central offices feeding 9-1-1 services into our building.
2193 I guess this is -- this to the -- this is going, I guess, to the point of, you know, the advantage, -- or the amount of infrastructure that the incumbent actually has is another factor here, right? So, you know, I think there’s a number of factors here that suggest that and organization that is invested in the community, in our case in British Columbia, is best suited to provide service to local government and, you know, PSAPs, basically, that are in the public safety business.
2194 THE CHAIRMAN: Under this regional delivery model, what’s your view of Prince Rupert; would CityWest continue to operate there?
2195 MR. WEBB: I missed part -- I’m sorry.
2196 THE CHAIRMAN: In Prince Rupert, would CityWest continue to operate there?
2197 MR. WEBB: Prince Rupert? We don’t deal with Prince Rupert at all. I believe ---
2198 THE CHAIRMAN: Okay.
2199 MR. WEBB: --- they provide ---
2200 THE CHAIRMAN: So you have no views on ---
2201 MR. WEBB: --- their own 9-1-1 service, so ---
2202 THE CHAIRMAN: Yeah, CityWest delivers there.
2203 MR. WEBB: Yeah.
2204 THE CHAIRMAN: So you just -- but in your vision of a regional delivery model ---
2205 MR. WEBB: I think in their particular case -- and I’m maybe, you know, overstepping my knowledge here a little bit but I think they would have to become users of that regional network because I don’t think you can justify, at that scale, implementing an NG9-1-1 network just to serve the community of Prince Rupert.
2206 THE CHAIRMAN: So even with your regional model, there’s a limit to how small ---
2207 MR. WEBB: Yeah.
2208 THE CHAIRMAN: --- it can be, right?
2209 MR. WEBB: I would think so.
2210 THE CHAIRMAN: Is that correct? Do I understand?
2211 MR. WEBB: Yeah.
2212 THE CHAIRMAN: You need something with girth, experience, depth ---
2213 MR. WEBB: Yeah.
2214 THE CHAIRMAN: Okay. In point six you address, in part, some of my questions about who, in the future, would be able to me a trusted entity that can connect -- interconnect because right now it’s pretty much limited to competitive local-exchange carriers, wireless carriers, PSAPs.
2215 MR. WEBB: Yeah.
2216 THE CHAIRMAN: You clearly envisage that there would be a need for a broader ---
2217 MR. WEBB: Yes.
2218 THE CHAIRMAN: --- list of potentially trusted entities. Do you think that that -- those that -- how do we decide who are the trusted entities that should connect? Is the -- are the examples you’ve given in point six the entire universe of those that you think should be trusted going forward?
2219 MR. WEBB: Well, the examples I’ve shown, actually, in point six are actually termination points.
2220 THE CHAIRMAN: Right.
2221 MR. WEBB: So these are not organizations that necessarily are originating traffic. So -- but they could. So to the point of how do you determine who is a trusted originator or user of the network, I think it has to start with a set of technical standards and criteria that must be met, right? And that would cover, you know, the ability of that service provider to deliver the appropriate information, for example, that a PSAP requires. I think that, of course, is around subscriber identification and location in today’s world, and there may be other factors.
2222 I think there are probably other criteria that are more of a technical nature to do with ensuring that those networks can be trusted at a -- you know, from a security point of view as well, you know, referencing the cyber security concerns that we have with NG9-1-1. So I think it starts with that but on top of that I think there has to be some process -- and this may be a role for a national coordinating entity to determine -- that okay, you know, that type of agency, either delivering traffic to or receiving traffic from the NG9-1-1 network, that there is actually a bona fide value being provided to emergency response either in that region or, more preferably, nationally because -- and many of these types of operations, they’re not unique to B.C. so, you know, I would argue that, for the most part, you can determine probably 95 percent of what’s appropriate at a national level.
2223 THE CHAIRMAN: Right. And when you -- you obviously envisage a process to understand the technical aspects but, I guess, also define some criteria and some vetting criteria for deciding who’s in and who’s out?
2224 MR. WEBB: You would have to.
2225 Go ahead, yeah.
2226 MS. ARITA: We tend to see two types of organizations terminating -- or transferring calls to 9-1-1; it’s either public service -- provincial public service type of calls or commercial. And the provincial public service are the ones that we’ve identified here -- are listed here and there is actually a couple of other like SARS ---
2227 MR. WEBB: Search and rescue.
2228 MS. ARITA: --- search and rescue.
2229 And then the commercial entities would be such as alarm monitoring, ACN, Voiceover IP. And that’s, I guess, a little to the question as to who would be participating funding members of the IP network as well, you know, as far as commercial services into 9-1-1.
2230 THE CHAIRMAN: And do you see this going-forward process falling under the network coordination, which you think should be done under the working group, or coordination under the PSAP part of things? Did you see it falling one side or the other?
2231 MR. WEBB: I think there may be pieces of it in both.
2232 THE CHAIRMAN: Right.
2233 MR. WEBB: I also think that the ---
2234 THE CHAIRMAN: That’s pretty frightening, by the way ---
2235 MR. WEBB: Yeah, I know.
2236 THE CHAIRMAN: --- when you think about operationalizing ---
2237 MR. WEBB: Well, but it’s true, right? I mean I just stated that there has to be technical standards; well, that’s not going to be -- those technical standards are not going to be first and foremost dealt with by the PSAP coordinating group, right? We’re going to be looking to -- whether it’s ESWG or some evolution of such an organization to coordinate technical standards at a national level.
2238 But the other thing I would also add is that there’s a governance funding regulatory component of this, right, so you know, the ability of those other types of agencies to connect to the network, there has to be an appropriate consideration of what, if any, cost recovery is needed.
2239 Now, we’re not advocating that PSAPs be charged for accessing the NG9-1-1 network. And I would probably argue that many of these other public-service type organizations should not as well because they’re providing a public service and a public benefit by being connected; it’s just an improvement.
2240 So I think there’s pieces of that question ---
2241 THE CHAIRMAN: But you might see alarm companies having to ---
2242 MR. WEBB: Because alarm companies, as commercial entities, right, they receive revenue from their subscribers and they provide a service on behalf of their subscribers; they should be recovering ---
2243 THE CHAIRMAN: Right.
2244 MR. WEBB: Or, you know, they should be paying towards the cost of that service.
2245 THE CHAIRMAN: Is that position driven by the fact that interconnection with those entities will provide the ultimate outcome better, that is, saving lives and property, or is it because you want an additional revenue fund so that your local ratepayers aren't taxed.
2246 MR. WEBB: Our motivation is purely to provide a better service, right? Now, it's also to make our operation more efficient, because a more efficient operation, meaning the ability to respond faster, right, less -- it means -- yes, it means less call-taker time, but it also means faster response to the emergency. You know, that benefits public safety, obviously.
2247 THE CHAIRMAN: Under the current system, we recently had a look at, you know, to what extent this current 9-1-1 system is reliable, resilient, and provides the required number -- the right level of security. Right now, the standard to meet is to take all reasonable measures to ensure that 9-1-1 networks are reliable and resilient to the extent possible, a few wiggle worms -- and you know, in -- with the view of best practices, it's the sort of standard that is a diligence standard as opposed to a hard list of criteria.
2248 MR. WEBB: Yeah.
2249 THE CHAIRMAN: Do you think that's the way to go forward on NG9-1-1?
2250 MR. WEBB: I think, given where we are today and what we know today, I think that's an appropriate starting point. But what I would add to it is that data does need to be collected as we move forward in the NG9-1-1 transition, and as these networks become operational, to give us the ability to measure, you know, are these networks actually performing at a level that is appropriate? In other words, not assess the actual measures that are being taken, but assess the outcome, right? So are we receiving a service that is reliable? Are we -- you know, are -- and then how is that to be determined? And the measurement will change, I think, as we go into NG9-1-1.
2251 I think we have another concern in this area, which is really to do with how do we deal with outages and that sort of thing, which isn't part of your question, but I think it is related, right, so ---
2252 THE CHAIRMAN: Right. Well, I was going to ask you, are there practical examples where you would advocate for clear standards to be met because of operational needs, and how do you get to that? I mean, I noted your reference to service level agreements.
2253 MR. WEBB: Yeah. I think today -- a challenge we have today is, we are not actually clear on -- I mean, when I look across the entire breadth of the services that TELUS currently provides to PSAPs in B.C., we are not actually clear what their obligations are or are not, right?
2254 THE CHAIRMAN: So you don’t have a service level agreement?
2255 MR. WEBB: We -- there are agreements, right? There is a standard agreement that exists between local government and TELUS for the provision of 9-1-1 service, but it is not at a level of specificity around what services are being provided. And a good example I'll point to is in Vancouver, you know, we receive 9-1-1 calls through a network ACD service as part of the Centrex service that's part of what -- how the 9-1-1 network is built.
2256 In other parts of B.C., where we also receive 9-1-1 calls, the same level of capability is not necessarily being provided, and there's a lack of clarity as to whether TELUS is or is not, in fact, obligated to provide that today.
2257 So these are some of the things that need to be clarified, I think, and that's why we're arguing for better definition of service level agreements. And of course, you can't have a service level agreement without having some means to measure, you know, performance against it, whether that's at a functional level or whether that's, you know, performance (inaudible) for the standard that ---
2258 THE CHAIRMAN: Right, the metrics of the standard that -- some sort of standard.
2259 MR. WEBB: Yeah.
2260 THE CHAIRMAN: So would you envisage that the need for a model standard level agreement to be developed?
2261 MR. WEBB: I would, absolutely. That would make everybody's life easier, I think, and starting a point.
2262 THE CHAIRMAN: How would that occur from a process perspective?
2263 MR. WEBB: Well, I think in our original thinking on this, we just sort of had the view that, you know, if the tariff, the access tariff regime and then the provincial tariff regime that currently exists, if that were to evolve that those tariffs would be built out and would define these service obligations. I know there is discussion now about this administrative -- network administrator function being established that would oversee funding, and I think that may be an appropriate place for standards of service to actually be defined.
2264 So I think there's different ways that that can be done. I don't think it specifically is a responsibility of a coordinating organization nationally that deals with operational matters, and I'm not even sure it's specifically the responsibility of a technical coordinating group. It sits somewhere in between, because service levels impact costs and vice versa, right, so you have to associate, I think, the establishment of service level agreements with those that are overseeing how funding is being provided.
2265 THE CHAIRMAN: You point out that this is very much an iterative process, that ---
2266 MR. WEBB: Yeah.
2267 THE CHAIRMAN: --- will occur, this transition. Is it too soon to think about a hard stop timeframe to have everyone, including secondary PSAPs, transition?
2268 MR. WEBB: I don't think it's too soon to think about it. I think we need to anticipate or envisage that there will be a milestone or a deadline on -- for all stakeholders, right, the network providers as well as PSAPs. I don't know that we're in a position today to say when it would be, specifically.
2269 THE CHAIRMAN: So then when is the timeframe to decide as to when the timeframe ought to be?
2270 MR. WEBB: Sometime in the future, you know what I mean?
2271 THE CHAIRMAN: Unfortunately, we can't regulate the past.
2272 MR. WEBB: No, exactly.
2273 THE CHAIRMAN: It's -- we don’t have that technology.
2274 MR. WEBB: I mean, without knowing, you know, what the landscape looks like, what the framework is and for example, who's providing the service and having, you know, develop the architecture and define the, you know, the network -- for example -- and they only talked about it in what she stated, that we can't go to our vendors right now and say, "We want you to, you know, help us upgrade our CAD system or our phone system or whatever, you know, to support NG9-1-1," because we don’t frankly know what, you know, the technical details of the service are that we're going to be delivering, right, or providing operations.
2275 THE CHAIRMAN: Sure, but a deadline focuses the mind so ---
2276 MR. WEBB: It does.
2277 THE CHAIRMAN: --- until we even create some sort of pressure as to when the -- when we will turn our minds to when -- to turn off the legacy system, you may not have the people focusing on it.
2278 MR. WEBB: Yeah.
2279 THE CHAIRMAN: So -- and I think you would agree, would you not, that there are operational consequences of being vague as to timeframe?
2280 MR. WEBB: And there are funding issues on our side as well, right?
2281 THE CHAIRMAN: Yeah, yeah.
2282 MR. WEBB: So for example, for us to develop a business plan or business case and then go through the procurement process for an upgrade to our phone system is probably a three-year process, right, just given the way we're funded and governed. And then in parallel with that ---
2283 THE CHAIRMAN: So that speaks -- doesn’t that speak more to how much time between the decision ---
2284 MR. WEBB: Yeah.
2285 THE CHAIRMAN: --- point as to when the -- that will occur in the final ---
2286 MR. WEBB: Exactly.
2287 THE CHAIRMAN: And I take your point that we're maybe not at that stage ---
2288 MR. WEBB: Yeah.
2289 THE CHAIRMAN: --- to decide the final point. What I'm trying to get at is, when should we be deciding as to when the final point will be? And when we decide when that final point will be, obviously, we have to consider the funding cycles.
2290 MR. WEBB: I'm not sure I can answer the question of when should we be deciding -- or sorry, when should the end point be. I think when you decide, I think you start to put some parameters around it when you make, you know, some kind of ruling out of this consultation. At least, you would describe the mechanism or the -- you know, at some level, the phases that would occur and who would actually be making those ---
2291 THE CHAIRMAN: Right.
2292 MR. WEBB: --- you know, establishing those deadlines.
2293 THE CHAIRMAN: Well, perhaps you can give some more thought in your final comments as ---
2294 MR. WEBB: Yeah.
2295 THE CHAIRMAN: --- to when the Commission should turn its mind to setting the deadline.
2296 MR. WEBB: Yeah.
2297 THE CHAIRMAN: I take your point that maybe today is not the point, but at one point, we're going to have to decide that.
2298 MR. WEBB: The first deadline, though, that is of interest to us is the one around refreshing, you know, and modernizing the network infrastructure, right, because I think today's 9-1-1 network is obsolete. Yes, it does function well, but it -- there are a number of issues. And so that is one of the first, I think, deadlines that needs to be put.
2299 THE CHAIRMAN: And there's not much wisdom in investing in legacy systems ---
2300 MR. WEBB: Correct.
2301 THE CHAIRMAN: --- when you know you have to invest in next-generation.
2302 MR. WEBB: Yeah.
2303 THE CHAIRMAN: Correct? Gateways will be a transitional means by which non-NG9-1-1 PSAPs will be able to connect with the new NG9-1-1. What are your views on creating incentives to bring people into the NG9-1-1 world more quickly by getting those using Gateways to maybe have higher costs? Because unless you create a disincentive to remain on a patch, nobody is going to want to move.
2304 MR. WEBB: Yeah, I think I would say, because of the amount of PSAP consolidation that has already occurred in B.C., I think it is within our visible horizon, you know, the point at which the organizations that are remaining that are providing PSAP services won't need a lot of incentive. You know, I mean, they could always use one-time help, if you will, to make, you know, steps forward from a technology point of view.
2305 But I think we're going to get to a point very soon in B.C. with police, fire, and ambulance services where the organizations that are providing, you know, PSAP functions have enough technical capability, and for the most part, have funding structures in place, that will allow this migration. So I don’t think it's an absolute requirement.
2306 I think funding will -- or incentives will drive faster adoption. There's no question about that, because ---
2307 THE CHAIRMAN: For both primary and secondary PSAPs?
2308 MR. WEBB: For both primary and secondary, yeah.
2309 THE CHAIRMAN: But you would agree that the secondary PSAPs might lag behind a little bit?
2310 MR. WEBB: They -- yes, they will, mostly because there's more to do, right, with the secondary PSAPs. I mean, we’re a little bit unique in B.C. in that we have a province-wide policed CAD system, right. So I actually, you know, sit as part of that organization as well. And we provide that service province-wide with a separate levy stream that supports its ongoing operations and its investment in, you know, its capabilities.
2311 And of course as we know, right, you know, 60 to 70 percent of all 9-1-1 calls are dealt with by police and so that deals with a significant portion of -- that organization will be dealing with a significant portion of the impacts of NG9-1-1 from a technology evolution point-of-view.
2312 So I think in this particular case -- and I’m referring to Prime Corp. here, Prime B.C. -- its biggest challenge is around knowing where it needs to get to, right. It’s not about being able to fund the transition. I mean, it does have resource challenges but really the question is, you know, where are we trying to go, right, and what services are we trying to deliver? What does that drive then in terms of updates to our CAD systems?
2313 THE CHAIRMAN: Right. Properly functioning next-generation 9-1-1 service needs the public to be well informed about it. I mean, we’ve heard great stories about very young children knowing what to do in an emergency by dialing 9-1-1 even though their reading and writing skills may not be up. But they know what 9-1-1 is.
2314 But by the same token, we have horror stories in Europe where people think 9-1-1 is the emergency number because -- and yet it sometimes isn’t the same.
2315 So public education is key in all this as we move to new data points that could be shared. How do you see the timelines and the methods of communications for getting the general population to become aware of all this, and whose role is it?
2316 MR. WEBB: I’ll let Naomi start.
2317 MS. ARITA: Well, I think one of the suggestions we do have in terms of the national PSAP organizational entity would be, you know, taking on that responsibility of planning and coordinating the public education across Canada from a public perspective.
2318 We certainly recognized some of the challenges with the new TEXT with 9-1-1 that was rolled out across Canada and how disparate it was, and not really well coordinated as far as implementation from a PSAP perspective.
2319 So the general public -- and through our outreach programs we did hear from them that, you know, it was quite confusing. The process was a little bit cumbersome and, you know, there was a real lack of understanding why it wasn’t available across Canada and even within the province why it was only available within some regions.
2320 So again, I think, you know, going to that national PSAP entity to coordinate, plan, and strategize in terms of rollout of new services so that it is better understood from the citizens of Canada across the country.
2321 MR. WEBB: I think public education needs to be addressed on multiple levels, however, right? I think it actually starts at its basic level with the emergency response agencies, right. All of the emergency response agencies that we support, they have their own public communications and their own programs around, you know, educating their citizens, around what service can the Vancouver Police Department provide to you and how you engage with them.
2322 E-Comm specifically is funded by some of our funders to provide public education specifically around 9-1-1 services, and we do expect that that role will continue and only get more important as we introduce new forms of engagement with the public for 9-1-1.
2323 But then I think at the highest level, as Naomi has suggested, there is a need for both national coordination -- and I think there is a need for the Commission as well to take a role in communicating at least, you know, what decisions is it making and how does that impact the provision of 9-1-1 services, or the receipt of 9-1-1 services by the citizens of Canada.
2324 I think at different levels there are different appropriateness of what types of communication need to occur. I mean, your focus would obviously be around, you know, the decisions that you’ve made and the regulatory structure you’ve put in place, and who’s responsible for what and all that sort of thing. It wouldn’t be down to the specifics of here’s what, you know, Joe Smith in any particular location in Canada would need to know but it’s more about that these services are coming and, you know, you’re taking action in order to make them available.
2325 THE CHAIRMAN: But shouldn’t be concerned that in an emergency somebody mistakenly believes that TEXT 9-1-1 is available in their area because it’s available in Newfoundland?
2326 MR. WEBB: We’re very concerned about that, right.
THE CHAIRMAN: And how do you -- at what point do you have sufficient critical mass to actually roll it out from a communication -- almost a chicken and egg issue, is it not?
2327 MR. WEBB: Yeah. I mean, to go back to the TEXT 9-1-1 example, I think there is a chicken and egg problem here, right, because you could take the view that we’re not going to roll it out anywhere until everybody is ready. Well, you’re never going to roll it out, right?
2328 But then on the other hand, you know, if you’ve got such a long period of time between rollouts in major urban centres, you know, in areas where arguably there is a capability to roll those things out in a more coordinated fashion, I think that’s a problem as well.
2329 So I think there’s going to have to be a happy medium between how much coordination and time alignment of rollout occurs versus, you know, delaying the rollout and creating a different issue, right, a different challenge or a detriment to the public.
THE CHAIRMAN: Yesterday it was suggested that with respect to Text-to-9-1-1 that there may be -- the City of Calgary -- I don’t know if you were in the room at the time -- that maybe there was benefit even before we get to NG9-1-1 to maybe expand Text-to-9-1-1, if not nationally, at least on a pilot project basis for individuals beyond the disability communities that are currently served. Obviously that would mean registration. I think the feeling there was that it would be particularly useful in situations of domestic violence. What are your views?
2330 MR. WEBB: I think we see the value of that and we see that there could be a benefit there, but I would also make the statement that unless we address the issues -- including, you know, the issues of public education, the issues with the registration process -- I think we’re just going to compound the challenges we had or just see a repeat of the challenges that we had, and more confusion therefore on behalf of the public.
2331 I think from our own perspective, you know, we have lots of things to do.
THE CHAIRMAN: Right. But you’re not volunteering for a pilot project?
2332 MR. WEBB: So we’re not necessarily volunteering to want to take this on necessarily. I think there are -- having gone through the T9-1-1 experience, there’s things that we would like to see done differently. And if we’re going to undertake a further rollout of something like that, particularly with the limitations that exist ---
THE CHAIRMAN: Can we learn from that rollout, perhaps ---
2333 MR. WEBB: Eh?
THE CHAIRMAN: Can we learn from that rollout? Perhaps we should have done pilot projects before rolling it out more broadly.
2334 MR. WEBB: Yeah, I mean, there were some issues with the technical capability. I think the bigger issue was just that it wasn’t coordinated and well communicated, and the support from the CWTA was not the greatest as far as this registration process and that sort of thing, right. So it was really more the operational parts of it that -- and I suppose a pilot maybe could have addressed some of that. I mean, we kind of were the pilot in some ways, right, because we bore a lot of the pain before anybody else did but ---
2335 THE CHAIRMAN: So maybe you’re not the pilot volunteers for next time, but you already gave at the office.
2336 MR. WEBB: Yeah, I’d need to take guidance from others on whether we want to volunteer at this point.
THE CHAIRMAN: Okay. With respect to texting but next-generation, obviously there’s a lot of ways to text. Whether or not SMS texting is on the way out or not, there’s real time text and of course there’s texting that’s facilitated by a variety of applications like WhatsApp and Facebook.
2337 Do you have views as to, you know, what’s the vision, the end-point vision with respect to all these texting potential platforms?
2338 MR. WEBB: The one thing I would offer up is whatever service is ultimately arrived at, that there not be multiple variations of it from the point-of-view of the PSAPs. So if there are different originating services or different originating networks, that there should be some sort of mediation or harmonization function that allows -- you know, whether it’s an abstraction of those services or whatever so that whatever appears to the PSAP is consistent; the operating procedure is consistent, the capabilities are consistent.
2339 I think real time versus non real-time text, I mean, that’s a discussion that is only just I think beginning. But, you know, we definitely see the value in real-time text. We’re just not sure how it would be implemented in a way that would be universal and consistent.
2340 I think this is a role for, you know, a technical coordinating body.
THE CHAIRMAN: Right.
2341 MR. WEBB: Whether it’s ESWG or ---
THE CHAIRMAN: Would your concerns go so far as some advocates that there would be development of a NG9-1-1 App?
2342 MR. WEBB: Yeah, I think we see value in that sort of capability.
2343 THE CHAIRMAN: And who would do that, and what if it fails?
2344 MR. WEBB: As to who would do it, I think it needs to be harmonized and consistent nationally, right. So the responsibility to develop it, I think needs to be assigned to an entity who’s driven by a national set of needs, right? I’m not sure specifically who should develop it. I mean, it could be contracted out. And the question is by whom?
2345 So is it something that the network service provider, you know, if a national or set of national network service providers is defined and whatever the structure around that is maybe, you know, they could see it and would potentially pay for it through whatever funding mechanism is applied more generally.
2346 But I think communicating to the public back -- because we were just saying about what the capabilities and limitations of that type of service would be -- you know, that has to go ultimately to the PSAPs and the national coordinating entity that we’ve talked about there.
2347 THE CHAIRMAN: It seems a bit like a -- I mean, the road to new and successful Apps is paved with a lot of good intentions.
2348 MR. WEBB: Yeah.
2349 THE CHAIRMAN: Whatever happened to Kik? I think some people still use it, but not as popular these days as it may have been. A lot of money gets put into projects. Is it really something any of us in this joint project should be involved in? It seems daunting.
2350 MR. WEBB: I think what’s important to harmonize is the capabilities of the network, right, the services that are provided nationally. What individuals have in their hand, you know, choice has to rule, right. The competitive marketplace, the innovation that exists, you know, among providers of technology -- that has to be basically -- and take the day as far as that’s how we need to be guided.
2351 I think we need to be concerned with harmonizing the capabilities of the network and harmonizing the capabilities that the PSAPs provide. So if that means there’s 15 different variations of this App that’s fine, as long as they all adhere to certain technical standards.
2352 THE CHAIRMAN: Basic functionalities.
2353 MR. WEBB: Right. And that the functionality that they deliver is consistent at least as far as it impacts the service that’s being provided by the PSAPs and the emergency response agencies.
2354 You know, I know there are going to be a lot of challenges with this sort of thing.
2355 THE CHAIRMAN: Yeah. But there may a point where unfortunately -- and how do you deal with that?
2356 MR. WEBB: Right.
2357 THE CHAIRMAN: Unfortunately, at some point somebody will think a very popular messaging function, let’s say Facebook for instance, is a great way to communicate with friends and family but doesn’t meet the sort of functionalities you’re talking about.
2358 MR. WEBB: Right.
2359 THE CHAIRMAN: So how does one deal with that because there could be a misstep?
2360 MR. WEBB: Well, it may be as simple as if Facebook as a service provider wants to be able to deliver, you know, messaging to PSAPs, there’s a whole set of technical requirements and arguably an interface or an API that it needs to adhere to that’s established, you know, and harmonized and agreed. And, you know, they’d bear the cost of that as an originating service provider.
2361 THE CHAIRMAN: Right. Except that the public may make assumptions.
2362 MR. WEBB: Yeah.
2363 THE CHAIRMAN: So that gets back into the public education aspect.
2364 MR. WEBB: Yeah. And I think there’s a burden on those service providers as well, right, to disclose what capabilities they do and do not provide, right?
2365 THE CHAIRMAN: Do you currently have capability for real-time text? No?
2366 MR. WEBB: We do not, no.
2367 THE CHAIRMAN: And do you see a horizon in which you might be able to do that?
2368 MR. WEBB: Not a definitive horizon. I think we are waiting for, you know, the next-gen 9-1-1 network to rollout to enable that sort of thing. We would not -- I don’t think we are planning at this point to implement text to or from 9-1-1 for any other purpose other than the deaf and hard of hearing community as is currently implemented.
2369 There are emergency response agencies in our jurisdiction that do use text messaging with the public. We’ve looked at that and we don’t at this point see a fit or a net value, a net benefit to introducing that into our organization currently.
2370 THE CHAIRMAN: Right. And what’s the timeframe do you think would be realistic for rollout of next-generation TEXT 9-1-1?
2371 MR. WEBB: I would say in the three to five-year timeframe. I think that’s what we said in our intervention as well.
2372 THE CHAIRMAN: Okay. Any lessons to be learned from the American rollout, what to do, what not to do?
2373 MR. WEBB: Well, I think we’ve talked about one of the big ones, which is sort of harmonization of the service, right, ensuring that it’s consistent from one geographic area to the next.
2374 I mean, the U.S. is a different environment than we -- as far as provision of public safety and first responder services. It’s much more fragmented. I think you have a different role for many of the States in the U.S. than the provinces play in Canada.
2375 I think we’re in a lot better position, to be honest -- I think this was stated yesterday by somebody as well -- because we are more cohesive, I think, in Canada around how we approach some of these things. But part of that is because of, I think, the scale.
2376 I mean, the lessons we could probably go on and on about some of the failures that have occurred. I wouldn’t profess to be an expert as to what were all the root causes there, but I do think that if you introduce the profit motive into delivery of a life critical, mission critical public safety service I think you always run the risk of creating vulnerabilities in the delivery of those services. And I think that’s been behind some of the incidents that have occurred.
2377 I think there are other issues there as well but -- which is actually why, you know, we are advocating a continuation of the current regulatory model where cost is not necessarily the primary concern of delivery of 9-1-1 network infrastructure. It’s resiliency, and avoidance, and mitigation of risk for the delivery of the service. So I think I’ll stop at that point.
2378 THE CHAIRMAN: Right. It’s interesting that you say that cost shouldn’t be the key driver to decision making because it’s my impression that with respect to storage and retention, the position of some PSAPs are concerned that the additional costs associated with retention and storage are such that the current model should not be brought forward.
2379 MR. WEBB: The pure cost of storage is not a major concern of ours I think with respect to other types of information or media that may be received.
2380 Our major concern is more about the business process around handling that information. I mean, today we store a large amounts of voice records on behalf of our clients. We’ve got, I think, a pretty efficient means of doing that, and the actual storage costs is not a particular concern of ours. Yeah, I mean, that volume will likely increase, could increase as other types of services are introduced but storage by itself is relatively cheap.
2381 I think what is, you know, more of concern is what information are we holding, why do we have that information, why did we get it in the first place, and what obligations do we have around management and disclosure of that information, right?
2382 The privacy legislation in British Columbia at least is such -- and this has been tested a number of times -- is such that we are viewed as a custodian on behalf of the emergency response agencies for which that information was destined. So we do not directly for the most part respond to disclosure requests. We will take direction from the agencies that we serve because it is viewed as their data, right? And I think that that same model would continue to apply in a next-gen 9-1-1 context with other types of media.
2383 THE CHAIRMAN: Are you of the view that the current privacy framework is adequate to deal with the next generation point?
2384 MR. WEBB: I think it’s adequate, but I think new issues will come up. And the one I’m particularly interested in -- I think there’s -- so back to what I just stated. I mean, there’s the question about why did we get a certain piece of information, right? Is it or was it necessary to effect an emergency response in that particular incident? And that has to be the test right at the very beginning.
2385 I think there’s then the question of, you know, the consent that’s provided by the citizen that delivers the information. I think that is going to create some, you know, areas where probably some further precedent needs to be established.
2386 I don’t see it as being an insurmountable issue because, you know, as I said, we do deal with large amounts of personal information today.
2387 The other thing that will be, I think, new about NG9-1-1 that is going to be maybe a bit more of a cause for concern is to do with additional forms of information will create additional forms of metadata that go with that information. And that will be a concern with respect to the operation and the obligations of the network service providers, right?
2388 So I think there’s very good reasons why they will have to maintain metadata related to information that they’ve transmitted through their networks. And even if you just get into things like, you know, lawful acccess and surveillance type purposes that are applied more generally to other types of networks, I think that’s going to be an area where work is going to need to be done to determine how to deal with those additional forms of metadata, because they do, you know, they do represent issues with respect to privacy. Just to know that so-and-so transmitted a photo, right, and that there is a log or a record of that, doesn’t matter what the photo had in it or whatever, you know, there is a potential privacy concern that goes with that ---
2389 THE CHAIRMAN: Right.
2390 MR. WEBB: --- right, that's beyond what we're doing today.
2391 THE CHAIRMAN: And law enforcement and national security folks will -- may want to have access to that.
2392 MR. WEBB: Absolutely, and you sort of wonder if it was for the purpose of ---
2393 THE CHAIRMAN: Exactly, yeah.
2394 MR. WEBB: --- health and safety, should life and property ---
2395 THE CHAIRMAN: That's right.
2396 MR. WEBB: --- should it be used for other purposes?
2397 THE CHAIRMAN: Yeah.
2398 MR. WEBB: Yeah, I think it's a little different, you know, than it is with voice today.
2399 THE CHAIRMAN: Right.
2400 MR. WEBB: Because there's a limited amount of metadata that goes with voice. There can be a whole lot more, right, that ---
2401 THE CHAIRMAN: Right.
2402 MR. WEBB: --- goes with these other forms.
2403 THE CHAIRMAN: So the same principles apply, but you're just saying that the data set is much bigger?
2404 MR. WEBB: I mean, from my perspective, I think the same principles apply. I mean, I can't profess to be an expert of what's going to happen, you know, going forward, because we haven't got there, but I -- that would be my view, absolutely.
2405 THE CHAIRMAN: Now, earlier we were talking about service level agreements, and you referred to the risk of outages. You know, as we go forward, I was wondering if you had views on the right framework for monitoring and reporting? And of course, I'm talking here about the area within the Commission's jurisdiction.
2406 MR. WEBB: Yeah.
2407 THE CHAIRMAN: The network component. Should there be regular monitoring and reporting, filing of annual returns or reports? Is that beneficial or is just -- that just collecting paper?
2408 MR. WEBB: We believe it's beneficial, yeah.
2409 THE CHAIRMAN: How so?
2410 MR. WEBB: We believe it's beneficial in terms of being able to benchmark, obviously, performance of, you know, a particular provider's services in any particular area. I think it creates an incentive to, you know, make sure that the service is as reliable as it can be back to the due diligence, you know, statement that was discussed earlier.
2411 I think if there is a record of what incidents have occurred, you know, determination can actually be made as to whether additional remedial steps need to be taken by that service provider or whether -- conversely, whether the service they're providing is, in fact, adequate and meets that due diligence requirement.
2412 So I would -- I don't think more data is a problem in this area, and I don’t think it's unreasonable to apply some level of burden to the service providers and include that in their costing models to report on these types of things.
2413 THE CHAIRMAN: My last area of questioning relates to the disability community, and I was wondering if you could speak to the challenges you have faced serving the disability community and how you’ve corrected course and things that we might want to keep top of mind when we do the transition to next-generation.
2414 MS. ARITA: We -- primarily from a disability perspective, our challenges have been around the deaf and hard of hearing and speech impaired. Prior to the Text-with-9-1-1 rollout, we were using TTY devices, which is a fairly, you know, old and antiquated service. And we didn’t or we don’t have those devices rolled out on every work station in the floor, so for the volume of calls, it's a little difficult in terms of maintaining training, quality of service, you know, if we're only getting one of those type of calls per year.
2415 Well, Text-with-9-1-1 has increased, that one, so we are seeing, you know, an improvement to the service for the deaf and hard of hearing and speech impaired.
2416 There was quite a bit of confusion from the community, and we did do quite a bit of outreach, as far as attending town hall meetings, having members come into our centre and demonstrating the process. And there was a lot of confusion from the community in terms of how the service worked, where it was available, why they couldn't just simply Text-to-9-1-1. So you know -- and identifying the location information -- and it really just got into a bit of the complexity around the whole 9-1-1 service.
2417 I think they were a bit surprised that they didn’t know where we were, even just from a text call, or even from initially calling, you know, the accurate location information is still not quite there yet either.
2418 THE CHAIRMAN: Right.
2419 MS. ARITA: So it was a little bit of a learning or an education process for this community. So again, you know, public education, I think, is going to be key rolling out any other new type of service, and ensuring that there is some uniformity across Canada.
2420 Now, although interpretation services for those that can't speak English isn't necessarily a disability, but that is another area that we struggle with.
2421 THE CHAIRMAN: Right, especially in your part of the world.
2422 MS. ARITA: Exactly. We get about 200 interpretation or language-line calls a month, and today on the current network, in order to conference in the interpretation service, we're going off the 9-1-1 network and onto the PSTN network, identifying, you know, what service the caller requires, and then to bring in police, fire, or ambulance, we're doing another PBX type of conference, not a 9-1-1 network conference.
2423 And our 9-1-1 call taker actually has to stay on the line for the duration of the call; otherwise, if they disconnect, they drop all participants. And last month, in December, the longest call -- time that our call-taker stayed on the phone was 40 minutes. So it really does tie up our resources.
2424 THE CHAIRMAN: Right. They're not doing anything else, but you need them there to patch in, presumably, an interpreter?
2425 MS. ARITA: That's all they're doing is (inaudible).
2426 THE CHAIRMAN: And that's because of a technical limitation in the network, right?
2427 MS. ARITA: Yeah.
2428 MR. WEBB: Yeah.
2429 THE CHAIRMAN: With respect to your TTY, did you -- do you still have the equipment in place?
2430 MS. ARITA: We do. We still have ---
2431 THE CHAIRMAN: And you continue to maintain it and ---
2432 MS. ARITA: We continue to maintain ---
2433 THE CHAIRMAN: --- train?
2434 MS. ARITA: Continue to train. We have what we call texting Tuesdays, so we, you know, just do random Text-with-9-1-1 calls as well as TTY calls.
2435 THE CHAIRMAN: How often is it used?
2436 MS. ARITA: The TTY is about once a year, if that, and then Text-with-9-1-1 is once a month.
2437 THE CHAIRMAN: And have you seen the TTY numbers go down as Text-to-9-1-1 emerged?
2438 MS. ARITA: No, no. It's generally stayed at that volume for -- since I can remember, 15 years or so.
2439 THE CHAIRMAN: Right. Has video relay been something you've had to deal with with the rollouts in September, a video relay?
2440 MS. ARITA: We actually haven't had any experience with that yet.
2441 THE CHAIRMAN: Okay, but you would be equipped for that, right?
2442 MS. ARITA: We actually don’t -- or we aren't equipped to take a video relay call.
2443 THE CHAIRMAN: But -- okay, you're not equipped, okay.
2444 MS. ARITA: No.
2445 THE CHAIRMAN: Are there any plans to equip yourself for that?
2446 MS. ARITA: Yeah, we haven't really discussed that matter much, although we are obviously going to be getting to that. It was a little bit of a surprise to us in terms of when it was rolled out. I think we were informed about it just a couple of months ago.
2447 THE CHAIRMAN: It's been a long process.
2448 MS. ARITA: Right, yeah.
2449 THE CHAIRMAN: Maybe monitor our website a little bit more. I think it was a two-year process.
2450 MR. WEBB: I mean, I'll make the statement, I guess, that we're not aware -- or I guess, don’t understand what obligation, you know, is actually being placed. And when I say "obligation", you know, in quotes, because I don't know that any obligation becomes a hard -- back to the other decisions we've been having about, you know, PSAPs adaptation into new services, whether that is, in fact, a hard obligation.
2451 But you know, it's been our approach that if these new services are available, given enough time, you know, we will try to adapt and roll them out. I think in this particular case, we're just too early in the cycle, right, to have put a plan together.
2452 THE CHAIRMAN: Right. Does provincial legislation create any standards or obligations on you with respect to TTY or any other ---
2453 MR. WEBB: No.
2454 THE CHAIRMAN: --- disparities?
2455 MR. WEBB: There is no provincial 9-1-1 legislation in B.C. I did mention the Emergency Communications Corporations Act, but that legislation just deals with the structuring and creation of special-purpose corporations such as E-Comm that provide these types of services. So there is not, in British Columbia, any 9-1-1 legislation.
2456 THE CHAIRMAN: Right. Well, thank you.
2457 Let me turn to my colleagues to see if they have any questions. Does legal have any questions? No?
2458 Okay, well, thank you very much. Those are our questions for now.
2459 So we will adjourn til ---
2460 MR. WEBB: Thank you.
2461 THE CHAIRMAN: --- 1:30. Yeah, so we're back at 1:30 for the other intervenors today. Thank you. Merci.
--- Upon recessing at 12:17 p.m.
--- Upon resuming at 1:30 p.m.
2462 THE CHAIRMAN: Order, please. À l'ordre, s'il vous plaît.
2463 Madame la Secrétaire.
2464 THE SECRETARY: WE will now hear the presentation of the Alberta Emergency Management Agency. Please introduce yourself, and you have 15 minutes. Thank you.
2465 MR. RENFREE: Hello. Bonjour.
2466 My name is Andrew Renfree. I am the 9-1-1 Manager with the Alberta Emergency Management Agency.
2467 On behalf of our agency and our Managing Director, Shane Schreiber, I want to thank the CRTC, the Commissioners and the staff for the opportunity to present today and for accepting written responses multiple times over the past year.
2468 One of those submissions was due in the middle of the response to the devastating Fort McMurray wildfires. We are thankful that the CRTC granted our agency, and the Public Safety Answering Points in Alberta, a one month extension for our submissions as we dealt with the disaster.
2469 Before the residents of Fort McMurray could return home, one of the key factors that had to be met was that 9-1-1 be fully operational in the municipality. It was a strong reminder of how 9-1-1 is one of the cornerstones of a safe community.
2470 Going forward, 9-1-1 will continue to be the cornerstone of a robust public safety system as we move towards next-generation developments.
2471 The opportunities NG9-1-1 brings must be leveraged in order to fully mitigate any challenges that come with the NG9-1-1. In order to do that, we must take a deliberate, coordinated approach, and this consultation is a step in the right direction.
2472 The Alberta Emergency Management Agency appreciates the ongoing, thorough consultation the CRTC is conducting on the establishment of a regulatory framework for next-generation 9-1-1 in Canada. We look forward to contributing to the evolving NG9-1-1 landscape in Alberta and across the country.
2473 Today I will be outlining how Alberta’s Emergency 9-1-1 Act supports the future of NG9-1-1 in Alberta.
2474 Calgary 9-1-1 presented to the Commission yesterday on their local perspective so our presentation today will focus more at the provincial level and how Alberta relates to other provinces and territories.
2475 The cross-jurisdictional challenges and opportunities were explained well yesterday by the NG9-1-1 Coalition of the Willing and their presentation to the Commission.
2476 The Alberta Emergency Management Agency has participated in the NG9-1-1 Coalition since its inception in 2013 and we appreciate the leadership that the Coalition has shown to advance NG9-1-1. They have done tremendous work without funding or any official status as a coordinating body.
2477 The Alberta Emergency Management Agency supports the submissions of the Coalition and our presentation today will focus on additional comments that reflect the 9-1-1 reality in Alberta. Specifically, I will be talking today about how Alberta's Emergency 9-1-1 Act positions us well for NG9-1-1 developments through funding and standards.
2478 Alberta has seen tremendous benefits from having provincial 9-1-1 legislation and we will see this as a first key step towards the NG9-1-1 future.
2479 The Alberta Emergency 9-1-1 Act came into force in April 2014. Up until that point, local jurisdictions developed a resilient 9-1-1 system, and maintaining local control over 9-1-1 has been a pillar of our program provincially.
2480 The provincial government did not take over 9-1-1 in Alberta; rather, we introduced measures to strengthen and support the local delivery of 9-1-1. The Emergency 9-1-1 Act supported local autonomy and decision-making for how jurisdictions provide 9-1-1 services. Local communities retained the ability to decide how they meet their 9-1-1 needs.
2481 One of the purposes of the Emergency 9-1-1 Act was to enhance existing PSAP capacity and their continued ability to provide reliable 9-1-1 services. The Act was a key step to accelerating NG9-1-1 in Alberta and it would support PSAPs integrating new next-generation 9-1-1 technology in several ways.
2482 First, the Act established a new source of funding through a 9-1-1 levy on wireless phones. The wireless levy was equal to the landline levy that had been in place in Alberta for over a decade.
2483 A 9-1-1 funding gap existed in Alberta because PSAPs had not been receiving 9-1-1 funding from wireless subscribers, yet wireless calls represented an increasing proportion of daily call volume. Yesterday, Calgary mentioned that about 70 percent of their calls come from wireless phones.
2484 Compounding this issue, the number of landlines was decreasing in Alberta. And given that many PSAPs were only receiving funding from landline subscribers, the decrease in landline connections negatively impacted PSAP funding.
2485 The wireless 9-1-1 levy was introduced through a mechanism to ensure that the funds generated by the levy are only directed towards PSAPs and administrative costs. Since the beginning of our program in Alberta, the wireless service providers have been very cooperative with our model. The providers transfer funds monthly to Alberta Treasury Board and Finance in a seamless process.
2486 We also knew that a new source of funding would be required to evolve the 9-1-1 system towards the next generation. In 2015 the NG9-1-1 Coalition of the Willing conducted a national survey of PSAPs, regional and national 9-1-1 associations, first responders, and provincial and territorial government departments involved with 9-1-1. Responders strongly identified cost as the largest concern about the future of NG9-1-1.
2487 Alberta’s 9-1-1 legislation sought to provide some funding support for costly NG9-1-1 developments. However, provincial funding only covers a portion of the costs and 9-1-1 in Alberta is funded through multiple streams.
2488 At the PSAP level, costs are shared in Alberta between call-answer levies on cellphones and landlines, as well as municipal funding.
2489 We respectfully submit that the same as today, 9-1-1 platform providers, which would be Telus in Alberta, should cover network upgrade costs up to the demarcation point, paid for either through existing or new tariffs put in place through the applicable CRTC NG9-1-1 proceedings.
2490 When the Alberta 9-1-1 Program started granting funds raised from the new wireless levy, we emphasized to PSAPs, and the municipalities that they work for, that this funding was meant to enhance, not replace, existing funding.
2491 The provincial support was to be in addition to existing municipal budgets to support service enhancement. Our 9-1-1 Grant Program guidelines clearly state that “this funding is intended to enhance, not replace, existing 9-1-1 funding,” and we wanted to stress the importance of continued strong funding from multiple sources to advance Alberta towards next-generation 9-1-1.
2492 During the CRTC consultation, the National Pensioners Federation, Council of Senior Citizens’ Organizations of B.C., and the Public Interest Advocacy Centre addressed, in an interrogatory, a question to the Alberta Emergency Management Agency. Their question was about the multiple 9-1-1 levies that exist.
2493 The NFP -- or NPF-COSCO-PIAC stated, “This creates the possible situation where a household may be required to pay several monthly levies.” They asked “In the Alberta Emergency Management Agency’s view, is there a more efficient and streamlined means of funding NG9-1-1 services in the future?”
2494 We want to take this opportunity to thank those organizations for their inquiry and their question to us, and also for their presentation to the Commission this morning.
2495 Having multiple funding streams for 9-1-1 has two main advantages. This model is more transparent, with a different cost going directly towards a different element of the 9-1-1 service. For example, Alberta’s landline and wireless 9-1-1 levies go back to PSAPs to fund their operations and enhancements.
2496 Carrier 9-1-1 fees pay for infrastructure and network costs. Municipal funding currently pays for other aspects closely related to 9-1-1 such as facilities, radio systems, dispatching, and first responder costs.
2497 Having multiple sources of funding ensures that expensive upcoming NG9-1-1 costs are shared and that the cost onus does not fall on one particular group. The Alberta wireless 9-1-1 levy is 44 cents per month, which amounts to $5.28 per year. This minimal contribution per wireless subscriber generates more than $15 million going back to support Alberta PSAPs each year.
2498 This is one of the key takeaways I would like to emphasize for the Commission today. The Alberta model is unique in Canada because as much of the funding as possible from the 9-1-1 levies goes back directly to PSAPs. The Alberta model provides a funding source directly to cover some PSAP costs while maintaining operational delivery and decision-making responsibilities with the local 9-1-1 centres for how they meet their needs.
2499 Providing direct funding to PSAPs has multiple advantages. They can spend money how they choose within broad parameters outlined in provincial guidelines. This allows centres to cover operational costs like staffing or upgrades such as new technology.
2500 In Alberta, they may also spend this money on NG9-1-1 capabilities and advancements, and Calgary 9-1-1 spoke yesterday about how they’re using the funding for some of those purposes. Direct funding also allows PSAPs more flexibility.
2501 Municipal budgets are often planned in three-year cycles, so it can be challenging to plan for enhancements in a PSAP. With direct provincial funding, a PSAP can make decisions and purchases more quickly.
2502 The Alberta 9-1-1 Program also allows PSAPs to carry forward grant funding for approved projects that will take more than one year to complete, or pay for.
2503 The second aspect of the Emergency 9-1-1 Act that laid the framework for NG9-1-1 was the ability to collaboratively develop provincial 9-1-1 standards.
2504 The Alberta Government has been working with stakeholders to create province-wide standards, processes and procedures for 9-1-1 call taking. This will ensure consistent service delivery across the province. A draft version of the Alberta 9-1-1 Standards has been produced, and is currently being reviewed by government.
2505 The Alberta 9-1-1 standards will be our gateway to NG9-1-1.
2506 For jurisdictions in Canada wondering how to get started on the NG9-1-1 journey, legislation and standards are the first steps, in our opinion.
2507 As the CRTC Emergency Services Working Group implements technical and operational guidelines for 9-1-1 networks, the Alberta standards will need to evolve appropriately to support local PSAPs and help them address any new requirements that are placed on telecommunications providers. So in this way, provincial standards are a key way to advance NG9-1-1.
2508 I will take this opportunity to reiterate the point that some of the other presenters have made about the importance of a national NG9-1-1 coordinating entity.
2509 Alberta will endeavour to follow best practices across Canada, and apply CRTC decisions in our provincial standards. However, without a national coordinating entity, it will be difficult to ensure that all provinces and territories are advancing NG9-1-1 consistently.
2510 It would be concerning if NG9-1-1 advancements were well established in one province or territory and not in its neighbours. Public education could also be coordinated across the country through a national entity.
2511 A national coordination entity could also assist with the development of a legislative template for Canada’s provinces and territories to advance NG9-1-1. Alberta’s Emergency 9-1-1 Act could be used as a possible starting place for a future legislative template because it supports local autonomy to the PSAPs so they can react quickly to NG9-1-1 changes.
2512 Alberta was the seventh Canadian jurisdiction to pass 9-1-1 legislation. Since then, Newfoundland and Labrador has passed an Emergency 9-1-1 Act. We are working with other Canadian jurisdictions that do not have 9-1-1 legislation to help them do the necessary research to potentially enact similar legislation.
2513 The intention of model legislation would not be to replace other provincial legislation already in existence, but it can help jurisdictions without provincial legislation or help jurisdictions that are updating their existing 9-1-1 legislation.
2514 The national coordinating entity should also keep informed on the progress of the national Public Safety Broadband network in Canada.
2515 When this network is established, public safety agencies will be using it for data and video, and this needs to integrate with the NG9-1-1 system. The United States FirstNet system is a good example of how public safety broadband can be closely connected with NG9-1-1.
2516 Lastly, I would like to build on the point that E-Comm 9-1-1 made in their submissions about network outages and notifications.
2517 In many respects, 9-1-1 and public alerting are closely linked; 9-1-1 is how the public reports emergencies to response agencies. Public alerting is how response agencies notify the public about emergency situations.
2518 The link between 9-1-1 and alerting will likely increase in prominence in the future as public alerting targets smartphones directly through wireless public alerting.
2519 The Alberta Emergency Management Agency looks forward to the CRTC decision on wireless public alerting later this year. As we progress on that front, both calling in through 9-1-1 and calling out through public alerting will be used the same device, our smartphones.
2520 For system outages that may impact 9-1-1 service, it’s important the PSAPs have a connection to public alerting in each province or territory so the public can be notified that 9-1-1 access may be impacted.
2521 Conversely, when the public alerts are issued for emergency events, PSAPs need to be connected because the public will likely be calling 9-1-1 about the incident. In Alberta, we have a robust alerting system called Alberta Emergency Alert. The draft Alberta standards say that in the event of a 9-1-1 system outage, PSAPs should contact a designated representative from the affected communities.
2522 Communities, at their discretion, can use the Alberta Emergency Alert System to notify citizens in these circumstances. In 2016, Alberta Emergency Alert was used eight times for events where telephone outages could potentially impact 9-1-1 service. If PSAPs are connected to public alerting, the sooner carriers provide outage notifications, the sooner the public can be aware of what measures to take to stay safe.
2523 On the other side of alerting, Alberta is piloting a project with one of our PSAPs so the broadcast alerting hardware is connected right into their centre. This means that they are the first ones to know about any emergencies occurring in their community. If the pilot goes well, we will look to expand this to all PSAPs in Alberta.
2524 I will conclude by saying that Alberta is looking forward to the future of NG9-1-1 and to contributing to its progress. NG9-1-1 is one of the biggest public safety opportunities Canada has, so we thank the CRTC again for the time to share the Alberta Emergency Management Agency’s perspective with you today.
2525 I am happy to answer any questions that you may have.
2526 THE CHAIRMAN: Thank you very much for that. I’ll put you in the hands of Commissioner Simpson.
2527 COMMISSIONER SIMPSON: Thank you.
2528 Good afternoon, Mr. Renfree, how are you?
2529 MR. RENFREE: Great, you?
2530 COMMISSIONER SIMPSON: Fantastic, thank you.
2531 As I said to Calgary 9-1-1 yesterday, “Wow.” I’m going to ask you a whole bunch of questions about how you got this far this fast, and good old Alberta giddy-up is not going to be good enough as an answer. I want to know more.
2532 From the standpoint of the impetus behind the Act and the levy, could you just give me a quick circle tour as to how this came about? What was the spark that lit the match that lit the gasoline that created this Act?
2533 MR. RENFREE: Sure, thank you.
2534 Ultimately, the driver was PSAPs and municipalities in Alberta demanded changes. So they were looking to other provinces that had already passed Emergency 9-1-1 legislation, and they requested through the municipal associations in Alberta -- the Alberta Urban Municipalities Association, and the Association of Municipal Districts and Counties which represents the more rural areas -- they both pressured government to do this.
2535 It took a few years of research and consultation with the Alberta 9-1-1 Association and other stakeholders in Alberta. But ultimately, I think what sort of drove it into the end zone was we had a minister of municipal affairs who was very passionate about this file and he took that research and said it was a no-brainer to pass this Act. So he really, really drove it through the legislature so we can certainly give him credit for that aspect.
2536 And our agency was smart in hiring an individual who had a legal background and also had worked in a PSAP, so he had a great perspective on the sort of policy and the legislative aspects that would be required to put this through.
2537 COMMISSIONER SIMPSON: Okay, thank you.
2538 I’ll ask you some questions about the levies and the inputs that come from the Act later. But yesterday I asked Calgary 9-1-1 when they made reference to how they’ve had to catch the ball sometimes when technological or financial changes and challenges caused PSAPs to just collapse under the weight of the new burden -- and they used Airdrie as an example.
2539 Could you explain to me, assuming that what I heard from you that distribute funds on the basis of grants and requests for funding; so would you explain to me how the Calgary 9-1-1 PSAP would go about making application to take up the burden of Airdrie into their system? How it works with you guys from the money flow standpoint.
2540 MR. RENFREE: Sure. So our grant-funding model -- each PSAP in Alberta gets a base amount of $75,000 per year. So this ensures that even some of the smaller centres are still getting funding. And the remainder of the funding is distributed based on the population that they serve. So that really strikes a balance between giving some of the smaller centres some funding, but also recognizing that the larger centres have more staff and more technology to support their operation.
2541 So if a centre was to take over another territory, whatever population was served by that area would now be moved to the new centre. So it would change the amount that they’re funded.
2542 COMMISSIONER SIMPSON: So they’re essentially through your coordination able to grab the portion that Airdrie was getting and perhaps top it up with some of their own needs, and formulate a new budget that rectifies the funding problem of what Airdrie was dealing with. Why wouldn’t Airdrie be able to do that on their own?
2543 So in other words, if they were presented with a set of new challenges -- the bar gets raised technologically –- what causes them to make the decision to not try and apply for more funding and -- because it’s normal to try and maintain your turf. So why would they give up?
2544 MR. RENFREE: So since the Emergency 911 Act came into place and the funding started flowing, they’re haven’t been any PSAP closures in Alberta. Prior to that, I think they largely closed because of financial reasons.
2545 And going forward, the Emergency 9-1-1 Act doesn’t dictate the number of PSAPs; we’re not going to force a consolidation in Alberta. What we will be doing, though, is developing provincial standards, and we’re well on the way on that front.
2546 COMMISSIONER SIMPSON: Yeah.
2547 MR. RENFREE: So if a local municipality decides that 9-1-1 is an important public safety service in their community, as long as they’re following provincial standards, then they can continue doing that.
2548 COMMISSIONER SIMPSON: So on the basis of those standards, I’ve got a couple of questions. If you’re saying that there isn’t a plan to consolidate secondary PSAPs, how -- is there a separate set of criteria that you push that particular PSAP through to help them, as well as themselves, determine whether they should stay in the business of being a PSAP or they should consolidate? Is there a separate process that you use?
2549 MR. RENFREE: Yeah, so just to clarify, we deal with the primary PSAPs in Alberta so ---
2550 COMMISSIONER SIMPSON: I realize that but in the course of a PSAP being financially challenged, it must, politically, in a small-piece sense, transfer back to the government that this service has the potential of being taken away from a community and become a separate problem but still within the catchment of 9-1-1.
2551 MR. RENFREE: Right. We haven’t had those conversations with any of the PSAPs, the smaller ones or the larger ones.
2552 COMMISSIONER SIMPSON: Yeah.
2553 MR. RENFREE: What I can say is that the provincial standards in Alberta have been developed in very close collaboration with all of the PSAPS. We work closely with Alberta E9-1-1 Advisory Association and most of the PSAPs are present at those meetings; and if they weren’t present, we reach out to them separately for input.
2554 So it really is a provincial standard. And that was important because I’ve never answered a 9-1-1 call in my life so we really wanted people who had answered them and did have that frontlines experience to help draft these standards.
2555 So we got their input and we looked to what was going on in other provinces, and also internationally, and sort of took the best practices and applied them in Alberta.
2556 COMMISSIONER SIMPSON: Okay, so is it safe to say, then, that the standards that were created through legislation, and through the adoption of all the other best practices that you looked at, becomes the immovable object, and it a PSAP can’t -- a secondary can’t make that leap through financial means, then that becomes the tipping point for them; is that correct?
2557 MR. RENFREE: Yeah, in some senses. The -- you know, we can’t -- we don’t have the jurisdiction to shut a PSAP down.
2558 COMMISSIONER SIMPSON: Yeah.
2559 MR. RENFREE: So the standards are very closely tied to the funding. So if a PSAP is not meeting provincial standards, you know, we would meet with them and try and get them back on track, put together a timeline for how they could rectify things. But if that keeps going on, then we could withhold provincial funding.
2560 COMMISSIONER SIMPSON: But were the standards that you originally developed, though, did they take the abilities of the secondary PSAPs in mind when you were drafting them?
2561 MR. RENFREE: They were in the room when we considered it, as was Telus, the ILEC in Alberta, so they certainly had input into where the standards were going. But from a legislative standpoint, our mandate is just with the primary PSAPs. Our Act sort of draws a line in the sand at the point of dispatch and so that’s when the funding is eligible up until and that’s when the -- that’s where the standards are applicable to.
2562 COMMISSIONER SIMPSON: M’hm.
2563 MR. RENFREE: So our secondary agencies were part of the conversation but the standard doesn’t directly apply to them.
2564 COMMISSIONER SIMPSON: Okay. Just sticking with the standards for a minute, front to back, approximately how long did it take you from the starting point to get to a final draft of your standards, and what informed those standards in terms of outside input?
2565 MR. RENFREE: Right. So it took over two years to develop the draft that we have right now, and that’s currently going up and being reviewed by government.
2566 COMMISSIONER SIMPSON: Yeah.
2567 MR. RENFREE: The reason that it took that long is because we held several face-to-face meetings with Alberta’s PSAPs to discuss what should be in the standards.
2568 So our first meeting, we got together in a room like this and handed out index cards to everybody and said, “Write down what you want to see in a provincial standard,” and put them all up on the wall and organized them into categories, and then sort of prioritized which areas to focus on.
2569 From there, we developed some small working groups to really draft the different sections to look at what was going on in other provinces and internationally, and either use those directly or write it for what was required in Alberta.
2570 Then, once we had a draft of a section from a working group, we would take it to the whole group to sort of vote on, debate, discuss, and we had some really good discussions. The 9-1-1 community in Alberta -- and I’m sure it’s the same in other provinces and territories -- is very passionate and, you know, they are in this game to make Alberta safer, so we had a lot of great discussions, a lot of good input, and that’s really how the document was developed.
2571 COMMISSIONER SIMPSON: Did you consult with any of the -- you said there are seven provinces now with 9-1-1 Acts or legislation. Did you do any consulting with the other provinces to see what they were doing?
2572 MR. RENFREE: Yeah, absolutely. The Maritimes have a lot of great documents for standards; we looked quite a bit at New Brunswick and Nova Scotia. And Saskatchewan also has a fairly detailed 9-1-1 standard. In Manitoba, their standard is actually written more into the legislation itself, and their standard spoke a lot to the business-continuity type of practices that PSAP should follow.
2573 So we took a little bit of everything that existed from around Canada. We sort of took a buffet approach, a little bit of that, a little bit of that, and applied it in Alberta. So I think the document that we’ve developed is pretty robust for that reason, and also because of the consultation that we’ve done with our PSAPs.
2574 COMMISSIONER SIMPSON: In general terms, how much do your standards vary from the other provinces? Or if you were to look at the seven provinces’ various legislations, is there much of a variance in terms of those standards from province to province?
2575 MR. RENFREE: I would say it depends on the section of the standards. And we probably looked to different areas for guidance on different sections. So as far as how calls are managed and transferred, it’s probably pretty similar to New Brunswick. I think the business continuity section of our standards is probably similar to Manitoba. So we really did take a bit of each standard that was out there.
2576 COMMISSIONER SIMPSON: Just in the ranking of how you think you did, did you set the floor; are you at the ceiling; or somewhere in the middle in terms of your comparison of your legislation to the other provinces? Where do you think you fit?
2577 MR. RENFREE: I think it’s very comparable. You know, there are aspects of each that form our standards. But yeah, I would say it’s fairly comparable.
2578 The aspects of the standards that we looked at first were sort of the tip-of-the-iceberg aspects, things like call management and the business continuity piece, the redundancy. So some of those key things were the first things that we tackled in this version, and as we go forward, we’ll be looking to keep pace with NG9-1-1 developments across Canada, and we’ll do that through our standards.
2579 COMMISSIONER SIMPSON: Okay. You’ve been pretty forthcoming about how collaborative you’ve been in working with not only the Coalition of the Willing and other groups.
2580 As you look at what we’re trying to do on this side of the fence, it would be very helpful if we were able to see a copy of your standards. Would you be willing to share them through an undertaking with the Commission?
2581 MR. RENFREE: Yeah, I certainly. I have to clarify with our legislative advisors when I can do that because they’re being reviewed by our Minister’s office right now.
2582 COMMISSIONER SIMPSON: Right.
2583 MR. RENFREE: But ---
2584 COMMISSIONER SIMPSON: Well, we have a hard stop, I think, of January 24th that require -- if you wouldn’t mind spending a dime on a phone call, we’d love to get a copy of them and take them under advisement. So that would be January 24; if you’re capable of doing it, I appreciate it.
2585 MR. RENFREE: Okay.
2587 COMMISSIONER SIMPSON: I’ve already asked you about your collaboration with other provinces. Is that same collaboration that you exhibited with the creation of your Act -- I assume it extends to the Coalition of the Willing and the working group, the ESWG, that you’re active in all of those organizations?
2588 MR. RENFREE: Yeah, we’re very active in the NG9-1-1 Coalition. I would say that we’re occasional observers of the ESWG progress, my team we’re not technical experts. And that’s usually the focus of the discussion at the ESWG levels. But we certainly want to keep abreast of what they’re doing, and ultimately their decisions will eventually drive what happens in Canada with NG9-1-1 developments. So we feel it’s important to keep aware, but I would say we’re not active contributors to that group
2589 COMMISSIONER SIMPSON: The Coalition was pretty clear that they weren’t a big fan of the consortium model. Are you sharing that opinion, in that we’re looking at models that potentially could embrace a consortium of either a single provider or a collaboration of providers?
2590 MR. RENFREE: Right. Our focus is not so much on the technical side, so as far as how the network is built and ---
2591 COMMISSIONER SIMPSON: Well, I’m thinking of the overarching group. I shouldn’t have said the IPs but, you know, an entity that takes responsibility for the coordination of the provision of services at the ---
2592 MR. RENFREE: Right. So, yeah, we agree with the Coalition. I think that the main thing that we’re looking for is an entity that can provide some guidance and coordination even on standards and best practices, and things like public education.
2593 So Alberta wants to be in step with other provinces, but other than us being proactive and sort of following the ESWG proceedings, there’s nothing really official at least that sort of drives that. And we do our best in the Coalition to coordinate and share where we’re all at.
2594 COMMISSIONER SIMPSON: Right.
2595 MR. RENFREE: But we’re all doing that on the corner of our desks, and it would be good if there were dedicated staff devoted to that. I don’t think that structure needs to be overly bureaucratic for what the Coalition needs.
2596 The Alberta 9-1-1 team is only three staff, and we’ve been able to develop provincial standards, manage funding, and look at gaps in the system as well as other things like public education. So I don’t think you need a huge structure to do that, but we are looking for some sort of coordinating entity.
2597 COMMISSIONER SIMPSON: Help me put a face to what this might be because we’re hearing not only from the Coalition but others that a coalition that’s less ad hoc and more formal is something that the Consortium of the Willing is not willing to take on, yet I don’t think -- I’m not a legislative expert -- but I don’t think it’s a hat that the CRTC can wear either.
2598 So have you had any discussion with your group or others in any of the groups you work with as to what this group would be, what it would look like? Put a face to it if you can.
2599 MR. RENFREE: Yeah. From a Coalition perspective, we haven’t really had much discussion about how that group would be made up or what the representatives would be.
2600 COMMISSIONER SIMPSON: Right.
2601 MR. RENFREE: I think it would be good to have representatives from each province, either a provincial government representative or a representative of the local 9-1-1 association. Ultimately what we want is -- in Alberta at least -- something like how the building codes are developed. So a national building code is developed and then those are adopted or amended by the provinces and territories as they see fit.
2602 And I think that’s something that we would look for from a national entity is, you know, here’s the national standard, here’s the national roadmap for NG9-1-1. Some provinces may not be able to keep up with it but that would be the pace and the process for NG9-1-1 developments.
2603 COMMISSIONER SIMPSON: Okay. I just want to stay with the consortium concept for a minute. We can talk about other administrative forms in a minute. But in the wisdom of the whole as we come out the other end of this, if a consortium was deemed to be the best route to go and through the RFP process a provider or group of providers was selected by tender through an RFP, and that term was again five to ten years, do you see any pitfalls or opportunities knowing that you’ve already stated your case on consortiums?
2604 Can you give me your perspective on what you think it would be like to work with that kind of a model, whether it’s a single or a multiple provider?
2605 MR. RENFREE: Right. And so are we talking more the network side and the network oversight or ---
2606 COMMISSIONER SIMPSON: Yeah, well, yeah. I think we have to make some assumptions here that if a consortium were built that there would be -- let’s pretend there’s a funding model that goes with it so the burden of working off the corner of your desk is removed, and this consortium is in place representing a collection of the interested parties.
2607 Do you see any challenges or pitfalls or opportunities in working with a consortium model from the standpoint of being a PSAP? Because you’re responsible for PSAPs so that’s why I’m asking that question.
2608 MR. RENFREE: Yeah, so because the Alberta model really puts local autonomy first ---
2609 COMMISSIONER SIMPSON: Yeah.
2610 MR. RENFREE: And this is consistent with a lot of things we do in public safety in Alberta as far as emergency management and building codes, that sort of thing. The PSAPs in Alberta would be better able to speak to how they want to deal with a network configuration, so I can’t really speak to that.
2611 But from a provincial standards perspective, I think we’re looking for a body that has some authority and represents all provinces and territories and can say, “Here’s the way we want to move with NG9-1-1.” And we can take that and act accordingly.
2612 COMMISSIONER SIMPSON: Okay.
2613 MR. RENFREE: In consistency with other provinces and territories.
2614 COMMISSIONER SIMPSON: Okay. That’s not dissimilar to the answer that I’ve been getting to that question so I appreciate your candor.
2615 Let’s move over to the network design for a second. We’ve been looking at again the possibility of one national network with an ILEC doing the work or a combination of regional networks deployed and maintained by an entity other than the network providers. So there’s two different scenarios here. One is a national network with an ILEC operating it and the other is a series of regional networks maintained by an entity other than the current 9-1-1 provider.
2616 So can you just walk me around with respect to your views as to -- are there opportunities or pitfalls to either of those two models that you can see?
2617 MR. RENFREE: I’m not sure that I can add much more than maybe what Calgary or E-Comm said.
2618 COMMISSIONER SIMPSON: As you say, you’re in the middle, right.
2619 MR. RENFREE: Yeah, I think they probably captured that pretty well. And they would be able to give you a better perspective.
2620 COMMISSIONER SIMPSON: Yeah, okay.
2621 MR. RENFREE: Provincially we don’t really deal with network matters.
2622 COMMISSIONER SIMPSON: Right, yeah. I understand. It’s the old plague with, you know, if you talk about it you own it, if you own it you pay for it, so therefore, you know, you may have the leash on the beast and therefore you are the owner of it. That’s why you wanted to ask.
2623 I think I’d like to go back to best practices for a second.
2624 You know, when you were building -- again, this is more of a PSAP question but you were trying to set the bar for PSAPs on a primary level. So when you were looking at your standards and trying to establish best practices which are implemented in the field, again I want to ask the question about how far afield did you go beyond talking to other provinces? You know, is there any other models that you looked at -- are there any other models that you looked at that informed you, the U.S., Australia, or any of the others that have been referenced?
2625 MR. RENFREE: Yeah, for sure. I would say the other one that we looked to quite a bit was NENA, the National Emergency Number Association.
2626 COMMISSIONER SIMPSON: Yeah, right. Right.
2627 MR. RENFREE: So they’re based out of the States and their standards are applicable to American PSAPs, but we found them to be very useful here. NENA is great because they have a lot of standards that were developed with quite a bit of rigor, and they’re all available for free online so you don’t have to pay to access them. You can go through them and peruse their whole library of standards. So they’re very open from that perspective. So we did look to the NENA standards.
2628 We also looked a little bit to the APCO standards, the Association of Public-Safety Communication Officials. Their standards are good as well and have supplemented what we looked at.
2629 COMMISSIONER SIMPSON: Okay. On the issue of -- again this is network related. But on the issue of resiliency, we’ve got a couple of things that we wanted to shine the light into, and it's not only the resiliency and the reliability of the network, but also the security of it.
2630 So I'm going to start by asking you whether your contemplation of the standards that you set took into full account the issues of the NG9-1-1 network, having the same rigours of resiliency and reliability as the existing network, or do you think that it's the old analogy of the dishwasher with too many buttons is more prone to break than the one that only has two buttons?
2631 And does technology bring about the potential for weakness or failure in a more elaborate system? And if so, did you contemplate that when you were setting your standards?
2632 MR. RENFREE: So the -- one of the sections on -- in the Alberta standards is on facilities and business continuity. So we talk about the type of facility that's required, as far as physical security, cameras, that sort of thing, and we also talk about the power that's required, the generators and the uninterrupted power supplies. And we also speak about emergency response plans and that PSAPs need arrangements with other PSAPs in Alberta, where they need to have robust processes in place so that if something happens, they can go to their backup options.
2633 So our focus was more from that perspective. We didn’t get too much into technology, other than to say that they need to have a certain level of redundancy in their technology. But we didn’t focus too much on the cyber security side, that sort of thing.
2634 But one of the things that was pointed out when we first met with PSAPs and said, "Hey, what would you like to see in the standards?" technology standards were certainly one of the things that were mentioned. I think we probably decided to wait on that one a little bit, just to see where NG9-1-1 was going and focus more on the aspects of 9-1-1 that we knew were happening right now first.
2635 COMMISSIONER SIMPSON: So do I take from what you said that as far as your view of resiliency and reliability, it's still a work in progress because definitions of the network are still to be determined? Because I thought you had standards that determined what the network looked like.
2636 MR. RENFREE: The standard doesn’t talk, at this point, about the network.
2637 COMMISSIONER SIMPSON: Technologically, it talks operationally.
2638 MR. RENFREE: Yeah, right, but it does talk about resiliency from the standpoint of if there's a fire in your PSAP, what do you do to make sure that you keep answering 9-1-1 calls ---
2639 COMMISSIONER SIMPSON: Right.
2640 MR. RENFREE: --- and that no calls are dropped? So a lot of those mechanisms were already in place.
2641 COMMISSIONER SIMPSON: Yeah.
2642 MR. RENFREE: And during the Fort McMurray wildfire, the PSAP had to evacuate, but their calls were automatically taken by another centre in Alberta and that arrangement was already in place. So we were sort of standardizing something that already existed on that front.
2643 But at this point, we didn’t get into too much about the NG network. You know, we did talk about the network fail-overs between PSAPs and the redundancy that's required there, but I think the next version of our standards will really look at NG9-1-1 and some of those technological developments.
2644 COMMISSIONER SIMPSON: Oh, that's fair.
2645 Does your organization, at the level you're working at, take an interest in -- this is on the reliability standpoint -- do you want to see or do you see the reliability reports with respect to network outages and other failures; is that something that your group gets preoccupied with or is that something that happens at a different level in government?
2646 MR. RENFREE: What we would like to see is that network outages are -- the PSAPs are notified as soon as possible and what we've encouraged in the provincial standard is that they work through their local municipalities to activate the Alberta Emergency Alert System ---
2647 COMMISSIONER SIMPSON: Right.
2648 MR. RENFREE: --- if necessary. And last year it was activated eight times for telephone-related issues.
2649 COMMISSIONER SIMPSON: But the follow-up reports that explain why the network failed, are those important to you?
2650 MR. RENFREE: I think we would certainly be interested in seeing them, although really, that is for the PSAPs to work out with ---
2651 COMMISSIONER SIMPSON: Right.
2652 MR. RENFREE: --- the providers about, you know, fixing issues or gaps.
2653 COMMISSIONER SIMPSON: Okay. Let's just swing back to money for a minute. The question is going back to PSAPs, you know, I guess secondary PSAPs. Are they -- or let's put it a different way. As NG starts to roll out, again, certain PSAPs may find themselves under some form of operational or financial duress, in that they can't quite get up to the -- to fit the timelines that are required with the rollout of the network. And there's going to have to be some -- there are going to be some puts and takes with respect to how the slack gets taken up.
2654 Do you or have you contemplated how those costs of certain PSAPs should be recovered? Like, should they be recovered by the primary PSAPs? I'm thinking in particular, the cost of gateways if they're necessarily used to handle deficiencies.
2655 MR. RENFREE: Yeah, gateways to the secondary PSAPs?
2656 COMMISSIONER SIMPSON: Yeah.
2657 MR. RENFREE: Yeah.
2658 COMMISSIONER SIMPSON: Yeah.
2659 MR. RENFREE: So the funding to secondary PSAPs is something that definitely needs to be considered. I think we can all agree that secondary PSAPs need to be able to receive NG9-1-1 data just as well as the primary centres, or else the system won't work and you're dealing with work-arounds, where PSAP telecommunicators are reading text by voice or something like that.
2660 COMMISSIONER SIMPSON: Right.
2661 MR. RENFREE: And it's really the secondary centres that will require pictures and video. The PSAP is perhaps a mechanism to pass that on to them, but they may not provide benefit to the telecommunmicator answering a 9-1-1 call.
2662 The challenge in Alberta is that our provincial legislation focuses on primary 9-1-1 centres, and the reason for that parameter in our act is that EMS dispatch was already regulated under the Emergency Health Services Act.
2663 COMMISSIONER SIMPSON: Right.
2664 MR. RENFREE: So we had that reality, and you know, the RCMP provides police dispatch for the non-urban centres in Alberta, and they're governed by other legislation in Alberta and they report to a different department. So we felt the area to focus on was on 9-1-1 call answering.
2665 COMMISSIONER SIMPSON: Right.
2666 MR. RENFREE: So that's sort of the parameters for our funding, but you know, definitely funding of secondaries is something that needs to be looked at across Canada.
2667 COMMISSIONER SIMPSON: Right. Thank you.
2668 I want to ask you about -- and this is in line with new communications methods that NG will bring, the ability to handle -- we're trying to roll out Text-to-9-1-1 and we're hearing that there have been issues, you know, communications issues that bring about this question I'm going to ask you now, which is as you get into the belly of the beast and next-generation is starting to become a reality, two questions here.
2669 Who should be coordinating the awareness campaign for this next-generation system in terms of priming the pump for expectation? And secondly, when should that communication start; before the network becomes operational, at the time it becomes operational, or sometime thereafter?
2670 MR. RENFREE: Yeah, I think that coordination of national public awareness is something that should be coordinated through the national entity that the Coalition is referring to. That would be a prime thing that they could do. I think that each province and territory probably has their own approach with public education. In Alberta, we've put together a working group made up of volunteer PSAPs to look into that so that we can sort of coordinate messaging within the province. But it would be good do have agreed-upon key messages and communications points across Canada, so definitely, that's something that a national coordination entity could do.
2671 As far as when that campaign should be, you know, I think people will start to ask more and more questions about NG9-1-1, and as they travel to the States, you know, maybe they have an experience where they have to dial 9-1-1 and maybe it's in a State where they can Text-to-9-1-1 or maybe they’ve heard about those developments in the States ---
2672 COMMISSIONER SIMPSON: Right.
2673 MR. RENFREE: --- or in other places. The world is very global now, and it's very easy to find out what's going on in other places. And as other jurisdictions move forward with NG9-1-1 I think there will be an expectation in Canada that we maybe already have those things.
2674 And I think it was Eric Torunski from CITIG referenced a survey that was done a few years ago that I believe over 30 percent of respondents thought that you already could call for help on social media, and that was a few years that that study was done.
2675 So I would say the sooner the better for communicating some of these things and agreeing on even a timeline to communicate to people so that it’s clear about what they can expect when.
2676 COMMISSIONER SIMPSON: Okay. On alternate forms of communication theme continued, I know that you’re not technically prescriptive with respect to your legislation but from a standards standpoint, I’d like to ask you about text.
2677 Where are you at philosophically or legislatively with -- or from a standards-based perspective on text? We heard yesterday that Calgary is not capable of real-time text receipt right now. But is that part of your lexicon in terms of your role in guiding PSAP standards going forward?
2678 MR. RENFREE: So our role would likely be as the CRTC makes decisions about when telecommunications providers should offer text.
2679 COMMISSIONER SIMPSON: Right.
2680 MR. RENFREE: Subsequently that will be rolled into our provincial standards.
2681 COMMISSIONER SIMPSON: Okay.
2682 MR. RENFREE: So, you know, when a decision is made about when the providers need to offer it, you know, we will go through the process of updating our standards. And it may not be mandated in Alberta for maybe another two years if I’m being realistic because that’s probably the timeframe to sort of cycle through and get the standards updated, but eventually we look to raise the bar as these developments come in. And eventually they’ll be included in the Alberta standard.
2683 COMMISSIONER SIMPSON: So this is something that you take to discussion at the working group level?
2684 MR. RENFREE: Yeah. So it’s very much a provincial standard; it’s not the Alberta Emergency Management Agency Standard. It’s one that’s developed in close consultation with our stakeholder groups. So we would put together a working group on NG9-1-1 developments. It sounds like voice, IP, and texting will probably be the first developments. But put together a working group on that, recommend draft wording, and then bring it to the Alberta 9-1-1 Association for discussion and decision.
2685 COMMISSIONER SIMPSON: And this wouldn’t be something that the Coalition would take on as a goal and try and drive that down into the working group?
2686 I guess I’m trying to understand without us enacting regulatory requirements, as you’re looking at the abilities technologically of next-generation, you know, I’m trying to understand what we can count on the providers wanting to provide rather than being told to provide. And, you know, and understand better where the ambitions of the Coalition and the working group lie without having to be prodded with a stick from a regulatory standpoint.
2687 MR. RENFREE: Right. So I would say that Alberta wants to be proactive and, you know, we want to advance 9-1-1 at the same pace at least as other places. But we might be a bit reluctant to put it in the standard until it’s clear what the impact will be on PSAPs and how it will work from an operational perspective.
2688 COMMISSIONER SIMPSON: Sorry that you’re getting a little of the overlap from the gung-ho that we heard yesterday from Calgary ---
2689 MR. RENFREE: Yeah, that’s fine.
2690 COMMISSIONER SIMPSON: --- who wanted to embrace, you know, anything including carrier pigeons, it seems. And so I’m just trying to test your interest on this.
2691 You’re sort of operating at a higher level but PSAP-directed, and this question, I think, is best suited for you because it really isn’t a fair question to ask of PSAPs. But the world’s going App, there’s an App for everything, and there’s been a lot of detractors who said an App is a very good tool to provide people who are proactively going to download the App and put it on their phone in case there is an emergency.
2692 But from the standpoint that you’re sort of taking a bit of a top-down view with respect to the PSAPs underneath you, have you talked about at your group level the importance of or the possibility of designing an Alberta App for 911?
2693 MR. RENFREE: We haven’t had discussions about designing an Alberta 9-1-1 App.
2694 COMMISSIONER SIMPSON: Okay. Yeah, it’s an App, a federal or provincial responsibility.
2695 MR. RENFREE: Yeah, it’s ---
2696 COMMISSIONER SIMPSON: Yeah.
2697 MR. RENFREE: I mean, I think I would echo the comments that some of the other presenters made that if an App complied with certain standards then that could be something that we could look at.
2698 COMMISSIONER SIMPSON: Okay.
2699 MR. RENFREE: But, yeah, we haven’t had that discussion in Alberta. When the time comes that Apps need to be considered though, we’d use the same mechanism as we have with our standards.
2700 COMMISSIONER SIMPSON: Right.
2701 MR. RENFREE: And, you know, we’ll put together a working group and discuss the wording for the standard if we go that way.
2702 COMMISSIONER SIMPSON: Okay, thank you.
2703 This is another question that’s just -- it suits you to a T, I think. Transition is something that sort of is plaguing our thoughts. As you start building a new thing you have to make sure the old thing is still up, running, and robust and impenetrable.
2704 And we’re trying to get a sense of -- and we think you might have a good clue to this because of how you’ve been very proactive in working on NG9-1-1 -- of whether, and if necessary how and when, we should start looking at sun-setting the existing 9-1-1 network.
2705 This is going to be more of a gut feel answer, I think, but given that you’ve been looking at this for a while now, you’ve got some legislation that is adding rigour to what you’re doing, any thoughts as to transition out of old networks to new?
2706 MR. RENFREE: Yeah, I would defer to some of the comments that were made by some of the other presenters. I think the 2020 is certainly a target that our Coalition has put forward.
2707 COMMISSIONER SIMPSON: Yeah.
2708 MR. RENFREE: And it’s something that we can definitely shoot for in Alberta. Whenever we agree on a timeline, then eventually that will be incorporated into provincial standards so centres will have to comply with that.
2709 COMMISSIONER SIMPSON: Okay. I guess I have to go back to the gateway question then. So I guess it stands to reason then that gateway would be a backup if a PSAP can’t -- I’m thinking of the transitionary flow here. If we were to have a best before date or a due date for transition, gateways would in your estimation be the backup plan if a PSAP is not able to keep up?
2710 MR. RENFREE: Using gateways to still transition the information to secondary centres?
2711 COMMISSIONER SIMPSON: Yeah.
2712 MR. RENFREE: Yeah, I’m certainly not a technical expert so ---
2713 COMMISSIONER SIMPSON: Okay.
2714 MR. RENFREE: --- I wouldn’t be able to give you much more detail on that.
2715 COMMISSIONER SIMPSON: Okay. You said earlier that there’s no game plan to transition out of secondary PSAPs. But if that was to happen for any one of a number of reasons, technologically, financially, or otherwise, do you think that would accelerate the adoption of the next-generation networks?
2716 MR. RENFREE: It may but the PSAPs in Alberta are very keen to have standards.
2717 COMMISSIONER SIMPSON: Yeah.
2718 MR. RENFREE: And they want to be seen as an area of best practice. So when we have conversations with them, we’re sort of hearing them say, you know, “We want the standards to be more strict. We want them to advance as quickly as possible.”
2719 And as I mentioned in the Fort McMurray fire example, many PSAPs in Alberta already were following robust protocols as far as facilities and business continuity as an example.
2720 COMMISSIONER SIMPSON: Right.
2721 MR. RENFREE: But many of the other protocols that we have in here were things that were largely being done already in Alberta, so I think the PSAPs are keen to move onto the next-generation of 9-1-1.
2722 COMMISSIONER SIMPSON: Okay. Privacy? We’ve heard from PSAPs that they prefer a -- again, talking about big data or alternate data. PSAPs are saying, “Don’t send it to us unless we ask for it. But if we do get it, there’s the requirement for capture, hold, manage, and archive,” I suppose.
2723 But Shaw came at the problem from a different standpoint, saying that they believe that it should be PSAPs that capture and hold the data as part of the due course of doing their business, and the TSPs don’t have anything to do with that; they want everything to stay at the PSAP level.
2724 Have you had that discussion on privacy and responsibility of management of the data at your working-group level?
2725 MR. RENFREE: Not specifically on that front. The discussion that we have had is about record retention, and what we’ve said in our standards right now is that the PSAPs need to outline in their quality assurance plan what their record-retention policy will be.
2726 And currently there’s a mixture, but a lot of centres keep voice records, for example, indefinitely, and in some cases they might be on old tapes that are not even readable by modern technology.
2727 So what we’re going to do in addition to that is put together a working group to look at data-retention policies, and that could probably apply to NG9-1-1 data, pictures, videos, texts, et cetera.
2728 COMMISSIONER SIMPSON: Okay. Yeah. Almost done.
2729 We’ve been asking PSAPs to gain a better understanding of the challenges of answering and managing communication with individuals with disabilities.
2730 Have you anything to add to that question in terms of the challenges that PSAPs have been having when responding to requests for assistance from individuals with disabilities? Is this something that you’ve wrapped your head around or brought up to your level of attention?
2731 MR. RENFREE: Yeah, so one of the sections of the standards that will be in a future version is on accessibility. So that will cover a lot of things but I think the overall principle behind that will be that everybody should be able to contact 9-1-1 when they need it.
2732 So the accessibility section can talk about things like texting for people who are deaf, hard-of-hearing, or speech impaired. It can talk about things like language lines, like E-Comm mentioned earlier today, and also talk about any other NG9-1-1 developments that might make 9-1-1 more accessible.
2733 So it’s certainly a conversation that we’ve had at the early level and we’ve we do intend to put things like that in our standards.
2734 COMMISSIONER SIMPSON: Have you got, in your standards, anything that references how long you’ll continue to support TTY?
2735 MR. RENFREE: No, we don’t at this time.
2736 COMMISSIONER SIMPSON: Okay. Just two more questions and then I’m done.
2737 In your oral presentation this morning, on page 6 -- and this is to educate me because I may not have been as good as I should have been in reading your Act but, with respect to the levy, I was under the impression that your capture of 44 cents was just on cell phones.
2738 MR. RENFREE: That’s correct.
2739 COMMISSIONER SIMPSON: And yet you referred to in one, two, three -- third paragraph you said:
2740 “For example, Alberta’s landline and wireless 9-1-1 levies go back to PSAPs to fund their operations.”
2741 What landline levies are you talking about?
2742 MR. RENFREE: Right. So the province doesn’t manage the landline levy but it’s been in place in Alberta for over a decade. So Telus collects and administers that and that funding goes back to the PSAPs. But the reason we brought in the wireless funding was that funding was decreasing each ---
2743 COMMISSIONER SIMPSON: Oh, sure, it’s, like, 60, 70 percent of the calls.
2744 MR. RENFREE: Yeah, exactly. So the centres were not getting nearly as much funding from the landlines and that was really the only segment of Alberta that was providing direct funding to PSAPs. So now this wireless funding has given them a top-up; it doesn’t cover all their costs but it certainly helps. And as Calgary mentioned yesterday, it’s a good way to really start on some of these next-generation developments.
2745 COMMISSIONER SIMPSON: So again thank you. I told you it would be for my own education; I didn’t realize the legacy nature of that. If Mr. Menzies had been questioning you, he would have known that.
2746 So anyway, the last question I have for you -- and it may not be answerable at this point but it certainly is worth asking.
2747 In the event that the decision goes to the consortium route, your group has been very active and enthusiastic with respect doing whatever it takes, wherever the application of energy is -- needs to be applied to helping build a national model, but would your organization -- could we count on that cooperation continuing into a consortium model if we asked?
2748 MR. RENFREE: Yeah, absolutely. And I mean, from our perspective, I know there’s a lot of technical aspects that need to get sorted out.
2749 What we’re looking for is more of the policy standards, public education, that sort of guidance so that as we move forward we know that we’re taking the right steps in Alberta and we’re doing it in conjunction with other provinces and territories, and we’re doing it in a way that is clearly publicly communicated so we don’t have a situation where people are saying, you know, “What’s going on here? I don’t really understand. I travel to different provinces and everything is different.”
2750 So that’s really what we’re looking for from a coordinating body. And I know that a lot of the other presentations have talked about some of the other aspects of what they will do, and I can’t really comment on that. But as far as being involved with that, absolutely, we want to do that.
2751 My team, our full-time job is 9-1-1 and making it stronger in Alberta, and also across Canada. So whatever we can do to help, you can count on us.
2752 COMMISSIONER SIMPSON: Thank you very much.
2753 THE CHAIRMAN: Vice-Chair Menzies?
2754 COMMISSIONER MENZIES: I just wanted to clarify on an analogy you made when you talked about our role potentially being like setting national building code and then provinces amend and that sort of stuff. And when I heard it I thought, “Well, that makes a lot of sense,” and then I kind of went, “Whoa, wait a second.”
2755 I may have taken it the wrong way because it sort of sounds very workable for the 9-1-1 system that we have now but my concern with that -- and you’ve talked about the need for national coordination and that sort of stuff -- is that, well, what if you had Text-to-9-1-1 in one province and you didn’t -- and I drove from the west side of Lloydminster to the east side of Lloydminster and it wasn’t working?
2756 Help me understand what you intended with that analogy or how those sorts of things would be managed, like if one province wasn’t keeping up with the other. Wouldn’t that cause -- doesn’t that run the risk of the public making bad decisions, or inappropriate decisions, or potentially dangerous decisions? You’re the 9-1-1 guy so help me understand that ---
2757 MR. RENFREE: Right.
2758 COMMISSIONER MENZIES: --- because right now it’s a phone call. You make the phone call and somebody answers, right? If you have these other methods, having a patchwork might be dangerous.
2759 MR. RENFREE: Yeah, so I think we certainly want a reality where the provinces and territories are consistent. And you raise a good point, that you want to be able to travel from Alberta to Saskatchewan, for example, and if you can text in one, be able to do it in the other.
2760 But I think we also have to appreciate that provinces won’t just flip a switch and, you know, go from the current system to a next-generation system. It will have to sort of transition. And there may be some time where provinces are at a different place, so I think that’s where the public education piece really comes in. And if it’s not at the same time, then say, “Okay, this is what’s happening in your province.”
2761 And I think through that public communication, if a province or territory was lagging behind, they would probably do what they can to get in line and do what they could to advance their system.
2762 I certainly wouldn’t want to go to my Minister and say, “I’m really sorry but there’s going to be advertising going out across Canada that says that Alberta’s lagging behind.” So that would probably result in a lot of work for me and my team so that we could get caught up in Alberta.
2763 COMMISSIONER MENZIES: So you think public pressure would manage some of that? I mean if Saskatchewan had Text-to-911, and B.C. did, and Alberta didn’t, that that would create ---
2764 MR. RENFREE: Yeah, I think it would. And ---
2765 COMMISSIONER SIMPSON: --- a sort of political market force?
2766 MR. RENFREE: Right, yeah. And barring some -- you know, I don’t know if there’s an appetite for federal 9-1-1 legislation, so to speak, but historically 9-1-1 as always been a provincial and municipal matter. And so I think that’s maybe one of the most practical ways to do it without really changing the legislative framework in Canada.
2767 COMMISSIONER MENZIES: Okay, thanks. I understand better now what your intent was. Thank you.
2768 THE CHAIRMAN: I believe those are all our questions. So thank you very much.
2769 We’ll take an afternoon break for about 10 minutes or so. Why don’t we come back at 2:50 because we have to set up a conference call?
2770 So we’re adjourned until 2:50. Merci.
--- Upon recessing at 2:41 p.m.
--- Upon resuming at 2:53 p.m.
2771 THE SECRETARY: Please take your seats.
2772 THE CHAIRMAN: À l’ordre, s’il vous plaît.
2773 Madame la Secrétaire?
2774 THE SECRETARY: Thank you.
2775 We will now hear the presentation from the Saskatchewan Telecommunications, appearing by videoconference from the Regina CRTC Regional Office.
2776 Please introduce yourself and your colleagues, and you have 20 minutes for your presentation. Thank you.
2777 MR. SPELAY: Thank you. Good afternoon, Mr. Chairman, Commissioners. My name is Kevin Spelay, and I am a Regulatory Affairs Manager for SaskTel. I am pleased to have with me today, on my right, Jeff Fowler, Senior Engineer Wireless Development, and on my left Ben Ryan, Director of Carrier Services.
2778 In the second row are our technical gurus. Directly to the right of Jeff is Rick Kuruliak, Network Planner. And to the right of Rick is Mark Miles, Senior Engineer, Wireless Service Development. And to the left of Ben is Joy-Ell Sahlmueller, Marketing Analyst.
2779 We are very happy to be here to offer our input in regards to the evolution of 9-1-1 in Canada.
2780 As the ILEC in the province of Saskatchewan, SaskTel has been part of the evolution of 9-1-1 services since its inception, from basic wireline 9-1-1 to the current E-911 and the evolution of 9-1-1 calling on cellular.
2781 There has been a large amount accomplished though the collaborative efforts of the Commission and the industry in the past to bring 9-1-1 service to where it is today. We’ve met all the challenges collaboratively as an industry and have developed a world class reliable, resilient public safety network in Canada, as the Commission itself has recently noted in its Telecom Regulatory Policy CRTC 2016-165, Matters related to the reliability and resiliency of the 9-1-1 networks.
2782 The implementation of the Canadian i3 solution, which is the basic building block of NG9-1-1, will build upon this already established framework going forward. With this in mind, SaskTel’s position remains to continue to allow the current ILEC’s 9-1-1 service providers the opportunity to build upon current networks to bring forth NG9-1-1 to Canada. The implementation of the Canadian i3 solution will be complex and challenging.
2783 As we work through this process we must not lose sight of the end goal, which is to provide a world class, reliable, resilient 9-1-1 network that provides superior public safety to all Canadians.
2784 The initial i3 solution will provide the like for like base upon which to build any future features and functionality. This should be the focus of the Commission and the industry in the near term, getting this solution right and in place.
2785 There are many advanced services and capabilities that have been proposed to date in this proceeding. While we do not underestimate their potential, we’d note that they are future-oriented solutions that are best dealt with down the road, once the i3 network is in place.
2786 More importantly, PSAPs and other public safety agencies will need to be in a position to receive and utilize such data. This will require that municipal, provincial and federal governments spend additional millions of dollars on upgrading the communications systems and networks of these entities in order to make use of these enhancements provided.
2787 I will now pass it over to Jeff to discuss some technical challenges we see moving forward.
2788 MR. FOWLER: Thanks, Kevin. Good afternoon, Commissioners.
2789 As Kevin noted, the move to an i3 compatible architecture in Canada will be a large undertaking, and we are only beginning the planning stages of this endeavor. SaskTel is an active participant in the CISC ESWG process that is shaping and developing the model that the industry will implement in the coming years.
2790 Next-generation 9-1-1 will require what is essentially a new network to be developed for the provision of 9-1-1 services. This new network will run in parallel with the established TDM-based E-9-1-1 network for a period of time -- we estimate at least 5 years -- until it becomes economically feasible to retire the legacy 9-1-1 network.
2791 This is due in part to the fact that at the present time, the majority of traffic still resides on the TDM network within our serving territory. The premature retirement of the legacy 9-1-1 infrastructure would result in a requirement to convert this traffic through gateways to the new next-generation 9-1-1 network, and would be a costly and inefficient use of resources and capital.
2792 Rather, it would be more prudent to wait until such time as more traffic has been migrated to IP within networks to make this change. It will not be an automatic flash cut to next-generation 9-1-1, as some may be led to believe. Furthermore, as the architecture is not fully developed at this time, the final cost of this implementation cannot be determined; however, we estimate the total capital costs to be in the millions of dollars over this time period.
2793 It is important to note that in the near term, the baseline i3 solution currently under development through the ESWG is essentially a like for like replacement of the current TDM 9-1-1 functionality in IP form.
2794 Part of the challenge in doing so is replicating the reliability, resiliency, and overall functionality of a tried and tested TDM network in a SIP environment. It is imperative that we as an industry take the time and effort to ensure that this base layer of the new architecture is properly defined and implemented as it will be the building block for all future 9-1-1 public safety services.
2795 With that said, the i3 solution has the potential in the future to provide much more robust functionality than its legacy predecessor, and these functionalities will need to be developed and explored in due course.
2796 For instance, ESWG is currently reviewing potential solutions to the age-old problem of automatically determining the location of nomadic VoIP users. In the case of this functionality, it must be noted that not all end-user SIP-based devices in the market today are capable of providing location information utilizing current technology. And even if implemented, the industry will ultimately be at the mercy of equipment vendors to provide updates to make this functionality work.
2797 Further functionality will be made possible, such as the ability for users to send text and video messages to the PSAPs; the availability of medical records or building plans to be accessed; and other yet unknown features and functions.
2798 We must be cognizant that while the i3 platform and next-generation 9-1-1 have the theoretical potential to introduce many of these new elements, that these are future-oriented services that will need to be managed, developed, and implemented in the future once the transition is complete.
2799 Network service providers such as SaskTel will be part of the solution, but unlike the current 9-1-1 system, many of these new elements will require the participation of other outside parties to be successful.
2800 For instance, if medical records are used as an example, the service providers could host servers that contain the records and ensure that a record is delivered when requested. However, other third parties such as health authorities and PSAPs will ultimately need to be involved to manage the content and application of such records in an emergency situation.
2801 Similarly, we must all be cognizant that over-the-top applications such as Facebook, iMessage and WhatsApp and/or the creation of a standalone next-generation 9-1-1 App are outside of the control of the service providers.
2802 If it is anticipated that these applications will be able to be utilized within the next-generation 9-1-1 system, it will be required that the providers of these services be engaged to ensure that these applications can be integrated successfully.
2803 I will now hand it over to Ben.
2804 MR. RYAN: Thanks Jeff. Good afternoon, Commissioners.
2805 I am going to speak to the elephant in the room, which is of course the funding model. As you are aware, SaskTel is in somewhat a unique situation amongst 9-1-1 service providers in Canada in that its funding model is based upon a Commission-approved tariff based on a cost study filed in 2001.
2806 Unlike other providers, SaskTel’s 9-1-1 telecommunications rate remains constant, at $0.21 per working telephone number per month. This Commission-approved rate is also reflected in provincial legislation, as SaskTel has a legislative obligation to provide 9-1-1 network functionality and connectivity services within the province.
2807 It is our position that we do not need to make wholesale changes to the way 9-1-1 is funded for the transition to NG9-1-1. Rather, the changes could be made to the current tariff and the associated $0.21 rate going forward once the architecture has been decided upon and costs are determined in the future.
2808 This would of course require that new Phase II cost studies be performed for the NG9-1-1 network, and at the present time it is too soon to determine whether this rate would increase or decrease.
2809 However, the new rate must be compensatory for the costs incurred on an ongoing basis for the new network. Upon further review, it may also be determined that for NG9-1-1 in the future, the base upon which this charge is to be recovered may very well need to change. As more and more subscribers move to SIP-based devices and potentially other forms of communication such as texting or video calling, for instance, the idea of levying a fee based on working telephone number may no longer be relevant.
2810 We’ve wrestled internally as to what the appropriate base could be going forward should working telephone numbers no longer be relevant. Some possible solutions could be by IP address or by registered device. These are all questions that ultimately need to be decided at some point in the near future, possibly during a follow-up proceeding to determine the funding model of NG9-1-1 once a policy direction has been set through this decision.
2811 This brings us to another topic of funding discussion that must be had, that being the transitional funding regime where service providers are providing 9-1-1 services over both the legacy and NG9-1-1 systems. As Jeff alluded, it may take between five to ten years for the transition to NG9-1-1 to be fully complete.
2812 It is SaskTel’s position that the Commission must allow service providers to retain the ability to recover the costs of operating the legacy network, while at the same time recovering the cost of the new NG9-1-1 network. As I have already discussed, it is anticipated that the rate, as well as the base upon which it is levied, will be different for NG9-1-1 than it is currently for legacy service.
2813 One such solution may be the ability of service providers to continue to charge customers on legacy networks the current rate, and those on SIP-based networks the new rate going forward once a customer has migrated to a new service platform.
2814 Regardless of the cost-recovery model chosen going forward, we must be cognizant of the level of capital budget available to the industry, and the economic reality that is present in the majority of the country.
2815 In Saskatchewan particularly, we are in the throes of an economic turndown. While we put the provision of 9-1-1 and emergency services at the highest priority when developing our capital budgets, we must recognize that this will affect other important areas of the industry where this capital could be deployed, such as the transition from TDM to IP voice services.
2816 With this in mind, we would expect that the investment in the provision of i3 infrastructure be spread out over a longer time period and that the introduction of future-based functionality be deferred until such a time as the entire public safety ecosystem is prepared to make use of such functionality. This would ensure that we are prudently spending capital on the provision of NG9-1-1 where immediate impacts on public safety can be realized, and not in areas where services may be “nice to have” or “market trialed” as opposed to actually needed, or where the impacts will not be seen til some point in the future.
2817 Additionally, it should be noted that new services and functionality will not only take capital dollars to develop and implement, but also require service development to occur in terms of governance, marketing, policy controls, and other systems work. As such, additional time and resources will be needed to turn these services functional and implement them in the marketplace. Any implementation times must take this into account appropriately.
2818 Finally, I would like to touch briefly on our relationship with Sask9-1-1. SaskTel has developed a close working relationship with the provincial governing body for PSAPs within Saskatchewan. We work closely with Sask9-1-1 on all aspects of delivery of 9-1-1 emergency services within the province, from network connectivity and services, to the collection of the provincially-legislated $0.62 call-taking fee on their behalf. This relationship, to the best of our understanding, is unique within Canada. It has worked well to serve the residents of Saskatchewan and we anticipate that it will continue to provide the same benefits going forward into the future.
2819 I'm going to now pass it back to Kevin for some closing remarks.
2820 MR. SPELAY: Thank you, Ben.
2821 Commissioners, we would like to thank you again for the opportunity to come here and make our case before you. As both Jeff and Ben have noted, we are presently in the process of moving towards the implementation of the Canadian i3 network architecture that will ultimately be the base upon which NG9-1-1 services will be enabled in the future. This implementation will bring forth numerous improvements to the provision of 9-1-1 services in Canada, but it will take time, effort, and capital to become a reality.
2822 We ask that the Commission, industry players, and public remain patient and cognizant of the challenges that we will face in this transition. It will not happen overnight, nor will it be the silver bullet that some people envision it to be, but it will develop over time.
2823 With that, we are now ready to take your questions.
2824 THE CHAIRMAN: Thank you very much. I will put you in the hands of Vice-Chair Menzies.
2825 COMMISSIONER MENZIES: Thank you. Before we get into some of the other stuff, can you just clarify for me the $0.62 fee is -- that's the fee that funds the PSAPs; is that correct? And the $0.21 fee ---
2826 MR. RYAN: The primary PSAPs.
2827 COMMISSIONER MENZIES: Yeah, there's three, right?
2828 MR. RYAN: Yes, there is.
2829 COMMISSIONER MENZIES: Yes, so that ---
2830 MR. RYAN: Three primary PSAPs.
2831 COMMISSIONER MENZIES: So the $0.62 you collect and remit, and that goes from -- through the government to fund the PSAPs, right? And the $0.21 is ---
2832 MR. SPELAY: (off mic) three.
2833 COMMISSIONER MENZIES: Sorry, and the $0.21 is your cost recovery for SaskTel's costs; is that correct?
2834 MR. SPELAY: Correct.
2835 COMMISSIONER MENZIES: Okay, thanks.
2836 I wanted to get your impression on -- of, rather, the Coalitions and request for a national coordinating body for NG9-1-1 as we go forward. I understand, and many have made the point too that there's a lot of complex issues to work through down the road, but they and others made arguments, persuasive arguments, that as we go forward and there's a variety of different things to look at, there is a greater need for more coordination as opposed to direction at a national level regarding some of these things.
2837 So I'd just like to -- like you to share, if you could, your thoughts on that proposal and other similar ones.
2838 MR. SPELAY: From a perspective of coordination of thoughts, ideas, governance policy, we would definitely tend to agree with the Coalition that a national body could be of great help to the industry and all players -- PSAPs, emergency service providers, et cetera.
2839 We're not necessarily in support of a national service provider model. We believe that the current model where the ILECs within the provinces that they serve are the network service provider for 9-1-1 is appropriate going forward. We do have the relationships with the PSAPs, both primary and secondary, as well as emergency service providers in our jurisdictions.
2840 COMMISSIONER MENZIES: Is it that relationship, do you think, that makes the present model, the ILEC model -- we'll call it that -- more in the interests of public safety than a national -- than the national proposed model with an RFP model for an operator?
2841 And I'm just trying to get to what is it specifically about the current model that you believe makes it operationally superior?
2842 MR. SPELAY: From our standpoint, the PSAPs know what we're capable of. The PSAPs know what we're willing to step forward with. We have a very close relationship with them. It's a local presence for our PSAPs and our emergency service providers. It's not some operator out in southern Ontario or Vancouver that they'd be talking to to try to get services or talk to somebody about an outage.
2843 From a technical standpoint, I believe that we have some concerns as well ---
2844 MR. FOWLER: Yes.
2845 MR. SPELAY: --- from a national provider's sense.
2846 MR. FOWLER: Yeah, I think the model (inaudible) distributed IP network is inherently resilient and more redundant, just because of the way it's built, and so that kind of lends itself to the way that the ILECs have put things together.
2847 And then secondly, the call quality of a 9-1-1 call, you know, when we're talking about great distances to a central location, there may be some issues with that that I don't think would be very good for our customers.
2848 COMMISSIONER MENZIES: But it’s more specific to reliability and resiliency; is that the primary argument there technically? That the ---
2849 MR. FOWLER: Technically, yes, for sure.
2850 COMMISSIONER MENZIES: Okay, thanks.
2851 On another item mentioned yesterday and I think it’s been mentioned more than once today too, TELUS and others have estimated that it would take three to five years as a reasonable timeframe to think about beginning the rollout of NG9-1-1. And TELUS was reasonably specific. And this doesn’t sound much different from what you’ve said, but they gave 2028 as a date that would be a reasonable end date for this transition. That would be the point at which we would be shutting down the existing network and going with a new network, going forward solo with the new network.
2852 Do those dates make sense to you?
2853 MR. SPELAY: Yes, that would be consistent with us and our thoughts.
2854 COMMISSIONER MENZIES: Okay, thanks.
2855 You mentioned it today, and in paragraph 13 of your written presentation you pointed out that a legislative change would be required in Saskatchewan if we went with the sort of single national network model because you’re required as a Crown to provide 9-1-1 service.
2856 If we went that way, would you expect that legislative change to be a problem?
2857 MR. SPELAY: I’m not sure it would necessarily a problem. It would be something to keep in the back of everyone’s mind. Depending on when the decision came forward, whether our provincial government was sitting at the time. It will all have to go through their legislative processes to repeal that bill and that specific legislation.
2858 COMMISSIONER MENZIES: Okay, thanks.
2859 Now, would you agree with TELUS then that the best way to create a national network is by connecting the regional networks? I think you kind of suggest that in paragraphs 14 and 15 of your written.
2860 MR. SPELAY: That would be correct, yes.
2861 COMMISSIONER MENZIES: Okay, thanks.
2862 Now, you also indicated in that written that you hoped to have a plan and transition budget to NG9-1-1 by early 2017. And it being early 2017 now, albeit very early 2017, I was just wondering if you had anything you could share on that in terms of progress?
2863 MR. SPELAY: Unfortunately, not at this time. We continue to work through CISC. We continue to work internally trying to determine what components, et cetera, that we would require to make the transition and get some idea of the costs. So unfortunately we haven’t got to that point yet as an industry.
2864 COMMISSIONER MENZIES: Okay. And how soon do you expect to be able to -- working with Sask911 to be able to upgrade? Because you’ve suggested that too, that you were working to upgrade to an IP-based hosted solution at all three centres. Do you have a target date for that?
2865 MR. SPELAY: The implementation of that whole solution?
2866 COMMISSIONER MENZIES: Yeah.
2867 MR. SPELAY: That is complete.
2868 COMMISSIONER MENZIES: It is, okay. Good.
2869 MR. SPELAY: It has been up and running since, I believe, July.
2870 COMMISSIONER MENZIES: Okay. Super, thank you.
2871 Now, in terms of the compensation models, you’ve sort of referred to that as the elephant in the room but let’s sort of start off with this point first. Some have argued in this process that the current 9-1-1 network operators are very likely being overcompensated for their costs, and I expect they would argue that’s why you prefer the current tariff compensation model.
2872 I wanted to give you the opportunity to comment on that point of view. Are they correct; is $0.21 too much?
2873 MR. SPELAY: We definitely do not believe so. We’re not making any money at $0.21. We’re not losing money, we’re not making money. It’s covering our costs going forward.
2874 Ben could speak more as that rate is collected in his shop, but that fee does cover the present system as it is today as well as in the upgrades that we do make to that system. It’s an ongoing upgrade process that we’re always refreshing software loads on our switches that are affected by that. We are increasing battery banks, doing maintenance on battery banks to keep those switches running, et cetera.
2875 So I don’t think that we’re overcharging by any means. I think it’s probably pretty close to our costs.
2876 MR. RYAN: I think that the current success that we’ve had in terms of reliability and resiliency of the network is the result of the efforts that Kevin has mentioned that we put towards this. We don’t believe our $0.21 is different from other jurisdictions but we will -- you know, and it could evolve going forward, and it will evolve as the networks change.
2877 But right now because it is truly a cost recovery model, we think that there’s more success in looking at this than potentially an enterprise where someone could bid on a RFP with commercial units. They’re looking at seeking a merchant for their own interests.
2878 COMMISSIONER MENZIES: I understand that. When we’re looking at potential future compensation models for NG9-1-1, and looking at likely parallel systems for at least 10 years, or roughly around that 10 years, would you think it would be appropriate to have the same rate apply to mobile phones as to wireline phones? And would you think that ISP revenues or ISP bills might also be a source of funding for NG9-1-1?
2879 MR. SPELAY: I think that’s ultimately where we’ll be driven. As the landline network, the TDM-based network continues to ride into the sunset over the next 10 years we’ll more into the SIP and IP-based environment. We’ll see a lot more communication over the IP network in addition to over the public Internet, so to speak.
2880 That’s where we get to -- it’s probably not going to be collected on a working telephone number basis like it is today anymore. It may be needed to be collected on an IP address basis, a device MAC level basis. If it can interconnect with 9-1-1 network we need to charge at that level. It’s really an unknown at this time.
2881 COMMISSIONER MENZIES: I understand that.
2882 MR. SPELAY: So definitely ---
2883 COMMISSIONER MENZIES: Go ahead, please.
2884 MR. SPELAY: I definitely think that the ISPs will need to be brought into the model and into the funding of NG9-1-1 going forward.
2885 COMMISSIONER MENZIES: Okay, thank you.
2886 So far when referring to costs, the answer seems to be more. And it doesn’t get much more specific than that in terms of that. Is it possible for you to give us a ballpark figure? Like, would it cost -- if we’re dealing with $0.21 now will we be dealing with $0.45, or will be dealing with $0.90, or will be dealing with $1.50 in terms of the extra cost to subscribers?
2887 And keeping in mind too that there would be multiple sources of funding from within each household assuming there's two or three or four cell phones and an internet subscription and the what -- and the landline. Perhaps if they have all of those then there could be five or six bucks a household going towards this at the end of -- per month.
2888 Do you have any idea on those? I'm not going to hold you to it; just a best guess.
2889 MR. SPELAY: (Inaudible). I think you'll probably potentially see it go up marginally -- and I'll say marginally. We'll have fixed costs. They'll use it and will need to recover just like they do today. But like you said, we'll spread that cost a little over a larger number of potential sources of collection. So where today we might only get it from the landline, tomorrow we might only -- we might get it from four cell phones, an iPad and two internet connections. So I think the base will grow, but the fixed costs will probably remain the same or could slightly increase ---
2890 COMMISSIONER MENZIES: Okay, thank you.
2891 MR. SPELAY: --- from our costs.
2892 COMMISSIONER MENZIES: Okay, thanks. So the overall impression of your presentations is that you’re really pretty much status quo, albeit you spoke of how a national coordinating body can be useful, at least until the construction of an i3 architecture is complete, right? And I just want to push you on that a little bit.
2893 Like, why shouldn't we push a bit more rather than -- because your -- my impression of what you said was, "Hurry up and wait. Let's just wait. Let's get this done and then we can move forward one step at a time," which is, you know, a prudent approach, some could say, but we could also say that it's overly conservative and that we should push forward and -- on this file a bit -- to make sure the networks are in place to meet the demands of next-generation methods of accessing 9-1-1.
2894 I mean, City of Calgary gave a couple of pretty good examples yesterday of how efficient it can be, even though they were doing a bit of an end around their system. Don’t you think it would be useful for us to be -- err on the side of urgence?
2895 MR. SPELAY: We could definitely be more -- less conservative, get our network in place, get some of this functionality going to the primary PSAPs. They're not necessarily the ones that will make the end use of some of that extra functionality and features. That will be further down the pipe, either in the secondary PSAPs or right down to the -- say the fire truck that's on the way to a call. That's something that hasn’t necessarily been fully discussed and I'm not necessarily sure that we understand the full financial impact of those decisions.
2896 When we speak of a small town in Saskatchewan and their volunteer fire department, they're more worried about having money in the bank to fill the truck, not whether or not they can get text and pictures. So I think we need to be cognizant of that, going forward, as we push.
2897 As well, a lot of the new future functionality hasn’t been proven out. When we speak of being able to contact 9-1-1 through Facebook, we have no visibility or control of the Facebook application, so we would have great difficulty on even knowing, as a network provider, that a call was coming in through Facebook without Facebook being involved, et cetera.
2898 So that's where we're being a little more conservative in that we need to get all the pieces (inaudible) where people are at the table and the right decisions are being made before just rushing in.
2899 COMMISSIONER MENZIES: Okay, thank you for that. And just a couple of questions to points of clarity.
2900 In your submissions, when you refer to the funding -- or not the funding model, but the network model -- when we refer to ILECs, we are referring to those ILECs with 9-1-1 obligations; is that correct?
2901 MR. SPELAY: Correct.
2902 COMMISSIONER MENZIES: Okay, thanks. And speaking of which, I understand that you share a network with Bell to some extent. Do you see that continuing with NG9-1-1?
2903 MR. SPELAY: So we do utilize Bell Canada's ALI database, and that decision was made to utilize that as a hosted solution. Due to cost reasons and economies of scale, the solution they provided us is better than anything that we could have, you know, put together ourselves for that cost.
2904 Going forward, there may be certain portions of the network that we could share with other providers, but once again, we need to really know what those portions of the network are, what they do, and what they cost before we could submit to sharing that with others.
2905 COMMISSIONER MENZIES: Okay, I understand.
2906 In terms of interconnectivity, in the current framework, CLECs -- which I don’t think has any impact on you -- wireless carriers, and PSAPs are considered trusted entities that can connect directly. So is there -- going forward, looking at NG9-1-1, do you think there is anyone we should be adding to that category of trusted entity?
2907 MR. SPELAY: I think that question relies on kind of what you want NG9-1-1 to look like, going forward. If we're talking adding the availability of medical records, we would probably have to include a Department of Health in the mix. We would probably have to potentially include third parties, Facebook, WhatsApp, those type of entities as well if you're planning on allowing those communications methods to come through to the 9-1-1 system.
2908 COMMISSIONER MENZIES: Okay, and who do you think should be responsible for approving membership in that club -- the working group, CRTC, a national coordinating body of some kind, Sask911?
2909 MR. SPELAY: I think -- well, it could very well be Sask911 in our case or at least the ESWG which brings together the industry, the vendors, the PSAPs themselves.
2910 MR. RYAN: At this point, they have the broadest representation with their members.
2911 MR. SPELAY: Definitely. That will be at least a starting point, going forward.
2912 COMMISSIONER MENZIES: Okay. Now, also in terms of reliability and resilience and security, some again have made the point that the IP-based communications and open standards have some exposure in terms of network vulnerability that may not exist with the current system. Do you agree with that or do you see that being a manageable issue going forward, if it is -- if you see it as an issue at all?
2913 MR. SPELAY: (Inaudible).
2914 MR. FOWLER: I think we would agree that that is an issue that, although there are -- let's call it -- it's a more distributed network, so failures, in essence, can be self-recovered more easily. The complexity of the nodes within the network are more complex than we have today, so that would lead you to believe that there could be some challenges there in dealing with, you know, new versions of software, where we get stuck today sometimes, or other issues like that.
2915 So, you know, I think it’s a little bit of both, really. The general architecture itself, like I said, should be more resilient to, like, hard failures and stuff like that, but you are implementing any more software-centric solution, which in itself is not as mature as the technology we’re dealing with today, obviously.
2916 COMMISSIONER MENZIES: Okay, thanks. Among the cost -- what is the single largest cost factor that you see in terms of additional cost of NG9-1-1, or is there one?
2917 MR. FOWLER: I don’t know if there’d be a single one. I just ---
2918 MR. SPELAY: No.
2919 MR. FOWLER: It’s really tough to ---
2920 COMMISSIONER MENZIES: No, that doesn’t mean ---
2921 MR. FOWLER: Until you get into it and actually look at your pieces, right?
2922 COMMISSIONER MENZIES: Right, there could be multiple largest-cost factors in terms of that. But if there was a single one that you could point to, that was that question. But there -- the fact that there isn’t is certainly as adequate an answer as if there was one.
2923 So the next question is -- I just wanted to confirm for the record, too, that you prefer the current ILEC tariff-based collection -- or cost-recovery method in terms of that. Is Phase II costing still your preferred method to compensation going forward?
2924 MR. SPELAY: We would believe so. We wouldn’t know of a different methodology that would provide the same level across all ILECs involved. And it’s definitely approved, then, by the Commission so we know -- and the public and others know that you’ve looked at those costs and you’ve approved those costs based on your costing methodology.
2925 COMMISSIONER MENZIES: Okay. Do you think NG9-1-1 should or could be designated or viewed as a basic telecommunications service?
2926 MR. SPELAY: We could definitely say it’s a basic telecommunications service in that we, as a telecommunications service provider, have the network in place and are capable of delivering it.
2927 In our particular case and jurisdiction, our network’s capable of delivering E9-1-1 to all landline phones in Saskatchewan, as well as wireless phase 2, stage 2 throughout our wireless network.
2928 However, in the very far north of Saskatchewan, 9-1-1 isn’t offered. And that’s not because our network doesn’t support it there; it’s because Sask9-1-1 has nowhere to dispatch in those areas.
2929 So we could say it’s a basic telecommunication service in that we can provide it as a telecom provider, but there’s other portions of the delivery that may or may not be in place.
2930 COMMISSIONER MENZIES: Okay. I’m looking forward and you’re, as noted, cautious in terms of what is down the road in terms of developments. And that’s not inappropriate at all because the world is changing very quickly, without much warning from time to time. But there’s been general consensus in this process so far that IP Voice services, likely followed by Text-to-9-1-1, are probably the first -- the predominant elements of NG9-1-1 going -- that they will be the first things people will deal with with that.
2931 Assuming you agree with that -- and if you don’t, please let us know -- what do you see as being the next thing, OTT? Like, you referred to Facebook -- other developments or demands that you see?
2932 MR. SPELAY: So -- yeah, the IP platform, as it’s being developed, will provide the base that makes a lot of things capable, whether it be text, whether it be video, whether it be schematics, or any of those things. I think the biggest issue around any of those advanced services is a) whether PSAPs and public safety agencies are wanting that information and how much they want to push us to provide it.
2933 And I’m looking to the technical guys because I don’t ---
2934 MR. FOWLER: You know, I don’t want to get into a situation where we just build something that nobody’s going to want or make use of. So if we spend a lot of money to engage (inaudible) or make sure video is capable but then nobody -- the firefighter or police officer’s not able to us it, well, then what was the point, you know?
2935 COMMISSIONER MENZIES: Right, no, there’s no ---
2936 MR. FOWLER: Yeah, we don’t -- we’d like to have some (inaudible) direction, right?
2937 COMMISSIONER MENZIES: Yeah, there’s no point in building over capacity but you also don’t want to build a whole new system and then find out in a few years you got to build another new system -- a new network, rather, because of additional pressures.
2938 MR. FOWLER: No. But I think that’s one of the benefits of the IP base, as a base technology that’s being used in this new network, is that it can -- it’s, by nature, extensible ---
2939 COMMISSIONER MENZIES: Right.
2940 MR. FOWLER: --- which could mean I can extend this to other forms of media, connectivity, and stuff like -- much more easily than I could have, probably, obviously today.
2941 COMMISSIONER MENZIES: Right. Okay, well, anyway, all we were trying to do there in terms of trying to anticipate what sort of demands would happen.
2942 As things change, and as public’s expectations change of how they may communicate through 9-1-1, text, for instance -- and I’ll just go into text for a minute because the FCC is moving ahead in sort of an RTT direction in terms of that and this poses a bit of a dilemma for us, a bit of a chicken and egg situation.
2943 In terms of Text-to-9-1-1, should we be waiting until history takes its course with terms of SMS as people transition, as some anticipate, from SMS to OTT and RTT-type of communication as opposed to just the cell-phone text? Or should we be moving ahead with it now and building in room for that to evolve -- for Text-to-9-1-1 to evolve within those frameworks?
2944 To make it easier, is SMS on the way out and is it going to be replaced by OTT and RTT in the next few years?
2945 MR. MILES: I think, from our perspective, we see SMS as pretty steady today, so we still see a lot of devices that are still using it to send (inaudible) consumer products. So we feel that that’ll be around for a while.
2946 In the new network, or the next-generation network, RTT is very specific for Real-Time Text. There still are some facilities to send text messages on kind of the same path that the voice goes. So there are some interim steps there where you could invest to get that text happening.
2947 I think one of the main questions that we had about that was, “Is it actually appropriate to invest in texting when it is not real-time?” And so do you really want to have that -- if you’re going to have your investment, then you want to look at something that is real-time.
2948 So I think this is going to be a good question to ask once the NG9-1-1 specifications are set through the ESWG to say where exactly those texts fit.
2949 Today, it is considered a (inaudible) network. And so do you want to be spending money on (inaudible) networks?
2950 COMMISSIONER MENZIES: Right. Thanks, that is the question. In terms of -- and I guess somebody is going to have to come up with an answer eventually.
2951 MR. SPELAY: So ---
2952 COMMISSIONER MENZIES: Go ahead.
2953 MR. SPELAY: I guess what Mark is really saying is that SMS as it exists today and texting as it exists today is legacy. It’s -- we don’t know what the full new format of text and real time text is at this moment. The Text-to-9-1-1 or TEXT with 9-1-1 that we’ve implemented today is just kind of a clunky solution.
2954 We could go down the path of opening that up; we could do down the path of trying to clean that up to be more mainstream, but is it best to focus there or focus rather on the solutions that we know are going down the pipe in a couple of years?
2955 COMMISSIONER MENZIES: Yeah. As we get down those couple of years and these changes begin to take place -- even if they don’t take place in Saskatchewan, if they’re taking place in neighbouring provinces -- that creates issues for 9-1-1 operators as well.
2956 But obviously any time things change people need more information. Do you think somebody should be designated as being responsible for public education on these matters, for instance, text? Many PSAP operators would say, “Yes, please use text.” If you are bound and gagged and in the trunk of a car and that’s the only way you can communicate, or in the Calgary example of the young woman being on the train. But it is not the preferred method of communicating for many reasons.
2957 Do you think we should be designating or look at designating being responsible for public education on these changes, or do you have a different point of view?
2958 MR. SPELAY: That may be a very good fit or role with some type of national consultative group that is looking at potentially a transition period outside of the network build, so to speak, that we’re looking at through CISC ESWG. Or it could be an extension of the CISC ESWG activities if such a national group didn’t come forward.
2959 We could of course educate our customers through build and service, et cetera, but it would only be our customers. There’s a number of other providers that offer services within the provinces, whether they be alternate wireless providers, alternate Internet providers, even alternate VoIP providers. So it’s really -- you’d almost have to do it through a media blitz as well.
2960 I’m not sure if we’re the appropriate form for that to happen, or potentially a government agency or some other form would be better than coming from SaskTel.
2961 COMMISSIONER MENZIES: Okay, thanks.
2962 What is your experience with Text-to-9-1-1 for the deaf and hard of hearing so far? Has there been much usage of that or registration for that?
2963 MS. SAHLMUELLER: Sure, yeah, I can speak to that. We have just over 200 customers that have registered for it now, and we did actually have the first call towards the end of December. So there has been one call.
2964 COMMISSIONER MENZIES: Okay, thanks. And no issues? Everything, I mean ---
2965 MS. SAHLMUELLER: It went well. It was a medical call.
2966 COMMISSIONER MENZIES: Okay, thank you.
2967 What about the potential, what are your views on the potential for a national 9-1-1 App? See pros or cons for that, any safeguards that might be needed that you’d like to point out?
2968 MR. SPELAY: We’re definitely not App developers, we’re network providers, so we don’t have a lot of experience in developing Apps. Our biggest concerns with an App would be not only once it’s developed, it’s the ongoing maintenance of that App. It’s ensuring that it works on all devices that would be commonplace. So it works on the iPhone, it works on Android phones, it works on OS versions on all those phones, it works over Wi-Fi, it works over LTE, it works over broadband. There’s a lot of issues that could happen with an App like that that would need to be managed.
2969 It depends on what you want that App to do as well. Is it just to allow texting to a PSAP or is it that they could access your camera from a PSAP? It’s wide open on what you would want it to do, and you’d have to build it accordingly. I’m not sure who undertake the development of such an App or the ongoing support and maintenance of such an App. You’d probably need some type of national provider that would develop it and manage it throughout the country.
2970 COMMISSIONER MENZIES: Okay, thanks. What do you see as being the main privacy issues, new privacy issues that may come up with NG9-1-1, if any?
2971 MR. SPELAY: Once again, it depends on what the system is expected to deliver. If it’s expected to deliver like for like to today, there probably won’t be any new privacy aspects. If it’s expected to somehow tie medical records or potential access from stuff such as alarm systems in your home, et cetera, camera footage from your home, that opens up a whole aspect of privacy not only from our perspective but the perspective of the companies that may be providing those services.
2972 Security companies may need to change their privacy statements and contracts. The health boards may need to change their privacy to allow this. So it really once again depends on what’s coming over the system and what new functionalities would be opened up.
2973 COMMISSIONER MENZIES: Okay. Would you agree with Shaw and others than any retention of any documents should be left to the PSAPs, and that perhaps we could entrench that concept in policy by regulations that that’s where the responsibility for the storage of any documents lies is with the PSAP and not with the network provider?
2974 MR. SPELAY: Yes, we would agree with that position.
2975 COMMISSIONER MENZIES: Thank you.
2976 Do you think it will be necessary to add or amend any reporting and monitoring requirements like in terms of outages, for instance, going forward with NG9-1-1?
2977 MR. SPELAY: I think we have a good basis point today to start from, with service outages, etcetera. I’m not necessarily sure we’d need to add more unless there’s a need to add more, unless there’s a proven need to add more reporting. We think the current amount is enough.
2978 We tend to have a very resilient network today. We’re very proud of that we don’t need to do a lot of outage reporting. And we don’t anticipate that it would be needed in the future either.
2979 COMMISSIONER MENZIES: Okay. So would you be comfortable sharing usage statistics with -- and other information like that with PSAPs or the CRTC?
2980 MR. SPELAY: Usage statistics, as the number of calls to 9-1-1?
2981 COMMISSIONER MENZIES: Yes, that sort of thing -- number of texts, number of calls, source of calls, that sort of thing?
2982 MR. SPELAY: Yeah, we -- I believe we already do share that with our PSAPs.
2983 COMMISSIONER MENZIES: Right.
2984 MR. SPELAY: And we could share it with you if requested, yes.
2985 COMMISSIONER MENZIES: Okay. Do you think it would be -- and then I will turn you over to my colleagues, if they have any questions. Do you think it would be useful for us to be setting any targets going forward in terms of start times for -- start dates for NG9-1-1 for networks -- initial network architecture being in place, potential retirement dates for the current system? Would those dates be useful in helping people focus or not?
2986 MR. KURULIAK: I believe that we’re still of the opinion that the three to five-year timeframe is still applicable to implement and stand up that NG-9-1-1 infrastructure. So certainly if we want to talk in terms of a start date, you know, our position is it should fall within that three to five-year timeframe.
2987 In terms of establishing end dates, I'm not sure what is really an applicable end date. It’s going to, I guess, depend on the migration of current TDM technologies or E9-1-1 technologies into an NG9-1-1 infrastructure. And when that’s nearing completion, that could ultimately dictate when that date is going to be. But for us to put a hard stop on when we think that might be, I believe it’s a little premature right now to do that.
2988 MR. SPELAY: I also believe that it’s ultimately somewhat out of our hands in terms of we probably have a fairly good indication when our main three PSAPs for Sask9-1-1 would be ready, willing, and able to take everything.
2989 We have a lot of secondary PSAPs within the province that aren’t part of that, and we have a lot of first-responder agencies, et cetera, that are also there that aren’t part of that that would need to make the changes as well.
2990 It’s a question of how they would receive funding to make a change, especially if we’re forcing them to make a change. They may or may not push back on us.
2991 COMMISSIONER MENZIES: Okay. Those are my questions. Thanks very much for your intervention. My colleagues may have some more. And I note that the temperature got above zero today for the first time in a month in southern Saskatchewan so you may -- hopefully, you will be able to enjoy a little bit of the rest of the day. Thank you.
2992 MR. SPELAY: Thank you.
2993 THE CHAIRMAN: Thank you. Just a few questions, quick ones.
2994 Do you currently have any pilots or trials that might inform a transition to NG9-1-1?
2995 MR. SPELAY: No.
2996 THE CHAIRMAN: Are you planning any?
2997 MR. FOWLER: Nothing concrete at this time. I think we’re going to wait to see what comes out of the various working groups and then determine whether it makes sense to proceed through a trial or proof-of-concept kind of scenario once we determine what the end-state looks like a little more clearly.
2998 THE CHAIRMAN: If I understood you correctly, you said that you believe that the current NG9-1-1 network providers should continue to receive the cost of operating those networks ongoing while we set up new rates for the NG9-1-1. Is that what I understood to be your position?
2999 MR. SPELAY: Yes.
3000 THE CHAIRMAN: So if that’s -- what’s the incentive, in that sort of a two-stream funding model, for the legacy network operated by the ILECs to transition fully to NG9-1-1?
3001 MR. SPELAY: So we’re undertaking a capital plan currently that will see us retire our TDM-based network over the next number of years, probably fairly close -- without putting words into the mouths of our technology department -- fairly close to that 10-year timeframe. So it will naturally migrate to the IP network and ultimately NG9-1-1 on its own through this transition plan.
3002 Today, however, most of our traffic remains on the old legacy telephony systems. So to turn on NG9-1-1 today would require us -- and turn off legacy 9-1-1 would essentially require us to somehow translate the majority of our voice traffic from TDM to IP and invest a lot of money in gateways, et cetera, to do so, where that will just naturally occur over time.
3003 So our focus would rather be on getting the NG9-1-1 network built and working faster on retiring our legacy voice networks through that organic means rather than trying to do a bunch of translations to meet our 9-1-1 goals.
3004 THE CHAIRMAN: I understand that but there’s always ways of squeezing a little more lifeline on a legacy network. And what I’m suggesting is that if you can continue to have the revenue stream from the costs of the legacy NG -- legacy 9-1-1, there may be less incentive to move to the new-generation 9-1-1 service, which, arguably, is in the public interest.
3005 MR. SPELAY: Agreed.
3006 THE CHAIRMAN: So what’s the incentive for that not to ---
3007 MR. SPELAY: There’s other reasons ---
3008 THE CHAIRMAN: Yes.
3009 MR. SPELAY: There’s other reasons other than NG91-1-1 that we want to switch from legacy to IP in our network. Our goal is to do that as quickly and efficiently as possible.
3010 The -- I guess having legacy 9-1-1 fees or revenue coming in wouldn’t be an investment decision as to the speed at which we would switch those networks from legacy to IP.
3011 THE CHAIRMAN: Okay, thank you. I think legal may have one or two questions for you.
3012 MR. BOWLES: Yes, Mr. Chair.
3013 If I understood correctly from the conversation you were having with Vice-Chair Menzies, you expressed agreement with Shaw’s position that TSPs should not be made to host any additional data or information; is that correct?
3014 MR. SPELAY: Correct.
3015 MR. BOWLES: When I’m looking at paragraph 14 of the -- of your oral presentation today, you provide an example of service providers hosting medical records. Is there any inconsistency between those two positions?
3016 MR. KURULIAK: So I think it’s really meant -- our position is we could host the infrastructure that provides, you know, the storage of those medical records or whatever information that is, but really, we’re just the infrastructure owner; we’re not the application owner; we’re not the administrator of that data. We’re simply providing you a network element to store that on that is interconnected into the NG9-1-1 infrastructure would not be part and parcel of an ESInet, but it would be an ancillary interconnection device to provide additional information.
3017 MR. SPELAY: Correct. In that sense, you know, if E-Health wants a secure, robust, reliable, resilient area to store their medical records for 9-1-1 purposes, we have data centres in which they could store those.
3018 MR. BOWLES: So you may have partially answered my next question. You don’t foresee this information as being user inputted, or at least, not necessarily so?
3019 MR. SPELAY: I'm not sure we're in a position to necessarily comment on that. I know from dealing with the PSAP community and other health professionals, they're not big fans of user inputted data. It's not verifiable. If -- I think if a PSAP or other first responder wanted to know about medications or about potential health problems, they would want that information to come from a verified source such as a health authority or a health record that was created there, not a health record created by an end user.
3020 MR. BOWLES: And just one last question on this. If a TSP were to host additional information, do you foresee a need for any changes to existing privacy obligations or modifications to agreements between the 9-1-1 service providers and the PSAPs or the relevant local authorities, or are the existing obligations that the information is only transmitted and only to be used by those in receipt of it for the purposes of responding to the emergency that triggered the 9-1-1 communication? Are those sufficient?
3021 MR. SPELAY: Those would be sufficient in our minds as well. When -- but once again, when we speak of hosting those records, it's not that we would have access to those records or look at those records. We would essentially provide them server space in a data centre, that type of thing, that's within our ecosystem.
3022 MR. BOWLES: Okay, thank you. That's all.
3023 MR. SPELAY: Thank you.
3024 THE CHAIRMAN: Thank you very much. Those are all our questions, and that brings us to an end of today's intervenors, so we're adjourned until nine o'clock tomorrow morning.
3025 Donc, un ajournement de neuve heures demain matin.
--- Upon adjourning at 4:05 p.m.
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