Transcript, Hearing January 19, 2017
Location: Gatineau, Quebec
Date: January 19, 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 Thursday, January 19, 2017 at 9:01 a.m.
4153 THE SECRETARY: Please take your seats.
4154 THE CHAIRMAN: Order, please. À l’ordre, s’il vous plait.
4155 Madame la secrétaire.
4156 THE SECRETARY: We will now hear the presentation from Media Access Canada.
4157 Please introduce yourself and your colleagues, and you have 15 minutes.
4158 MR. TIBBS: Thank you. For the record, my name is Anthony Tibbs. I am Chair of the Board and Acting CEO for Media Access Canada.
4159 To my immediate right is Gary Birch, CEO of the Neil Squire Society and Content Expert Consulting with MAC in this proceeding. To Gary’s right is Carmela Hutchison, President of Disabled Women’s Network of Canada; and next to her is Haylea Ostafichuk, a consultant with Analysis and Research in Communications, assisting in these submissions.
4160 To my immediate left is Glenn Martin, Executive Director of Canadian Hard-of-Hearing Association; and to her left, Kim Kilpatrick from Canadian Council of the Blind.
4161 Commissioners, Commission staff and members of the audience, good morning.
4162 According to Statistics Canada, 3.8 million Canadians suffer from some form of disability that limits their capacity to participate in social and economic activities. Around half of that number, or approximately two million Canadians, experience severe or very severe disabilities.
4163 Having severe disabilities has a profound negative impact on employment opportunities and disposable income, and access to basic services that we all take for granted. This makes it challenging for many members of our community to access essential goods and services including emergency first responder services and emergency alert services.
4164 Media Access Canada and the Access 2020 coalition of stakeholders represents a variety of national disability organizations with the objective of achieving full accessibility of media and communications services by 2020.
4165 The coalition participants cross a diverse spectrum of Canadians with disabilities to include a voice for blind and low-vision, deaf and hard-of- hearing, mobility, cognitive, intellectual, and other forms of disability.
4166 Our partners include, among other organizations, the Disabled Women’s Network of Canada, Canadian Hard-of-Hearing Society, and Canadian Hard-of-Hearing Association and national organizations including March of Dimes, Easter Seals, the Alliance for Equality of Blind Canadians, and the Canadian Council of the Blind.
4168 THE SECRETARY: Sorry, please open your mic. Thank you.
4169 MS. HUTCHISON: Accessibility to 9-1-1 emergency services in Canada is critical to the health and safety of Canadians, and is an important part of ensuring that Canadians have access to a world-class communications systems. Indeed, many of the narratives of people with disabilities begin with a call to 911 as a result of an accident or medical emergency.
4170 The predisposition to the health and safety issues are increased for people with disabilities in part because of health and because of lack of access to social determinants of health, and in part because of the downloading of health services to communities without proper corresponding provision of community supports. The likelihood of calls to EMS is therefore increased coupled with the challenges of accessing communication systems inherently designed for people without disabilities and without consultation or field testing of the impact they have on those with disabilities.
4171 We share many of the same concerns as all Canadians in regards to the accessibility, reliability, interoperability, resiliency, redundancy, and security of the next-generation 9-1-1 system. As noted by the recent failure of the 9-1-1 system in the Ottawa Valley on December 20th, 2016, the migration to new technologies has created many new vulnerabilities that can affect the system in potentially life-threatening ways.
4172 As a community, we have concerns that the NG9-1-1 services will be implemented without appropriate consideration of how it affects people with disabilities if there is no appropriate regulatory framework.
4173 The resolution of issues for Canadians with disabilities, as they relate to 9-1-1 services, will often benefit more than one disability. In fact, like closed captioning, often these services will benefit those without disabilities. Therefore, while we have tried to provide highlights of the basic needs, these key and important services have utility for many other user groups.
4174 MR. BIRCH: There is a need to improve existing location-locating capabilities and the dissemination of information and distribution of Text with 9-1-1 updates to all consumers.
4175 Another example is real-time texting. The delay in current text-messaging based 9-1-1 services during regional emergencies is a known flaw. There is no guarantee that a text message will arrive in a timely manner. Sometimes the text message will arrive minutes after it is sent, based on the amount of traffic on a wireless network.
4176 People with cognitive impairments or disabilities are often an overlooked group of users but, in emergency situations, they are also one of the most vulnerable as they may not be able to accurately communicate the nature of their emergency and details of the situation to the emergency operators.
4177 For people with cognitive impairments and seniors, a symbol-based application that sends pre-determined messages would make it easier to deal with an emergency situation. A version of this type of application, though not specifically addressed to people with disabilities, has been launched by RapidSOS in the United States. Real-time video could then allow the operator to better assist the caller.
4178 For people with mobility impairments, just accessing and using a mobile phone has been a challenge. While, in principle, the CRTC directive of 2008-06-10 to make handsets accessible for people with moderate to severe mobility impairment is moving the industry in the direction of making mobile devices more accessible. As a community, we see this as a still-evolving area and there is still no consistent level of access that is available from particular handset providers or wireless service providers.
4179 The recent deferral-account process also shows that some wireless service providers are still not providing enough information to allow consumers to make the final choice of an appropriate phone.
4180 We commend the Commission on the recent directives in the basic services ruling in trying to move the process forward but note that more diligence might be necessary as the industry has been consistently slow to move to compliance.
4181 MS. MARTIN: If you are deaf or hard-of-Hearing in Canada, you must have a voice-plan contract with a provider in order to have a T9-1-1 call go through. Removal or clarification of voice-plan requirements to all ASL and LSQ users in Canada regards to Text with 9-1-1 is important. Overhaul or removal of the requirement for registration for Text with 9-1-1 is important to all Canadians. This should be a basic service for all Canadians and not a deaf and hard-of-hearing self-identifying requirement.
4182 There is a need for more reliable and real-time direct access to via text to 9-1-1 operators. Faster response time between 9-1-1 responders with deaf and hard-of-hearing consumers is critical to the safety of Canadians. Currently, T9-1-1 calls can bounce back and forth to a number of different points before the responders are actually sent out, which means a lot of critical time is lost.
4183 An improved GPS location system, as well as voice-to-real-time-text are just a few of the many improvements that would fundamentally improve access for blind and low-vision Canadians. Many vision-impaired users cannot adequately provide the information needed to direct emergency responders.
4184 It’s critical that access to any NG9-1-1 system not cost more for a Canadian with a disability than any other Canadian, for example, a deaf person having to purchase a voice plan in order to have text access. We note the Commission’s recent directive in the basic-services proceeding, Telecom Regulatory Policy CRTC 2016-496, that “directs all WSPs to offer mobile wireless service packages that meet the needs of Canadians with disabilities” as an important step.
4185 MS. KILPATRICK: We recognize the discussion and initiatives begin being worked on in the United States and in Europe with regards to accessibility and NG9-1-1 services.
4186 The Commission asked us to address specifically the NG9-1-1 regulatory framework being discussed in the United States. We recognize that even though there are similarities in the ecosystems, there are also distinct and important differences.
4187 There are similarities in that there is a fragmented nature to the regulatory and funding models divided between the levels of federal, state, and municipal governments and agencies. As such, there is no one agency or organization that had domain responsibility to ensure a uniform level of service is deployed in a timely manner.
4188 There are differences in the range and quality of services that exist between Canada and the United States. Speech-to-speech relay services, which allow people who cannot speak clearly to communicate to others, do not exist in Canada. Video relay services that allow sign language users to communicate with non-sign language speakers is still relatively new in Canada.
4189 Video relay services are provided in the United States 24 hours a day and 7 days per week. Canada currently only has video relay services 76 hours per week with hours of operation differing in some regions. There is no support for TTY services on mobile devices.
4190 There are also differences in that in Canada there is not yet federal accessibility legislation to ensure the accessibility of services. There is no regulatory framework in order to explicitly enforce the accessibility legislation and there is no the strong legislative voices from the disability community that is advocating for disability-friendly legislation and regulation.
4191 The FCC process created the Emergency Access Advisory Committee, EAAC, to help inform the rule-making process for NG9-1-1. The committee was made up of representatives from the disability community and the wireless industry.
4192 In principle, Access 2020 supports many of the recommendations in the EAAC report such as ensuring individuals can use handsets to access NG9-1-1 without the need for additional special devices; direct access to PSAP staff so that relay services are not required if the caller chooses not to use them; the principle that the same degree of access and quality of service should exist for people with disabilities as for people with no disabilities; no change to NG9-1-1 technology and procedures without considering the impact on people with disabilities.
4193 We feel a similar committee to the EAAC is required in Canada in order to ensure the needs of people with disabilities are included. The EAAC had a fixed mandate. We feel an ongoing engagement with the disability community through the transition process is important. Compatibility with international jurisdictions is important so that roaming is possible. But as noted earlier, Canadian realities should be recognized, pointing to Canadian solutions as opposed to a blind adoption of another country’s frameworks.
4194 MR. TIBBS: We note that there are differences in the scope of the regulatory powers of the FCC and other related government departments and agencies. The CRTC does not have an explicit, broad mandate to deal with accessibility-related issues, though we recognize the important efforts the CRTC has made to address these issues under its existing mandate.
4195 One of the submissions to the FCC process noted that some parts of the new next-gen 9-1-1 system fell under the mandate of the Department of Justice and the Americans with Disabilities Act, and the authority of the Department of Justice superseded the regional authorities in regards to NG9-1-1. There is no federal accessibility Act to ensure accessibility is provided in every public service.
4196 We note that federal accessibility legislation is being drafted by the current government, but whether it will have the scope and reach of the Americans with Disabilities Act is still unclear. There are no strong enforcement tools to ensure accessibility as there are in the United States. The FCC and the Department of Justice have the ability to levy financial penalties to ensure timely compliance.
4197 We also note that the FCC asked Congress for a greater ability to oversee the way emergency services are administered by the various state and municipal organizations, and how additional funding is supplied to these levels of government in order to ensure a more uniform transition.
4198 In preparation for these hearings, MAC commissioned a study to address a question put forward by the Commission about the usage of TTY services. Haylea Ostafichuk, our analyst, can speak to the specifics of the study, but the key findings were that 83.5 percent of deaf and hard of hearing Canadians claimed that they never use TTY, with the remaining 16.5 percent claiming they only use it 1 to 2 times a month; 100 percent of respondents said that email and text are the most commonly used form of communication technology in their deaf and hard of hearing communities.
4199 When contacting 9-1-1 services, 91.7 percent claimed that they prefer to use text while 8.3 percent prefer to use TTY; 25 percent of respondents claimed that when using text to contact emergency services, respondents were slow to reply. The remaining respondents said that they “could not say” because they have not had to contact emergency services.
4200 Not in our written presentation because this information came to me only yesterday, the Canadian Association of the Deaf has also been looking at the use of TTY services more generally. And a survey commissioned between December and January of 2016 backed up these findings. Nearly 70 percent of the respondents stated that they never used TTY relay service and only 6.5 percent said they use it 5 or more times per month.
4201 Similarly, 57 percent never use IP relay service; 14 percent use IP more than 5 times per month; while 44 percent never use video relay service at all.
4202 It is noticeable then that those who migrate away from TTY relay services toward IP solutions and video relay services tend to become more frequent users of the relay services than they were when they were using TTY.
4203 The Commission had asked when TTY relay should be phased out. The FCC in the United States has announced 2021 as the date they will cease supporting it as it will be replaced with real-time text. This may be a pessimistic timeframe, but many organizations, including CAD, echo and suggest that the CRTC set 2021 as a target year, subject to ongoing monitoring to determine the extent to which TTY is actually being used to access 9-1-1 services.
4204 In order to ensure the feasibility of that date, at least three things have to happen. One is that -- consistent with the Commission’s directive in December -- plans needs to be put in place to allow access to text TTY without necessarily requiring additional voice plans. A concerted effort needs to be made to improve deaf/blind people’s access to digital relay services; and video relay services in Canada needs to improve in all aspects as quickly as possible.
4205 Its launch in September of 2016 was a momentous event, but it is still beset with issues that will need to be improved before it can be counted on for this kind of access.
4206 With that, we thank the Commission for hearing us today and we're ready and able to answer any questions you may have.
4207 THE CHAIRMAN: Thank you very much. Just to remind you of who's on the Panel here today, so obviously this is Jean-Pierre Blais, the Chairperson of the Commission. To my right is the Vice-Chair of Telecommunications. As well, we have on the panel Commissioner Vennard, and to my left, Commissioner Simpson and Commissioner MacDonald.
4208 So Commissioner Simpson will start us off.
4209 COMMISSIONER SIMPSON: Good morning, Mr. Tibbs and Company. It's a pleasure to see so many familiar faces.
4210 I'm going to start off with some general questions that will, I think, guide the conversation later on by allowing you to provide some of your general views, and toward the end of my questions, I'll be getting into questions that may sound like we're taking an intellectual understanding step backward, but it's specifically for the purpose of asking questions to get your very clear answers on the record, which is what this whole procedure is about.
4211 I want to start by asking a question that I've been dying to ask over the years, but the forum really hasn’t been right. And it goes along the lines of, in order for an individual with moderate to profound disability and how it impacts their individual lives, do they have to make equally hard decisions at times regarding where they live in order to improve how they live? Do they have to be -- do they have to make esthetic sacrifices about where they'd like to live in order to be closer to services that provide them with the day-to-day? Is this a reality?
4212 MR. TIBBS: I suspect other people may have comments on this, but as a general rule, I expect that that is a very real consideration for a lot of people, particularly if they need attendant care, particularly if they need regular or ongoing emergency medical care. Living two hours out of a major centre may be a very difficult situation.
4213 But even in lesser situations, the availability of services such as sign language interpreters and such in smaller towns or centres could be a problem too. And so it's not necessarily just the moderate to severe people who end up needing to make decisions about where they will live and which province they will live in, for that matter, in order to access even more basic services.
4214 MS. HUTCHISON: The answer is yes, in the short. And in the longer, your disability very much dictates where you live, and if you have more than one condition, the decisions become more fragmented and even harder. And it becomes more and more complex, because there's competing rules everywhere.
4215 So if you have a particular disability, your mobility device is easier to obtain in one province. If you have autism, your services are easier to obtain in another province. If you have a hearing impairment, your services are better in another province. So you also sacrifice if you have autism, a hearing disability, and a mobility disability. You're going to be compromised.
4216 If you study -- one person didn’t realize that they would -- if they accepted a program for academic study in another province that they would lose their attendant services and almost have their mobility device taken right from under them as they migrated to that province. So there are many complications like that as you go from province to province and your services are impacted in that sort of thing.
4217 Those of us who have physical disabilities need to sometimes be out of the city because we need to get away from architectural controls and that raises complications for availability of health care resources and attendant care. So that's the longer answer to that.
4218 COMMISSIONER SIMPSON: So it is a -- not necessarily an acceptable reality; it's an unacceptable reality.
4219 But trying to explain why I'm asking, I'm starting this process this way, is that when we went through an examination of the whole broadband system in Canada, we're faced with a lot of the same problems, where accessibility to broadband is an expectation that everyone should have it, but it's a question of the degrees of broadband's ability to get to that individual. And it's something that we struggle with, technologically.
4220 And I think we're starting to back into the same kind of a scenario when we talk to the PSAPs. We're hearing that one of the cautionary issues that's emerging is that not all PSAPs might be able to operate at a level of standard that can be applied universally. And it's something that plagues my thoughts, because I think we have to -- that if we were to try and exert standards, we might be weakening the reliability of the system in the process. And so that's kind of where that was coming from.
4221 Mr. Birch?
4222 MR. BIRCH: Following up on that comment, how do I best -- I think I'm hopeful of -- I don’t even know if I'm -- I am hopeful for sure, but I'm just not sure what can actually be accomplished with the new national accessibility legislation. But the striking -- doing the research from the United States and how, thorough the ADA in particular, the Department of Justice had an ability to have that oversight and where needed, get involved so that to minimize that disparage -- because, you know, as we go into NG9-1-1, I think it's going to be amplified.
4223 And so some -- there has -- so there has to be some mechanism. So hopefully, that act can somehow possibly, if you'll let me just put it out there, change the mandate of the CRTC, such that you will have the tools you need so that -- not necessarily get rid of those institutions, but be able to oversee them and make sure that they're all providing a level playing field.
4224 COMMISSIONER SIMPSON: I'm glad you brought it up, because that was going to be my next question.
4225 Mr. Tibbs, did you want to say something first?
4226 MR. TIBBS: I was just going to say that in some ways, there's an opportunity here. As new technologies are developed and deployed, it may well be that some of those inconsistencies in terms of what PSAPs are capable of processing and handling may be reduced as everybody moves towards whatever the next new common platform will be.
4227 Right now, it's really a hodgepodge because every telephone company over the years has implemented 9-1-1 in different ways. There are some standards, but I know from my other life that the information that gets communicated through the wires to these PSAPs can be very different, depending on where the call originated from. And yes, there are varying levels of capability, but now might be the opportunity to try to level that a bit as we develop the next generation.
4228 COMMISSIONER SIMPSON: I hear you. Thank you very much for that.
4229 With respect to the disability legislation, I have not had the benefit of seeing the draft, of course, but I can only assume that the devil will always be in the details because if it is adopted, I should imagine -- and I think you're trying to point us in this direction -- that it would be full of good intentions, but it's the application of said legislation that's going to really provide the benefits. And that application, of course, is where you're saying that the Commission, perhaps, has to have more regulatory or legislative ability to be able to enact or enable that legislation. Is that what you're saying between the lines?
4230 MR. TIBBS: I was just going to say -- so there is no draft of the legislation yet.
4231 COMMISSIONER SIMPSON: Okay. That’s why I hadn’t seen it, I guess.
4232 MR. TIBBS: Yeah, right now they’re doing a number of consultation sessions. They’ve had a number of public consultation sessions. A number of organizations have received funding to continue that process to inform what will go into that legislation.
4233 COMMISSIONER SIMPSON: Okay.
4234 MR. TIBBS: One of the submissions that I know has been made repeatedly, and we’ll see what they end up doing with it, is that aside from implementing that legislation, there are a number of other existing acts that need to be amended to provide other entities, including the CRTC, with a greater mandate and ability to address these accessibility issues.
4235 So it’s several years away from what we’re actually going to see out of this process. But at this point all we can do is be hopeful that between that legislation and other changes they may make in the process, some of these wish-list items that have been very difficult to accomplish on their own might be part of that bigger process.
4236 COMMISSIONER SIMPSON: Yes, ma’am?
4237 MS. HUTCHISON: And I just want to be more optimistic and forward-thinking because we are embarking in our Canadian journey, as we said in the brief, on our 150th anniversary as a country.
4238 And first off -- I’m going to quote a little bit of Star Trek and talk about the fact that a thing is only impossible until it is not. That’s the first thing. Because we’re talking at the CRTC about all the things in Star Trek, about communication, about electronics, about space-age kind of things. So that’s the first thing. We’ve got to hold that vision. And that’s important.
4239 And we want to think about future and we want to think about optimism because we don’t want to get into the part of this where business people, when they say, “Oh, we just can’t do it. It’s not cost-effective. It’s impossible.” A thing is only impossible until it is not.
4240 And secondly, Minister Qualtrough in the opening address -- because I’m on the executive of the Council of Canadians Disabilities; I’m President of Disabled Women’s Network of Canada; and we are very much part of the leadership that is shaping these consultations.
4241 And in my addresses in the arenas, people with disabilities are also a market, 3.8 million people. We’re a significant market. We are people whose needs don’t change. We don’t boom and bust. Our needs are the same today as they are tomorrow, and we’re not affected by energy prices. Our needs are the same.
4242 And as age increases, our needs are similar to those of aging populations. So it’s an increasing market. And we are actually a market driver.
4243 So having said this, it is important to look at us that way as well. And we are a business. We’re a market and industry and it’s important to see us that way as well and to stop always seeing us in the negative. We are a market and we have dollars. I am a taxpayer too. I pay taxes. And that is very, very important.
4244 It’s also important, when you look at different statistics, that many, many people with disabilities actually also still work and pay taxes and contribute to this economy -- and to stop characterizing us as people who don’t. So those are important things as well to consider when you’re considering all these economic factors, and to start characterizing us in proper ways when you characterize us. Because it’s important to consider those things and to start removing those attitudinal barriers because it’s important to see us in those ways in the next 150 years and to get to those points.
4245 Because one of the things that also happens about those choices that you talked about in your earlier question, is that in order to even be able to live there’s a greater diaspora in the last few years of people going into rural areas and more remote areas in order to even be able to live and to be able to live at a way we can afford, to be able to build that house that’s accessible. Because the architectural controls are too restrictive in urban areas so people have to move to rural areas that are just outside of greater metropolitan areas. So those things are happening and it is going to be more of a challenge.
4246 Yet, Fort Simpson, which is in Northwest Territories, is the most accessible city. If they can do it through their bylaws and legislation, every place in this country can do it. It’s just the will to do it. So it can be done. And I want to make an inspiration here that it can be done.
4247 And having said that, I think it’s very important to close with a quote from Minister Qualtrough, who began the first consultation in Saskatoon with stakeholders, who said that:
4248 “Lack of choice for people with disabilities is bad for business and it’s bad for people with disabilities.”
4249 Thank you.
4250 COMMISSIONER SIMPSON: Thank you.
4251 MS. KILPATRICK: Can I just make a comment too?
4252 COMMISSIONER SIMPSON: Yes.
4253 MS. KILPATRICK: Some of the things that would make things more accessible -- and we don’t really know what they are as technology has changed so quickly and so much. When we think about the technologies we’re using now that are different from what we were using even three or four years ago, those things can benefit a far wider community if you think about the automatic door that will open that were installed for people that use wheelchairs but almost everybody uses those now.
4254 So some of the technologies are -- even I was thinking about the symbols, when we were talking about in the U.S., that someone can’t communicate, what it is they need to say. There could be a picture. Now, for me that wouldn’t work because I’m totally blind, but provided you had a lot of different systems. But say there was a picture and say you were really scared and you couldn’t get your words out. You could also use that.
4255 So I feel like a lot of the things that will come in, if we look at them in a broader framework, who could benefit from this? New Canadians or people with disabilities, someone who is just frightened and can’t really communicate or in shock. You know, I think that people think about accessibility as complicated and only for a certain small group. And that group is really important and needs to be served, but I really keep looking back at it to say the accessibility of things helps everybody in this society.
4256 And also I just really want to reiterate getting consultations from people with disabilities as different systems come in because right from the beginning we help and assist. We don’t want to sit back and just complain about it. I will help and assist you to see how accessible they are so that open communication and those types of committees, ongoing committees -- to make sure that we help each other to make things accessible and that accessibility benefits everybody, not just the disability community.
4257 COMMISSIONER SIMPSON: Thank you. I think to your point, this is something that’s been recognized by the software development industry. I was looking at the RapidSOS initiatives that is going on in the United States and they very much seem to recognize that where they will gain traction is technology that, for example, takes voice to text as a translation tool or text to voice. And the benefit is obvious to the disability community, but the market for it is going to be in handling communications while somebody’s driving, for example. So there’s your point.
4258 We get that. And I certainly hope that you don’t think that when you say “you” that the “you” is universal and not necessarily the Commission, because I think we’re marching toward what we all want. But it takes time and enabling legislation to get there.
4259 And frankly, a hearing isn’t complete, as far as I’m concerned, until somebody quotes the inspiration of Gene Roddenberry.
4260 But if I may, I’d like to get back -- because we’re running out the clock here and I’d like to get back to a few things that I really think are key to this appearance this morning.
4261 With respect to the legislation, I want to ask one more question. Are you aware of whether or not the working groups that are inputting and informing government are talking about funding that goes along with the creation of legislation? Or is that going to be one of those things that’s a laggard again, that everybody agrees what has to be done but nobody can afford it?
4262 MS. MARTIN: I’m Glen Martin; I’m the ED for the Canadian Hard of Hearing Association.
4263 COMMISSIONER SIMPSON: Yes.
4264 MS. MARTIN: So our association was one of the groups that was awarded the project.
4265 COMMISSIONER SIMPSON: Right.
4266 MS. MARTIN: We are focusing our consultations on certain themes that we submitted in our proposal but we have been told by the Office of Disability Issues that they are looking for recommendations. So that -- if it’s a specific recommendation that government is looking for, we can certainly channel the discussions around that.
4267 COMMISSIONER SIMPSON: Thank you. The question is -- was raised because, you know, we’ve been hearing about the other end of the -- again, the devil is always in the detail and the PSAPs are saying, “We would like to be able to everything but we have to go in steps because of funding, and also because of incorporation of new technologies, making sure it works before we can adopt it.”
4268 So I’d like to go from that statement into one question that has to do with inputting to this process. We’re trying to find the key principles that have to be baked into regulation with respect to how NG9-1-1 is going to be designed and implemented. And are you satisfied that the various groups that are inputting to the working group -- you know, the emergency services working group -- have sufficient inputs from the groups that are involved that coming out of the other end of it will be sufficient guidelines and recommendations for incorporation of the needs for accessibility?
4269 And also, is your group working with this emergency service working group now; and if not, why not?
4270 MS. MARTIN: I think that the consultations so far -- we’re just getting into the process -- they’re very -- they’re vague. We’ve been -- again, we’ve been directed to try to channel it to more specific recommendations. The federal consultations have even been more vague because they’ve received feedback on provincially-related issues and we’re trying to now focus more just on federal-related issues.
4271 So -- and the idea is to have individuals with certain disabilities talk to us about the issues are impacting their lives that could be improved with legislation.
4272 So we’re not specifically ---
4273 COMMISSIONER SIMPSON: But you’re still talking about the legislation that the federal government is working on. I’m talking about the principles and guidelines that would go into what we’re doing.
4274 MR. BIRCH: Commissioner, you mentioned a working group, sorry, the ---
4275 COMMISSIONER SIMPSON: Yeah.
4276 MR. BIRCH: --- emergency ---
4277 COMMISSIONER SIMPSON: Yeah, emergency services working group. It’s a CISC of sorts that is ongoing.
4278 MR. BIRCH: Okay, speaking for myself right now, because I -- I'm not aware of our organization, or any other organization, that’s had sort of and ongoing dialogue of -- I wasn’t even -- to be honest, I don’t think -- if I am aware, I’ve forgotten that I was aware of that group.
4279 So I think the short answer is I don’t think there’s been enough input, if any, and you saw in our opening statements that, you know, like the FCC had, there needs to be a specific committee that’s overseeing this from a disability lens point of view. In fact, we see an even longer mandate for that committee to make sure it’s in place throughout the transition.
4280 COMMISSIONER SIMPSON: And the one that I’m ---
4281 MR. BIRCH: (Inaudible).
4282 COMMISSIONER SIMPSON: The one group that I'm aware of right now that’s working with the group is the acronym, the DHSSI group is working with this working group. But it’s something that I think you should ---
4283 MR. BIRCH: Yeah, we should look into that.
4284 COMMISSIONER SIMPSON: --- get your head around.
4285 MS. HUTCHISON: And actually, could you say the name of that group more loudly, please?
4286 COMMISSIONER SIMPSON: I’m sorry?
4287 MS. HUTCHISON: The name of that group more loudly, please?
4288 COMMISSIONER SIMPSON: Okay, I need my acronym -- DHSSI.
4289 MR. BIRCH: Emergency, the emergency services ---
4290 COMMISSIONER SIMPSON: The emergency working group -- the emergency services working group is what you’re asking for information on. We can provide that to you.
4291 MS. HUTCHISON: Please, because obviously there needs to be awareness all around.
4292 COMMISSIONER SIMPSON: Absolutely.
4293 MR. BIRCH: Yeah, we definitely need, I think ---
4294 MS. HUTCHISON: Because we really need to have ---
4295 COMMISSIONER SIMPSON: Yeah, I suspected that was the case.
4296 MS. HUTCHISON: --- greater consultation around that, for sure.
4297 COMMISSIONER SIMPSON: Right.
4298 MS. HUTCHISON: That’s one of the biggest, you know, goals that we have coming into this is ongoing consultation and linkage around that. That’s important.
4299 And I think one of the other things, as well, is on hearing that the Commission needs a greater feedback into the federal legislation process as well.
4300 MR. CHAIRMAN: Well, we are part of that so you can rest assured that we are consulted and are part of the consultations.
4301 COMMISSIONER SIMPSON: The answer to that question was above my pay grade so that’s why this guy’s here.
4302 Mr. Birch, it’s great having Neil Squire here. You know, we’ve got a pretty good understanding from our working relationship with you in past so -- I want to unpack, for everyone’s understanding, something that I think may be an issue that’s more important than we presently understand, and it has to do with RCS.
4303 Now, RCS is a format that -- for text that is -- it’s a telecom protocol and other text applications sit on top of it, like RTT, and so on. And I was wondering if you were familiar with the RCS format?
4304 MR. BIRCH: I’m sorry, Commission, I am not. But ---
4305 COMMISSIONER SIMPSON: RCA, I should say.
4306 MR. BIRCH: Sorry, RC ---
4307 COMMISSIONER SIMPSON: Yeah, RCS is -- or sorry, it’s Rich Communications Services and it’s described to me as a suite of communication services that are offered on most modern wireless devices. And real-time text is one of the communication services that rides on top of it, or is supported by RCS.
4308 And the reason why I’m bringing this up is that we’re getting a lot of input that, as we migrate to next-generation 9-1-1, voice be the primary -- what does Gene Roddenberry call it, “the prime mission” or the “directive” -- “the prime directive”.
4309 MS. HUTCHISON: Yeah, “the prime directive”.
4310 COMMISSIONER SIMPSON: Thank you -- because it’s a known format -- voice is a known format, it’s understood and works best with PSAPs and the current 9-1-1 regime and that text should trail after a successful migration of voice onto IP.
4311 So I’m wondering aloud to you, with a technology background, whether the difficulty is not so much the migration of real-time texting but the protocol that RTT sits on top of, which is RCS, and whether that is the obstacle to immediate integration. And I’m led to believe, or I’m led to understand, that it’s because not all phones would be compatible or equipped to handle RCS protocols that RTT would be the beneficiary of.
4312 So that whole big packet of information is something I just sort of wanted to throw out there ---
4313 MR. BIRCH: Okay.
4314 COMMISSIONER SIMPSON: --- and ask if you could ---
4315 MR. BIRCH: Yes.
4316 COMMISSIONER SIMPSON: --- opine on it, possibly as a written undertaking, coming back to us for January 24th. I know I’ve just given you a bunch of homework.
4317 MR. BIRCH: Yeah. We’ll do our best. My colleague couldn’t be here today.
4319 COMMISSIONER SIMPSON: Yeah.
4320 MR. BIRCH: Much more versed in the nitty-gritty technical details. This is probably something he knows about already. But we will drill down and ---
4321 COMMISSIONER SIMPSON: Because I have a sneaking suspicion ---
4322 MR. BIRCH: --- do what we can in that turnaround time. Yes?
4323 COMMISSIONER SIMPSON: I have a sneaking suspicion that, you know, as we talk about NG9-1-1, that it’s like going to a new computer system in a business and we all want to use an application immediately when we get the new computer but, unfortunately, the computer doesn’t speak the code that the present application’s written on.
4324 MR. BIRCH: Yeah, I can’t speak to this particular case but we see that often in some solutions for accessibility where they’re available on some phones but not on others so I wouldn’t be surprised if this was a similar scenario.
4325 COMMISSIONER SIMPSON: Thank you. Also, you brought up something I just had a big red circle around in the oral presentation this morning about known flaws with texting right now would incorporate delays and other things. Could you just open that up a bit for me please?
4326 MR. BIRCH: Again, I have to rely on my colleague. I think you know him, Harry Lew. He has done the research on this. It's been well-documented that, especially in an emergency situation -- so I guess when the traffic's heavy -- that current texting messages can be delayed significantly, you know, if the traffic's heavy. And I think there's -- we can look into that as well. But he would not have put it in there if he had not had certain backup for it.
4327 COMMISSIONER SIMPSON: Thank you.
4328 MR. BIRCH: I've heard it before, that that's an issue with current texting.
4329 MR. TIBBS: And my understanding is there are two issues. One is that on a congested network there can be delays of up to several minutes for messages to get through, and there's no guarantee that it will arrive at all and no feedback if it didn’t, necessarily.
4330 And the second issue is partly an implementation issue in that because there are other parties involved in transitioning that text information to the PSAPs, sometimes it has to go through several layers before it gets to where it actually needs to go. We can probably provide more specifics on that, but I gather those are the primary issues at present.
4331 COMMISSIONER SIMPSON: Thank you.
4332 Yes, ma'am?
4333 MS. HUTCHISON: I know that even where I live, sometimes a text just -- and this isn't a 9-1-1 thing -- but I know that just because I live in a rural area, I know that a text sometimes has taken up to 24 hours just to get from me to someone else. So if that goes weirdly in a 9-1-1 setting, I can't imagine.
4334 And just in my own learning about the PSAP issue, it's a wonder anything gets anywhere. I was amazed that that -- that it was multi-layered, and I was surprised that CRTC actually had, you know, even involvement in 9-1-1. So it was quite surprising.
4335 I have a question as well about the whole call trace. There's a feature that happens with landlines, and I don't know if the personal anecdotes I submitted got to you as part of our submission. And that's a bit of a cross question. Did they? Okay.
4336 So there's a feature in landlines called star 57, and I don't know if it's applicable in cell phone technology or not. And so when you press star 57, you can actually have a call trace that comes on a call, that gets submitted and it goes to the police department.
4337 And it actually saved the life of somebody that had called my phone, and I was in a support group. I did not know the last name of the person or their phone number or their anything. And their therapist and the support group leader wasn’t at home. This person had taken a lethal overdose and she happened to know my phone number.
4338 So she phones me and said, "Nobody's home. I just wanted a human voice before I check out." And she had taken a lethal overdose and she hung up.
4339 So I was able to activate call trace successfully and EMS was dispatched. They saved her life and they said had I not done what I had done, she would not have lived.
4340 So when I went to a different support group, I told everybody about the star 57 feature. And one of my friends was like, "Oh, okay. Why am I listening to this?" Somebody drunk dialled, and she came home from the movies. So she activated call trace and this guy was in a hotel. She saved his life.
4341 So what I'm wondering is, is this technology now available on cell phones, Voice Over Internet Protocols; is this still something that's even usable? Because this happened to me, you know, back in the mid-nineties.
4342 COMMISSIONER SIMPSON: Okay.
4343 MS. HUTCHISON: But I had realized that, you know, I know that it's still available on landlines, but it star 57 something that can be used today on cell phones?
4344 COMMISSIONER SIMPSON: I’m aware of the landline application of it. I've actually used it when I was in broadcasting and we would get calls to the radio station and you wanted to -- and it was a facility. I don't know, but I'm sure staff will do some digging for you and can get back to you on that, because it is useful.
4345 But on the whole issue of communications between all our groups, one of the things that I wanted to circle back on -- and you’ve sort of given me a door to open -- that I can open here -- and it goes back to what we were talking about earlier, your -- a lack of awareness of the emergency services working group.
4346 You had indicated that the awareness of this group was low to none, and I guess my question to you is, what would be your recommendation for how we could solicit more input to the working group from all interested parties concerned with disabilities, not just your own? Is this -- should the working group be taking an initiative to try and reach out and make their presence known to all groups, or ---
4347 MS. HUTCHISON: Yes.
4348 COMMISSIONER SIMPSON: --- have we already done that by this hearing?
4349 MS. HUTCHISON: Awareness is always a challenge, but I think greater outreach ---
4350 COMMISSIONER SIMPSON: Yeah.
4351 MS. HUTCHISON: --- and I think also, like, publication of the mandate of the group on your website, certainly communicating to the Council of Canadians of Disabilities to Media Access Canada. Like, we just -- it's -- awareness is an issue for everybody. It's an awareness issue for our organization, for Media Access Canada, for Council of Canadians With Disabilities, for everybody. We're always trying to make, you know -- but put it on your website too and get it to our organizations. We'll fan it out. But for sure.
4352 COMMISSIONER SIMPSON: So thank you.
4353 MR. TIBBS: And ---
4354 COMMISSIONER SIMPSON: So I just have two more -- oh, sorry, Mr. Tibbs.
4355 MR. TIBBS: I was just going to say, you know, in our submission, we had recommended the creation of an emergency access advisory committee specifically to collect that kind of feedback and pass it on. It may be that that committee needs to exist as part of or to inform the emergency services working group.
4356 MS. HUTCHISON: Yes.
4357 MR. TIBBS: I can say for myself -- I don't know about anybody else -- no, we weren't aware of the existence of this group. That might be the channel for it go through, and certainly we'll follow up with that and ---
4358 COMMISSIONER SIMPSON: That type of group that was created by or for or with the FCC in the United States, is that group inputting directly to the FCC, or is it -- do you have any idea what their connection is?
4359 MR. BIRCH: Yeah, we do. We did a fair bit of research, some of which I don’t have off the top of my head or in front of me, but yeah, they developed a number of reports. We summarized their key recommendations and I believe that was directly to the FCC.
4360 COMMISSIONER SIMPSON: Yeah.
4361 MR. BIRCH: Interestingly, their mandate is over, I believe, where it would have made sense, just from us studying it, to keep it in place until they finished the transition. But it was a -- as we understand it, certainly, stakeholders from the various disability groups but it also included stakeholders from the telecommunication industries as well.
4362 COMMISSIONER SIMPSON: Thank you. Three more questions. I'm sort of -- I'm not -- we can take some more time if we need, but I think I only have three more to really touch on.
4363 Going back to your comments on cognitive impairment, do you have any information that you could submit that perhaps is what's anecdotal more research-based that would give us something to chew on that you could submit as an undertaking? Any research or anything that -- else that you could share with us?
4364 MR. BIRCH: Yeah, normally, it's an understudied area.
4365 COMMISSIONER SIMPSON: Yeah.
4366 MR. BIRCH: We might have more that we could supply. I'd have to look through that.
4367 COMMISSIONER SIMPSON: Anything would help, Mr. Birch.
4368 MS. HUTCHISON: And also, I think that would could approach colleagues for People First of Canada.
4369 COMMISSIONER SIMPSON: Great. And on the same subject, the research that was done on TTY, has that already been part of your submission to this hearing already? Okay, so we got that. Great.
4370 MS. HUTCHISON: I also would like to say one other thing too. There's the -- one thing that there's a provision within the whole infrastructure that allows people whose -- when their cell phone is not active that you can still access 9-1-1. And I had the experience once to be financially embarrassed and have the need to access 9-1-1, and that is a very good thing to be able to do. And so I just would like to say that if that's something that can be continued, that should be continued.
4371 COMMISSIONER SIMPSON: Thank you. On TTY, what you’ve given us today is very consistent with what we’ve been hearing in terms of the anecdotal information we’ve gotten from the PSAPs, that it’s definitely a technology that is in its sunset.
4372 Is there a need, and if so what would it look like, in terms of putting a piece of regulation in place or a recommendation for it, an endpoint to TTY? Because right now it’s still being supported by PSAPs but it’s not being used. So if there was a starting point of day 1 in a 10-year evolution of next-generation, when do you think we could look at officially ending TTY? At the time of introduction of real-time text or before that or let it go on in perpetuity? What’s your input there?
4373 MR. TIBBS: So the information that we have is consistent that TTY is not being commonly used; it’s being used significantly less than it may have been in the past. There are still certain groups who do rely on it. Certainly the significantly elderly population, that may be all that they’re used to. That may be all that technology they can manage to use. A smartphone and the like may be beyond their use ability.
4374 The other population that needs to be considered are the deaf/blind who may be accessing it through Braille. And there aren’t a whole lot of alternatives at the moment that have the same type of reliability.
4375 In the United States they’ve set 2021 as a sunset date for that and that’s what they’re working towards. But we would not want to remove the ability to use this until we’re sure that an alternative is available and usable by most people.
4376 Now, one of the challenges from our perspective is that we don’t know how much TTY relay is being used definitively and we don’t know how many calls via TTY are going to PSAPs in the first place. I suspect that the wireless providers and the telecom providers probably have that information and I understand they may very well submit it as confidential information. But we don’t know whether there’s 1 call a year or 500 calls a year that are currently using that service.
4377 So adopting an end date of 2021, which some organizations have suggested may be appropriate, is a possibility. But that needs to be done with ongoing monitoring of, if we can determine it, the actual use to determine whether or not removing that will actually cause significant hardship or not. It seems “not” from the statistics we’re getting, but the PSAPs, for example, may be able to provide very accurate numbers for how many calls they’re actually getting via that service and that might be the benchmark to use to determine when it can be rolled out.
4378 COMMISSIONER SIMPSON: Yeah, we’re hearing “not” a lot. I think E-Comm the other day said they got one call in the year. But that is not statistical; that’s anecdotal. But thank you on that.
4379 The last question I have for you, and it’s really a for-the-record question, it was -- the specific question was to do with the general nature of the telecoms. The providers of 9-1-1 as a network operator and the PSAPs were saying, “Let’s go voice first, text later.” And I want your position on the record.
4380 But given that we’ve heard this morning that there may be technological issues regarding RCS or even, as you said, some fundamental flaws with delay in text transmission, what’s your position for the record on whether text should be introduced at the same time as voice or whether there’s reasonable cause for integrating it later in the process?
4381 MR. BIRCH: I think I have to say that I haven’t -- that we may have not given that complete thought. Like, I didn’t realize there would be this -- I mean, I understood there would be a phase-in period. I didn’t think one would be at the cost of another. I think if it’s real-time texting, and I think that’s perhaps what this -- real-time texting probably depends on RCS. That’s my gut. You know, real-time texting needs to be in place at the same time that voice is because that’s an alternative that many people count on. So it worries me that we’d have this phased approach particularly on that technology.
4382 COMMISSIONER SIMPSON: Yes, ma’am?
4383 MS. HUTCHISON: I would have to say that it would be important to do both at the same time if possible because more and more people, with the increased economic challenges that people with disabilities face -- the mentally ill people that we serve, a lot of them are coming in now with only text plans and all they have is text. If they have a phone at all, all they have is text. And more and more and more -- because even now when we’re doing our statistics I’m answering more and more, like, chat and text than in calls. And I’m getting more and more voiceless communication than voice communication.
4384 So if that’s a guidance for you, I think that just even in terms of non-emergency -- you know, Alberta Network for Mental Health is not a crisis service, but we’re getting more and more voiceless communication than we are voice communication. So if that’s a guidance for you, that would be sort of the way that I would recommend. It’s really, really getting to be way less voice communication.
4385 COMMISSIONER SIMPSON: Thank you. My daughter would agree with you on that.
4386 I think those are my questions, sir.
4387 THE CHAIRMAN: Commission Vennard?
4388 COMMISSIONER VENNARD: Good morning. This question is directed initially at Ms. Hutchison, and then of course anybody else who would like to voice an opinion on it.
4389 You are the President of the Disabled Women’s Network of Canada. Could you tell me a little bit about that, how many members you have and so on?
4390 MS. HUTCHISON: Disabled Women’s Network of Canada, because it’s a network, doesn’t really have, like, a membership list, per se, okay?
4391 COMMISSIONER VENNARD: Okay.
4392 MS. HUTCHISON: Because people -- some of them identify as members but don’t sign up and other people -- like, it’s free membership and so they’ll sign up. So it’s a really -- like, we don’t really count in that way.
4393 COMMISSIONER VENNARD: So it’s very fluid and it’s more ---
4394 MS. HUTCHISON: Yes, it is.
4395 COMMISSIONER VENNARD: Is it more like a resource, a contact?
4396 MS. HUTCHISON: Yes.
4397 COMMISSIONER SIMPSON: Okay. So what would you say would be your volume of text or phone calls or women that would contact you per month, roughly? I’m just trying to get a sense of how large the scope is of your organization.
4398 MS. HUTCHISON: Right. And our head office in Montreal would be in the best position to answer that question. And so I don’t have as good a feel for that because we don’t keep those kind of statistics, per se. In Alberta Network for Mental Health I would probably have a better answer for that question.
4399 So in DAWN Canada -- I’m going to go totally off the top of my head ---
4400 COMMISSIONER VENNARD: Sure.
4401 MS. HUTCHISON: Note because the problem is that our head office is in Montreal and I live in Irricana, Alberta. And we don’t keep -- like, it’s not like a women’s shelter where they keep those statistics out tightly. So for me I spend on the phone probably about 30 hours a month on the phone.
4402 COMMISSIONER SIMPSON: So as President of ---
4403 MS. HUTCHISON: Like, that’s right off my cell phone thing. And I probably have -- oh, gosh; Andy gave that to me. I probably do several hundred texts. Like, it’s a lot. I do a lot.
4404 COMMISSIONER SIMPSON: Okay. My question is for you as President of this organization. So as President you would have a sense, a feel of the people that -- the women that use it. Do you think that there is some sort of a gender component to the accessibility? And by this I mean here I’m looking at -- I’m thinking of the -- you know, kind of the well-known sort of idea that girls aren't good at math and are going to have a tough time with technology and that type of thing. Do you sense that there -- have you picked up anything like that? So I think this is strictly about a gender question. Is there a gender element to any of this that we should be aware of?
4405 MS. HUTCHISON: I think that in terms of a gender element, in terms of them as ability to use technology, no.
4406 COMMISSIONER VENNARD: Okay.
4407 MS. HUTCHISON: I think because we have actually a Disabled Women's Network of Canada, we had a woman who actually designed for a visually-impaired woman, she designed our website so that the back end of it could be used for women with visual impairments. So she had a totally accessible website for us that could be used and designed by -- she was visually impaired, so she designed it for us so that it could be designed on the back end of the website is where it's accessible for visually-impaired users.
4408 And she came to us with her own proposal, so she developed the proposal to get the funding to do it and then implemented it.
4409 So I think that we have a dynamic group of very technically-savvy young people coming up, and I think that that is really improving in leaps and bounds.
4410 COMMISSIONER VENNARD: Well, that's ---
4411 MS. KILPATRICK: Can I make a comment?
4412 COMMISSIONER VENNARD: --- really nice to hear.
4413 MS. KILPATRICK: Could I make a comment too? In my job, I teach blind and low-vision people how to use technology, having old technology. I have noticed that older women who are blind and low-vision -- like, I'm not trying to generalize too much, but sometimes, if they haven't maybe been in a workplace where they were using computers, maybe they might have been less so than some men were, might be a little initially nervous about new technologies.
4414 And this is a generalization. I don’t mean to say women -- I expect maybe they had a little less exposure if they were staying at home where those things happened, but certainly, we're -- and will support as everyone does pick it up, of course.
4415 I find that the younger generations, there's no difference that I can perceive between women and men in technology, because technology has become so integral to everyone, and maybe even more so to people with disabilities because it helps us level the playing field so much. But there are a few people but not as many even as there were a few years ago where you might say that someone would say, "I've never used anything. I've never used a computer."
4416 So I'm not sure but I don’t find that in the generations, them using under, I would say, generations. So I don't know if that helps you or not, but ---
4417 COMMISSIONNER VENNARD: It does. Thank you.
4418 Yes, Ms. Hutchison?
4419 MS. HUTCHISON: The only other things that I would say that I see I notice, economic barriers would be the biggest barriers for women accessing technology. The changes that we talk about are also barriers, because as technology changes, afforded upgrades are difficult for women.
4420 And also, we do see -- because again, because I'm in the area of mental health in my home province -- we do see also women with disabilities are also more at risk for abuse, so we do encounter some of that as well. And so those are the areas where I see things being challenging for women in technology.
4421 COMMISSIONER VENNARD: Okay. Well, thank you very much for those comments. Now, are there any other comments from the people at the table on that topic?
4422 MS. HUTCHISON: The only thing I do have -- and those stem from some of my personal anecdotes that I have prepared for today which we will submit in follow-up -- not every corner of our province in Alberta has 9-1-1 service, and if we do, it's not unified.
4423 So I had a terrifying experience in 1999 when I moved to Irricana because we're a provincial organization. And so I had occasion to call 9-1-1 and someone had said, "God is going to kill me and I know I'm going to do it."
4424 So when I tried to intervene, she hung up, and I phoned and I said, "I'm calling for someone," and they had shunted me up to Red Deer. So I'm in Irricana, the person who's going to die is in Calgary, and they shunt me up to Red Deer's 9-1-1. And when I tried to explain this to them, they terminate the call. They say, "Call the 266-1234 in Calgary," and hung up. And I knew that that was the non-emergency number in Calgary.
4425 So now I've got nowhere to call. So I called the distress centre and they had nowhere to patch me in, and -- because they were supposed to have a way to seamlessly patch you in without hanging up, and that never, ever got implemented. And this was back in the mid-nineties.
4426 So as time went on ---
4427 COMMMISSIONER VENNARD: Well, hopefully there's been some changes since then.
4428 MS. HUTCHISON: Well, and I don’t know if there ever has been, but -- and I'll -- and I will follow that up because I know we can do that in the next two weeks -- but there -- the -- there hadn't been at that time and so the only way I got that person to help was to do three-way calling, and I had to call my different colleagues in the movement. And we got the person to aid by having three-way calling to 9-1-1 in Calgary.
4429 And so we did get the person to aid and luckily they were saved. But it was terrifying and it was just sort of one of those examples about how the jurisdictional issues, right, from area to area ---
4430 COMMISSIONER VENNARD: Well, every once in a while these -- some of these issues come together and examples that they can be really quite ---
4431 MS. HUTCHISON: Right place ---
4432 COMMISSIONER VENNARD: --- dramatic.
4433 MS. HUTCHISON: So how can -- is that something that can be resolved in the NG9-1-1? Is that a ---
4434 COMMISSIONER VENNARD: You're talking of an example that was ---
4435 THE CHAIRMAN: I think the point ---
4436 COMMISSIONER VENNARD: --- quite a number of years ago.
4437 THE CHAIRMAN: I think the point we draw from your evidence is that you are concerned about resilience and reliability, and yes, that will be a consideration. So it's very good for you to have put that in perspective for us.
4438 MS. HUTCHISON: Right, but is that something that the new system does address or ---
4439 THE CHAIRMAN: Well, the new system doesn’t exist yet, so we're building it, so the outcome you're talking about is an excellent one, so thanks.
4440 MS. HUTCHISON: Thank you.
4441 COMMMISSIONER VENNARD: Thank you very much for those comments, and I'm glad to hear that we're not -- we don’t have a lot of gender issues to be concerned about with respect to this. So thank you.
4442 THE CHAIRMAN: Vice-Chair Menzies.
4443 COMMISSIONER MENZIES: Yeah. Mr. Martin, you stated that -- in your oral comments -- you must have a voice plan contract with a provider in order to have a T9-1-1 call go through. I was wondering where you got that information?
4444 MS. MARTIN: I'll defer that question to Anthony or Gary or perhaps ---
4445 MR. BIRCH: That's our understanding, and I believe it was actually in the decision on basic ---
4446 COMMISSIONER MENZIES: Okay, well, you should check ---
4447 MR. BIRCH: But ---
4448 COMMISSIONER MENZIES: --- because in terms of ---
4449 MR. BIRCH: Because what ---
4450 COMMISSIONER MENZIES: --- understanding within your community, you should be able to place a 9-1-1 call without a voice plan. You should be able to place a 9-1-1 call without even a subscription. Even decommissioned phones, as long as they have power in them, can use the 9-1-1.
4451 MR. BIRCH: No, I think the issue though is people that only have data plans and with no voice ---
4452 COMMISIONER MENZIES: Yeah.
4453 MR. BIRCH: --- that they're -- because the ---
4454 COMMISSIONER MENZIES: You don’t need a voice ---
4455 MR. BIRCH: --- text ---
4456 COMMISSIONER MENZIES: --- plan to place a 9-1-1 call.
4457 MS. HUTCHISON: I can address this.
4458 MR. BIRCH: No, but if you're deaf, then you want to use text. And so what was happening is, people were getting their data plans, but were not able to actually text because texts are carried over the ---
4459 COMMISSIONER MENZIES: Okay, well, you should ---
4460 MR. BIRCH: --- voice ---
4461 COMMISSIONER MENZIES: We should make sure, for the sake of the community, that there's clarity on that, going forward, and ---
4462 MS. HUTCHISON: I can take this.
4463 COMMISSIONER MENZIES: Because people do not need to have a voice plan to ---
4464 MS. HUTCHISON: I can take this.
4465 COMMISSIONER MENZIES: --- place a 9-1-1 call.
4466 MS. HUTCHISON: I had a caller again on the Board of Disabled Women's Network of Canada who was deaf, and she was on the Board of the Canadian Association of the Deaf. She couldn't -- she could only use text and she was very poor. She could not have a text-only plan without purchasing a voice plan at that time.
4467 COMMISSIONER MENZIES: Okay, well, that's a different matter. But it is ---
4468 MS. HUTCHISON: No, but that is the exact problem.
4469 COMMISSIONER MENZIES: But it is -- but it is -- it is -- you'd -- like I said, you don’t even need to have a subscription to place a 9-1-1 call. I don't want people listening to this to come away from this thinking that ---
4470 MS. HUTCHISON: She can't talk ---
4471 COMMISSIONER MENZIES: Well, there's a ---
4472 MS. HUTCHISON: --- and that's the problem.
4473 COMMISSIONER MENZIES: --- code that goes into it when you place the call. But there should be clarity on that, because just for the sake of everybody, I mean, there might be matters for dispute and debate and what it should be and what it shouldn't be, but people should not think that they cannot place a phone call -- I mean ---
4474 MR. TIBBS: I think I can clarify ---
4475 COMMISSIONER MENZIER: --- their disabilities and have to buy a voice plan. Because like I said, you don’t even need to have any type of plan. The phone can be decommissioned and you can place 9-1-1 calls. In fact, it’s a big issue for PSAPs.
4476 MR. TIBBS: I think I can clarify -- I can check our remarks. But the issue is not making a voice call. The issue is accessing Text 9-1-1 from a phone that doesn’t otherwise have a plan or a voice plan.
4477 COMMISSIONER MENZIES: Okay, that’s fine.
4478 MR. TIBBS: As far as I’m aware ---
4479 COMMISSIONER MENZIES: We don’t need to go over it again. I just want to make sure that anybody listening -- and I appreciate that point; I take that point. I just want to make sure that people listening who are following the process do understand that, notwithstanding those complexities, a voice plan isn’t required to make a call.
4480 Anyway, thanks very much.
4481 THE CHAIRMAN: Thank you for answering our questions. Just so, you know, to help you prepare for the next phases and the rollout over time, I just wanted to underscore that the telecom notice of consultation that led to this proceeding made extensive references to the Emergency Services Working Group and there in a very extensive footprint on our website. So I do encourage you to take notice of that and be well-informed of it.
4482 Okay, thank you very much. Those are all our questions.
4483 We’ll take a short break to 10:35 to keep going with the next intervenors. Thank you very much.
--- Upon recessing at 10:22 a.m.
--- Upon resuming at 10:37 a.m.
4484 MS. ROY: Please take your seats.
4485 THE CHAIRMAN: Order. Order, please. A l’ordre, s’il vous plaît.
4486 Madam la secrétaire.
4487 MS. ROY: Thank you.
4488 We’ll now hear the presentation from the Canadian Hearing Society. Please introduce yourself and you have 15 minutes for your presentation.
4489 MR. MALKOWSKI (by interpretation): Hello. Thank you, Mr. Chair and the Commission, for allowing me to present. My name is Gary Malkowski. I’m the Vice-President, Stakeholder, and Government Relations for the Canadian Hearing Society.
4490 Our presentation has five areas, objectives we’d like to cover. We want to explain the solutions that will meet the needs of people who are deaf and hard of hearing and also Canadians who have disabilities related to speech. It’s for all Canadians, including new Canadians. It’s to benefit all; it’s a wide benefit.
4491 I want to discuss the challenges, the barriers in the current systems. What does it look like for us in the current system?
4492 And we’re going to talk about potential future solutions.
4493 I want to explore the available technology and what we need to do to be ready for the future.
4494 I will also give you some recommendations. And after that I have a video to show you. It’s a very short video.
4495 Our goal is for the audience. The first audience is the community, the users of the NG9-1-1 framework so that it’s compatible and interoperable with all technological solutions so that people can use any type of device, any technical device in order to contact emergency services. That’s one audience.
4496 The second audience are the PSAPs. It’s very important that they have their technology updated in their emergency centres. There needs to be standards and practices that are consistent. For example, they need to be ready to meet the state of future technology.
4497 What does it look like? There are four kinds of technology. First VRS technology, video technology. For example, FaceTime, Skype, video relay services, those types of video interaction where you can see the signing, the communication.
4498 Secondly, captioning technology such as TTYs, IP relay, RTT, which is new one -- that’s the real-time text. I’m going to speak about that more later. For deaf and hard of hearing, using text is important.
4499 Third, the carry-over voice. We call it “caption telephone”. You pick up the phone, you start talking, and you can actually read what you’re saying. That is a caption telephone.
4500 Fourth, the tactile text technology for deaf/blind individuals or low vision.
4501 The point is to keep all options in mind so that everything fits with all of the different technology.
4502 Accessible for emergency, the legislation -- you know about the UN Convention on the Rights of Persons with Disabilities. It was ratified and signed by our Canadian Government. And soon the Optional Protocol is going to happen, by the end of this year. And that means a very important change. Article 9 is about accessible information communication in emergencies. We have to make sure that technology will be available both in sign and in voice.
4503 Article 11 talks about the risks, an emergency or a national disaster, a flood, whatever that might be. For example, the lockdown of Parliament Hill. How did you tell people and how would you tell somebody if that happened again?
4504 The national accessibility legislation is coming. We’re going to hear about it soon; probably this fall it will be introduced. And I think it’s going to be better than the Americans with Disabilities Act. I think it will have a much stronger enforcement policy.
4505 And for that reason we need to not permit any creative discrimination to happen. We have to eliminate that completely. We have to not create new barriers. We have to remove attitudinal barriers.
4506 One good example is that I was CC’ed by a letter from Eric Bowles, the legal counsel, your legal counsel, in fact, and I was very surprised to receive this letter that you were not going to have sign-language interpreting through this week of hearings and captioning as well, real-time captioning, for this week of hearings.
4507 And CPAC was not going to live-stream with captions. And it is your responsibility as Chair and Commissioners. I am surprised that you allowed this discriminatory practice to happen this week. This is a really beautiful example of discriminatory practices and I’m going to wish you good luck when this gets through to the Human Rights Tribunal. I hope it’s going to be solved soon.
4508 I’d like to talk about the technological challenges.
4509 There are TTY challenges -- yes, it does need a landline. You use things such as VRS, MRS. These are time-consuming and they’re very slow.
4510 VRS requires a very strong internet connection and it needs to be high-speed. The data usage is cost-prohibitive and there are limited hours. Right now VRS services are 9:00 to 9:00.
4511 TEXT with 9-1-1 -- yes, that’s an improvement, but it has challenges too. It’s not live; it’s not real-time, interactive; there are delays and lapses; there’s no location-specific or GPS information for the PSAPs or the emergency call centres.
4512 For example, people recently registered with the 9-1-1 service, but I’m not even sure if that works; I haven’t tested it. And how am I going to know if it really is going to work in an emergency? I can’t test it.
4513 So when people register, how are we going to know if it’s working? That is an issue; it’s a challenge. The PSAP are still using text or TTYs but there are very few that can accommodate it.
4514 Through technological adaptations that are happening, there are more people who are using updated technology such as texting, instant messaging, or video chats. There are a lot more people using that, such as Skype and Facetime, as I mentioned.
4515 Emergency communication options in an emergency situation, people who are deaf or hard-of-hearing can use Text with 9-1-1 once they’re registered, video relay service from 9:00 to 9:00 -- I know this says 8:00 to 8:00 but it’s really 9:00 to 9:00 -- or there’s IP relay, text-to-voice.
4516 There’s chat and instant messaging but it’s only available in the London Police Services. It’s a great, wonderful service. It’s live and the messages go back and forth, but it’s only in London, Ontario. It’s not available anywhere else.
4517 And in Canada, not currently available is real-time text or the captioned-telephone I talked about, and it would be important for us to consider that people would like to talk and, perhaps, see the caption on their phone or a text of what they’re saying.
4518 The national accessibility legislation is probably going to add that as a recommendation and it’s going to impact your mandate as the CRTC. I think your mandate is going to change; it’s going to be the new national legislation and it’s going to be talking about functional equivalency. And everyone should be able to function -- participate on an equal basis.
4519 The national accessibility legislation consultation that’s happening across Canada --one of the hot issues, I tell you, over and over again that’s coming up is the CRTC.
4520 Now, about real-time text and new technology, the Federal Communications Commission, the FCC, on December the 15th announced that they had approved our real-time texting, RTT; they’re going to phase out TTYs. They’re going to go to an internet-based real-time text, the RTT Smart Phone. It’s really cool and we should be -- you should be considering minimum standards for the PSAPs, the emergency centres. They need to have a minimum standard that can be compatible with Smart phones, TTYs, any technology.
4521 And I’m surprised to hear you say this morning about RCS. I was surprised to hear you talk about the RTT being a problem in terms of the compatibility. But did they both sit down and have a meeting with the RTT people in terms of the RCS concerns and to discuss that issue? I’m really wondering about that. I was surprised to hear you talk about it.
4522 RTT allows you to use instant visual -- you can see the characters, the live-time back-and-forth communication, and they can also call the PSAPs, any call centre that’s available. It’s not going to be available until December of 2017. So they’re talking about a five-year -- yeah, so it’ll start -- over that five-year period they’ll start up the new stuff and, for some of the rural areas, they will still need to have TTY service. We’re not thinking that TTY will disappear completely; that’s not our goal.
4523 The Canadian Hearing Society, some deaf, and some hard-of-hearing people still purchase TTYs, believe it or not. They still book through OIS for OIS services through as hearing call through the TTY but the sales of TTYs are definitely decreasing.
4524 Our recommendation is that you consider setting up a minimum standard for the modernization of the PSAP call centres so that you engage emergency dialogue across different services.
4525 Once you’ve set up the minimum standard, perhaps RTS as the one minimum standard, you can develop, then a framework, a network that will be compatible with all of the different technologies such as TTY, IP relay, VRS, RTT and Tactile, as well as the captioned telephone, video calls and others ways, for example, Facetime and Skype, if it’s compatible.
4526 You’ll have to monitor real-time text in the United States as they introduce it and we’ll see how they manage it, and then we can see how it will apply to Canada. We need to have educational outreach so people have knowledge of the options.
4527 I’m a member of the CRTC working group for 9-1-1 emergency services and we’ve developed a communication kit with key messages for education. I needed to do some education there about existing technology but there need to be more work in educating emergency services so that committee becomes more familiar with the available technology.
4528 I’m asking for -- okay, I’d like you to roll the video so everybody can see this. It’s got voice and captions as well on it.
4529 (VIDEO PRESENTATION)
4530 MR. MALKOWSKI (by interpretation): That’s it. That’s the end of my presentation. I’m available to answer any of your questions. Thank you.
4531 THE CHAIRMAN: So thank you for your participation. And Commissioner Vennard will have a few questions for you.
4532 COMMISSIONER VENNARD: Good morning. Thank you for participating in our hearing.
4533 In your written submission, you provided us with four concerns and four recommendations and we thank you for those as well. And they will form part of our record.
4534 In your presentation this morning you mentioned that you participate in the Emergency Services Working Group. And one of my questions has to do with that. Do you have any recommendations for how that group can get additional input from accessibility groups or people with disabilities or get increased participation from individuals representing other accessibility groups?
4535 MR. MALKOWSKI (by interpretation): I think it’s important for that committee to communicate with Deaf Wireless Canada, other organizations that serve persons with disabilities as well, locally, provincially, and nationally.
4536 It’s important that the PSAPs’ emergency call centres also talk with all of these different organizations. We need to encourage them to be involved. I know they’re very busy and resources are limited, finances are limited. Technology is not really caught up. So it’s important for that kind of information that I just demonstrated on the video that this public hearing, for example, meets -- it’s educational.
4537 The Working Group, Emergency Group, has developed that communication kit and how we can use Text 9-1-1; it’s an education tool. And it’s a good educational tool in that kit. It could be used for anybody who is involved in an emergency call centre. So that idea can sort of carry over to how we talk about the various available options, for example, this RTT demonstration and what is the best resource, what’s the best training.
4538 And at the same time, we recognize the challenges, the technology challenges, the financial challenges. They all need to advance. And it really is going to depend on the CRTC’s leadership. We need to set that minimum standard and then we will succeed.
4539 COMMISSIONER VENNARD: Thank you very much for that input.
4540 My second and final question that I have -- is the deaf/blind community also adopting text as a means of communication?
4541 MR. MALKOWSKI (by interpretation): I’m sure that the tactile technology is available now. They have adapted it through an App and many deaf/blind people are using that through an online internet, smartphone. There’s a special feature that’s been designed for deaf/blind. And many deaf people have ushers or low vision and they use that a lot.
4542 COMMISSIONER VENNARD: Okay. Those are all my questions and I thank you very much for your contribution.
4543 THE CHAIRMAN: Commissioner Menzies? Vice-Chair Menzies, sorry.
4544 COMMISSIONER MENZIES: Good morning. Can you just update us on how many deaf and hard of hearing people there are in Canada?
4545 MR. MALKOWSKI (by interpretation): There is several different sources to get that information. There’s no formal research that confirms the exact data in Canada. That isn’t available.
4546 If you look at the statistical information from Mission Consulting on the feasibility study of VRS from a number of years ago, they calculated the numbers based on 2012 information. And so they were sort of figuring it out from the statistics in the United States and comparing it to the Canadian situation. There would be 360,000 Canadians who can’t hear, who can’t use voice phone; 35,000 people use sign language. But again, many are unreported.
4547 They don’t report themselves so it’s hard to get an exact number. But generally speaking, in the United States they say 1 in 10 Americans have some sort of a hearing loss. In the U.K. it’s one in every seven. In Australia it’s one in six. In Canada we don’t have any research on that. So we just use comparative numbers to the U.S. So you pick a number in between the U.K. number and the American number. So maybe we’re one in eight. But we don’t really have any real research on that. But it’s a close enough estimate. One (1) in 10 is a good assumption to make; 1 in 10 has a hearing loss.
4548 But again you have to remember the age of the population. And so we’re getting more and more older people. So obviously hearing loss follows age categories. So if you look at people over 50 I bet you it’s 50 percent, over 60 it’s going to be 60 percent have a hearing. At 70 it’s going to be 70 percent. It increases with each decade.
4549 COMMISSIONER MENZIES: Okay, thank you. I will go with the 35,000 who sign, for the purpose of this question.
4550 Why is it, if there are 35,000 people who sign, that only 3,000 of them have registered for text to 9-1-1 or for VRS to this stage? If all those people are in dire need of this service, what has gone wrong with the system, that less than 10 percent of the people in dire need of this service are registered for it?
4551 MR. MALKOWSKI (by interpretation): Well, with new technology it always is the case that many people are not aware of the availability of the technology. There does need to be a lot of outreach and education. The school system, for example, has not updated their information, so we have to educate the education system. We need a training program through the colleges and universities which includes digital literacy.
4552 And awareness training has to increase. It’s -- as you know, seniors are not really crazy about using computers or Smart phones but, through education, the numbers are increasing of seniors who are using computers. So it’s the same for the deaf and hard-of-hearing; it’s an education issue. The more awareness there is, the more it will increase.
4553 The other issue is a poverty issue; they can’t afford the technology. That’s a huge issue. The cost of the technology is escalating. You have to buy your data plan; you have add the technology; you have to add whatever. So who can afford it, is really one of the issues when you have to worry about your basic survival needs.
4554 Many of this population don’t have a phone, which is pretty basic. Many don’t have a computer. They tend to go to the library, for example, to use it, where you can use -- a public area where you can use technology for free, such as the computer.
4555 So we need to have -- so the two issues would be education that needs to be ongoing, and also the affordability.
4556 COMMISSIONER MENZIES: Thank you.
4557 THE CHAIRMAN: Thank you very much for your participation. And I note -- and of course you know this -- on your technology slide you pointed out that when you design text-with-9-1-1, obviously one has to be concerned about location-specific information getting to PSAPs.
4558 The Americans might not have done it right but because we followed the way we designed our Text-with-9-1-1 that information is delivered to PSAPs. So -- but thank you for bringing that issue to our attention when we design the future -- next-generation 9-1-1 that location information continues to be available. And we’ll certainly take that into account.
4559 MR. MALKOWSKI (by interpretation): I would like to add that I think it’s important that you be aware of this report. The report is the FCC Report; it was released in May of 2016. Although it was approved in January of 2016, it’s the Taskforce on Operational PSAP Architecture; that’s a very good report. It talks about the technical challenges and the financial challenges and who’s responsible in terms of oversight.
4560 I think this is an excellent report for your information. I’ll be happy to send you the link, if you’d like. It’s a great starting point in terms of knowledge. I’m not sure if you know about this report.
4561 THE CHAIRMAN: Rest assured we follow quite closely developments at the FCC and we are aware of the report, thank you very much. But good to bring it to the public record, thank you.
4562 MR. MALKOWSKI (by interpretation): My pleasure, thank you. And we’re all here to support you and I think it’s important that you show leadership and to make sure that all of the CRTC and public hearings are more accessible in the future.
4563 I think you need to think about positive action, proactive action. The CRTC needs to be a role model compared to other agencies. And I’m hoping that one day the CRTC will be one of the champions and be one of the very best models and we will beat the FCC.
4564 We need your leadership, and we’re all here to support you, and we will make sure that the national accessibility legislation includes changes that will give you possibly a new mandate, ensuring that it will give you more resources, give you more committee ability where community members -- persons with disabilities will be involved.
4565 We need to make it the best place possible for all of Canadians to benefit from this technology. The most important thing is the access, and the next-generation 9-1-1 is so very important.
4566 Thank you very much for giving us the opportunity to participate and I wish you all the best. Let’s make it the best celebration for 150 so that we can be really proud of what we accomplish.
4567 THE CHAIRMAN: Thank you very much for participating in the hearing.
4568 We’ll take a short, five-minute break just to switch around the panels to move to our next intervenor. Thank you.
--- Upon recessing at 11:11 a.m.
--- Upon resuming at 11:18 a.m.
4569 THE SECRETARY: Please take your seats.
4570 THE CHAIRMAN: Order. À l’ordre s’il vous plait.
4571 Madame la secrétaire.
4572 THE SECRETARY: Thank you.
4573 Before we begin the presentation, I would just like to announce that le Conseil provincial du secteur municipal du SCFP-Québec, qui comparaissait aujourd’hui -- that were appearing today, will not be appearing at the hearing.
4574 We will now hear the presentation from the Canadian Association of the Deaf, Deaf Wireless Canada Consultative Committee.
4575 Please introduce yourself and your colleagues, and you have 20 minutes for your presentation.
4576 MR. FOLINO (by interpretation): Good morning, Commissioners and Chairman. My name if Frank Folino; I’m the President of the Canadian Association of the Deaf. To my right is Lisa Anderson-Kellet, and she’s representing Deaf Wireless Canada Committee and she’s the Chair and analyst. To her right is Jeffrey Beatty, also part of the Deaf Wireless Canadian Committee. And to my left is Megan McHugh, and she’s part of the Canadian National Society of the Deaf/Blind, and the President of that organization.
4577 We would like to suggest that all of the slides and introductions -- part of our presentation become part of the public record of this proceeding.
4578 I have a few business items -- administrative items, if you may, before I turn it over to Lisa for her presentation, and Lisa will outline those.
4579 MS. ANDERSON-KELLET (by interpreter): I want to make a disclaimer about my participation and role here today. My role here as Chair of the Deaf Wireless Canada Consultative Committee, DWCC, and not a Director of the Canadian Administration of VRS CAV Inc. If any questions are directed to me about Canadian Video Relay, I will pass that off to Frank and Jeffrey to answer those.
4580 The next comment we’d like to make is about accessibility. And the previous presenter, Gary Malkowski, made comment to that and we also wish to make comment that we are very disappointed in the decision by the CRTC not to provide full access via sign-language interpreting for this week’s proceedings and hearings that are operating all day, every day this week.
4581 It’s our basic right to have full access to public hearings just like every other Canadian and we feel that we were not given that full access.
4582 The other thing we’d like to emphasize is that the UN Rights for Persons with Disabilities, specifically Article 9, is related to access, which would include the CRTC and other government departments. It stipulates that parties will take appropriate measures, including eliminations of obstacles and barriers to ensure equal accessible services. This includes to provide forums of live assistance and intermediaries, including guides, readers, and professional sign language interpreters to facilitate accessibility to buildings and other facilities open to the public.
4583 The next point is related to the legal decision in Canada, formally The Canadian Association of the Deaf, et al. v. Her Majesty the Queen from 2006. It requires that all federal government departments, programs, offices, and services must provide and pay for sign language interpreters, period.
4584 Thank you.
4585 I think I’d like now to pass it over to Megan.
4586 MS. McHUGH: Okay. Hello, everyone. My name is Megan McHugh. Thank you for this opportunity to represent the Canadian National Society of the Deaf-Blind, CNSDB for short.
4587 The Canadian National Society of the Deaf-Blind was registered in 1985 as a national consumer-run advocacy association dedicated to helping Canadians who are deaf-blind achieve a higher quality of life. We advocate for new and improved services; promote public awareness of deaf-blindness, deaf-blind issues; and gather and distribute information in order to help empower individuals who are living with deaf-blindness -- sorry -- and to become fuller participants of society.
4588 CNSDB provides expertise in accessibility related to the needs of individuals who are living with deaf-blindness, the distinct disability of deaf-blindness, which is different from deafness or blindness due to being unable to use one sense in order to compensate for the loss of the other sense.
4589 MS. ANDERSON-KELLET (by interpretation): For this particular proceeding we want to mention our intervention that we undertook in terms of a survey. The survey was completed and I will be reporting on that. It’s called “Redefining 9-1-1 and the Safety and Lives Survey Analysis for Deaf and Deaf-Blind Issues”. And I would encourage -- or actually, I would ask you for your permission to make the results of this survey -- it’s a total of 135 pages. If you could please include it in the public record, I believe that the findings from this survey will be of benefit for the work that we’re doing here today.
4590 Do I have your permission to do that before we proceed?
4591 THE CHAIRMAN: We’ll take your request under advisement, but you may proceed.
4592 MS. ANDERSON-KELLET (by interpretation): Thank you.
4593 So the next slide I’ll share the findings from the survey.
4594 There was a total of 601 valid entries or data responses that we received. It was quatro-lingual, both in English and ASL, French and LSQ. We also included an additional survey to include deaf-blind comments and participation. We provided it in colour-contrasted formats. We reached out through public events and also used SurveyMonkey and did that across the country.
4595 The goal of the survey was to test the awareness of TEXT with 9-1-1; discover how respondents learned about TEXT with 9-1-1 and where they gathered that information. We wanted to test their knowledge about their registration process. And we wanted to quantify the number of people registered with TEXT with 9-1-1.
4596 We also wanted to test the clarity of the TEXT with 9-1-1 website and the resources available. And we also wanted to determine the frequency of respondents requiring 9-1-1 and the methods they used to access the services from first responders and which technologies specifically.
4597 We chose a few questions from the surveys to share with you today. In terms of question 21 the question was:
4598 “If you have not registered with TEXT with 9-1-1, why not?”
4599 Thirty (30) percent didn’t know that they were required to register; 27 percent said registration wasn’t clear; and 57 percent said that there were many issues with TEXT with 9-1-1, with over half the respondents, with 300-plus respondents.
4600 In terms of the registration process, we asked:
4601 “Do you prefer very short ASL and LSQ videos of step-by-step instructions on how to register?”
4602 Overwhelming the answer was “yes”, at 80 percent. They wanted that information in sign language. Because if in any emergency, especially when life depends on it, communication is essential. And for deaf users that’s in sign language.
4603 Another survey -- the last question that I’ll share with you is:
4604 “The CRTC is proposing some changes to 9-1-1 services. What methods do you currently prefer to use?”
4605 The majority said that they would prefer to us a mobile App. Twenty-four (24) percent would prefer direct Text-to-9-1-1. They did not want to call through a voice line to access 9-1-1 services.
4606 Frank will talk about the issues and challenges.
4607 MR. FOLINO (by interpretation): Thank you, Lisa.
4608 In terms of issues and challenges, the first was there was a delayed response when communicating with 9-1-1. And the biggest concern the respondents had from deaf, hard of hearing, and deaf-blind people is that they would first have to call 9-1-1 and then wait up to two minutes, which is a delay, to have a response back from 9-1-1. And then at that point they would have an interactive communication with 9-1-1.
4609 We consider that to be a very serious issue, especially in a life-or-death situation, to wait up to two minutes. Anything could happen in that two minutes. It’s a very high-risk and a very serious concern.
4610 Another issue was there are so many variables happening after dialling 9-1-1. For example, you may be on hold, the voice line may be interrupted or dropped, the radius -- or there could be a power outage in the area where that person is attempting to reach 9-1-1. And that’s a very important concern and consideration for the CRTC to consider that, especially in an emergency.
4611 Now, back over to Lisa who will talk about TEXT with 9-1-1 and the voice requirement.
4612 MS. ANDERSON-KELLETT (by interpretation): A common scenario and complaint is a deaf customer goes into a wireless service provider, a vendor location, and they ask to have the voice portion of their plan removed. They don’t understand why they have to have that as part of their plan. We discovered that that's a common issue within our community, and that's one of the reasons that we're here.
4613 Deaf community customers are not fully understanding the reason why the wireless service provider replies with no, that they cannot remove it. And the reasons is because it needs to be in place to be able to use Text-with-9-1-1. But the customers gets upset because they're paying for something they're not using.
4614 And the App on the iPhone, for example, there's an App. Most deaf people put it at the very end of their -- all the apps available on their phone because they never use it, so it's not readily accessible. And the other reason is that a lot of deaf customers are not aware of the voice-credited data plans created. It varies from company to company, but can be from -- anything from $15 to $30 credit.
4615 But again, you have to think about why would a deaf person be required to use a voice plan and why would it be required if they don't use voice, and especially in a life-to-death situation? They're not going to be thinking about using their voice plan.
4616 And now, Jeff will speak next.
4617 MR. BEATTY (by interpretation): In terms of Text-with-9-1-1, the trial and the systemic decision process, I read through a lot of the information and we found that 27 volunteers were selected as part of the trial period for Text-with-9-1-1 before the implementation in the following cities: Montreal, there was 10; Peel, 7; Toronto, 6; and Vancouver, 4.
4618 Only two provincial deaf organizations were selected: The Canadian Hearing Society and the CD-CQDA that focus on Ontario and Quebec, but the remaining deaf organizations in eight different provinces were not included. The national deaf organization CAD-ACS was not included.
4619 So we question the validity of the systemic decision-making process, which was based on a very low trial participation number. How can you make such a big systematic decision based only on 27 participants when we were able to get a wider reach?
4620 From the graph that I have here to compare the numbers, DWCC -- oh, yes, DWCC and CAD, they surveyed -- 260 were the numbers that they were able to reach.
4621 Sorry, the interpreter is just seeking clarification here. One moment.
4622 So within the deaf community, the members within that community, there was 5,000 -- over 5,000. However, these people were not part of the trial.
4624 MS. McHUGH: Okay, so on -- okay, so deaf-blindness is the combination of a wide range of levels of vision loss and hearing loss that prevent individuals from depending on either sense to independently access information in communication. People who are deaf-blind communicate using methods such as sign languages, tactile sign languages and voice, and intervenors are trained professionals who provide communication assistance, environmental information, and sighted guiding. And there are other things too.
4625 In emergency, an intervenor can help us communicate with first responders and understand what's going on. Being deaf-blind can make it difficult to get help and find a safe place where first responders can find you. It is also challenging communicating with 9-1-1 operators and first responders.
4626 There must be extensive consultation with individuals who are deaf-blind and organizations that are run by and for people who are deaf-blind.
4627 Okay, so now, Text-with-911 -- oh, Text-with -- wait, sorry. Where am I? Okay, sorry, I'm sorry about that.
4628 The Text-with-9-1-1 registration system process needs to be made fully accessible and usable for low vision users and for non-visual users with Braille displays. The site layouts need to be less busy. Information should be in plain language and organized so that instructions are easy to follow. Larger, bold fonts and high-contrast text and background colours are essential. There should be plain text only paging and pages that include sign language videos.
4629 The registration process should be made consistent amongst all the wireless service providers. Being able to create a user profile when registering would allow us to indicate that we are deaf-blind and provide some basic information on communicating with us. This could allow first responders to be prepared to deal with an individual who is deaf-blind. There should be the option of calling -- of sending a text directly to 9-1-1 or to making a voice call and waiting for the 9-1-1 operator to send a text back, a text. It's just, the important thing is having the option of doing it one way or the other.
4630 Being able to text directly would save valuable time. If someone is unable to tell where they are or what's around, they cannot provide their location. So we need the location system to allow first responders to find us quickly. It's extremely important that 9-1-1 operators and emergency responders receive awareness training. Our lives depend on it.
4631 MR. FOLINO (by interpretation): The final part of our recommendations -- of our presentation are our recommendations. Recommendation number 1: Text-to-9-1-1 App. An App would provide functional equivalency and plain language for all deaf and hard of hearing sign language individuals, people who are deaf-blind, intellectually and cognitively challenged, and mobility issues, in light of any emergency situation where the responder can be able to arrive at the scene in a timely manner.
4632 Innovation and development of simplified and visual Apps that are available in popular smartphone devices including direct Text-to-9-1-1; GPS locators -- and instead of -- back to the direct Text-to-9-1-1, we don’t want a delay; we don’t want the two-minute wait time to have a response from 9-1-1; we want it to be instantaneous -- the GPS locators to be able to identify where we are; the ability to take and send photos and videos; and also to dial 9-1-1.
4633 I mean, the benefit of people who are not deaf is that they can have and do have direct access to 9-1-1 just by dialling three numbers. That benefit should also be applied to those of us in our community. And everybody can use this App, including people who are not deaf.
4634 Recommendation number two, real-time text. The FCC recently approved this new technology geared to replace the TTY since it is in declining or has stopped production of these devices. A description of this technology is in bullet form, which I will go through.
4635 Permits wireless service providers and handset manufacturers to support RTT in lieu of TTY technology; ensures RTT users will be able to call 9-1-1 for emergency services and 7-1-1 for relay services; it defines RTT to be interoperable across networks and devices and backward compatibility with TTYs; and establishes a phased rollout of RTT for wireless networks from December 31st, 2017 to June 2021.
4636 The links and resources are available in our survey analysis report.
4637 Recommendation number three. The GPS and PSAP triangulation. So I just want you to take a moment. There’s a photo here that I’ve included in the presentation and it’s of this building here, of the CRTC hearing buildings. And it shows about as 50-metre radius around the building.
4638 If you were to take a walk on your break and maybe walk over to where the church parking lot is, that would bring you out to 300 metres from this building.
4639 Now, while I was over there, if I -- you know, if something came up and I had to call 9-1-1, the PSAP would have this radius to try and identify my location to find me and I may be in this room where we are right now. And the App that we’re suggesting would be able to pinpoint my exact location to this room and not search within the radius.
4640 Now Megan, would you please go ahead and introduce our recommendation number four?
4641 MR. POMMINVILLE: The microphone is on.
4642 MS. McHUGH: Okay, it’s this right here, right?
4643 MS. POMMINVILLE: Correct.
4644 MS. McHUGH: Okay. Wait, where is it? Which slide is it? This one?
4645 MS. POMMINVILLE: Correct, yes.
4646 MS. McHUGH: Okay, sorry.
4647 Okay, so Text-to-9-1-1 registration in App.
4648 Text-to-9-1-1 App and registration has a note the person who is deaf-blind in the user profile; information for first responders; inclusive consultation process.
4649 Okay, just the next slide?
4650 MS. POMMINVILLE: Correct, yes.
4651 MS. McHUGH: So it’s a bit mixed up now.
4652 Okay, so 64 percent are registered or -- oh, sorry; I missed that. Sorry. Sixty-four (64) percent, which is over 300 respondents, are not registered or do not know or are not aware of TEXT with 9-1-1 registration.
4653 So what does this mean? A public relations awareness campaign and strategy needs to improve and through the deaf, hard of hearing, and deaf-blind community channels for increased effective awareness -- effectiveness, sorry.
4654 MS. ANDERSON-KELLET (by interpretation): Recommendation number six, improve dissemination. For example, if we look at the CWTA, the Canada Wireless Telecommunication Association’s website where Text-to-9-1-1 information is -- we saw some videos there -- and we agree it’s a good effort. However, there’s only four things. There’s pictures, images with text, words, and some signing. But there’s no captioning. We noticed also there would be an image and then it would jump over to someone signing.
4655 We would recommend a blend of all of these ways just to present in a presentation. So put a playlist -- develop a playlist so that it’s easy to find and identify. And then within the deaf community, we have about 260 contacts currently as of today -- we can disseminate that. But we could also provide a model about the video and website that we have included here for you to look at. Elections Canada -- that’s one model, and a good model, that you could use before disseminating your information.
4656 Recommendation number seven, Telecommunication Accessibility Fund. The CRTC here, as you know, has created a number of different funds for specific purposes, some related to accessibility such as the Broadcasting Accessibility Fund, otherwise known as the BAF. We strongly recommend that the Commission establish a similar new funding mechanism through a central contribution fund for the provision of accessibility to any telecommunication services, including TEXT with 9-1-1; an independent and impartial funding body supporting innovative projects that provide solutions to promote accessibility of all telecommunication services content in Canada.
4657 It would be of a similar concept of what the BAF is set out to do.
4658 The funding must be national to provide urban and rural communities, and it will also provide support for these resources for such important projects such as community educational workshops with simplified updated short and quick step-by-step informational and educational videos that are critical and create -- and distribute widely in ASL and LSQ video vlogs.
4659 Recommendation number eight, stakeholders’ involvement. It’s very important that the CRTC consult with groups like ours here before you today and involve us.
4660 For an example, the Emergency Working Group -- none of us here are involved within that committee; the Canadian Wireless and Telecommunications Association -- we do have some involvement there but there has been almost no activity for almost three years, nothing, so we have some concern about that and we wanted to bring that up to make you aware of that.
4661 The Public Safety Answering Points -- there are some of us that have participated there and that should be ongoing; the CRTC Advisory Committees; and also finally the Board of Directors of the NG9-1-1 Administrator.
4662 The previous interventions this week had mentioned the need to have more involvement from our community and to have an advisory committee. And we would like to be involved to speak to the issues before us. We believe that a lot of our recommendations and findings and life experience will better improve the access to the people of our community.
4663 We have to work together. We have to communicate. Communication is a two-way street and we need to meet halfway and start working better together to improve this and to create a better model for all of us here in Canada.
4664 The theme is "Nothing about us without us," and that includes all of us. And that's a very, very important quote and concept to take home today.
4665 To wrap up, in terms of our last recommendation, Text-to-9-1-1, we don’t want Text-with-9-1-1, which includes voice. We want direct texting to 9-1-1. That will improve the safety and life emergency situations. We're suggesting the re-examination and possible overhaul of Text-with-9-1-1 system. Some ideas are: remove the voice requirement for 9-1-1 access via texting and the App, the 9-1-1-to-app; texting delay issues need to be addressed with re-examination of Text-with-9-1-1 system; public education and awareness; Text9-1-1 strategy needs to be more in plan and has to have more of our community involved.
4666 And the -- in December, the Telecom Regulatory Policy TRP 2016-496 for last -- in December 21st of 2016, resolves about the data plans, but voice issues still remain and need to be addressed with 9-1-1 in this proceeding. And that's why we're here.
4667 We want to thank you for inviting us here and allowing us to present. We appreciate your time and attention to the issues presented by our committee and our group, and we want to leave you with this final quote: "Accessibility must be a first thought, not an afterthought." And that comes from Tom Wheeler, the FCC Chairman.
4668 And we want to see the CRTC undertake that same thought and feeling and bring that to the work we're doing here. Just like Frank said, "Nothing about us without us." Thank you very much.
4669 THE CHAIRMAN: Thank you very much. I'll put you in the hands of Vice-Chair Menzies for a few questions.
4670 COMMISSIONER MENZIES: Thank you. I get that it's frustrating trying to communicate through some of these channels, and I'm frustrated too because I know many of our staff who have bent over backwards in recent years to do everything they can to bring better service for your community. I know Commissioners who have stuck their necks out and I know we worked very hard to do -- to get the Text-to-9-1-1 launched -- considerable nagging, given our jurisdictional limitations.
4671 And we're working hard on this. And this is about building a network or making decisions about the nature of a network that will support further enhanced services.
4672 And you’ve been very clear in a number of areas why you're frustrated. My frustration -- and maybe you can help me with this -- comes from the fact that it's been now three years since the Text-to-9-1-1 was made available to the PSAPs to access, and in most areas it's now available. And it's been two and a half years since we had the hearing on VRS and it launched this past September.
4673 And through all of that, from the number -- going back to our previous conversation this morning -- the number of people who sign in Canada is 35,000. We have just around 3,000 people registered to access these services. To put that in context, the budget for VRS, which they are not completely consuming at this stage, is $30 million a year, which is $10,000 per every subscriber at this stage. And that's disappointing, primarily because we wanted to provide a service for people and one which they appear to be unaware of.
4674 So help me understand why that has happened, why there's been that much push for these services and yet there's been such an obviously poor job done in making -- in getting folks to sign up for those services and access them. Either we have all failed -- you and us -- in this, or there's not the demand that we've been talking about.
4675 So help me understand that, because until we -- there's no point, really, in talking -- well, there's some point -- but if we can talk about all the future services we want, we're not -- it doesn’t matter unless those services are connecting with the people who need them. So help me understand that.
4676 MS. ANDERSON-KELLETT (by interpretation): Again, I can't comment on that question. I'll refer -- defer to Frank and Jeff.
4677 So Frank?
4678 MR. FOLIN (by interpretation): As far as I know -- and my understanding of video relay service -- it opened about four months ago, September of 2016 -- it's just begun. So 3,000 users are on the system now. I think that a year from now we may be seeing a very different number, and we'll see an increase to that.
4679 When we talk about the Canadian administrator of the video relay service, CAV, they have not yet begun their public outreach and educational program, and that comes back to the CRTC -- sorry, just one moment for the interpreter -- 2014-147, which mandated public education, and that is up to the Canadian administration of video relay service to do that. And as far as I know, they have not hired someone yet to do that.
4680 There was a job posting looking for community outreach position that would take responsibility to do that. We hope that that would be in place soon and then there'll be workshops in training in communication made to the deaf community across Canada. And with that in place, I believe you'll see a huge increase into your numbers.
4681 So the comment that we failed, I think is premature. I think that the service has just begun and I think that a year from now we'll look back and possibly see an increase in the number and we may be surprised at the increase. We all will be, but I think a big piece is missing that the outreach has not yet begun.
4682 MR. BEATTY (by interpretation): And I'd like to add to Frank's comments in terms of the experience that I had in -- it's kind of like déjà vu, déjà vu, if you will, in the United States when VRS was first implemented in the year 2000. It had a similar beginning to what we're doing here in Canada. There wasn’t a lot of outreach, a lot of information made available in accessible formats to the deaf community. They weren't aware that it was available or how to use it.
4683 In the first three, four months of Canadian VRS, it kind of feels like the American experience. The more awareness, the more training, the more access to the services, deaf people will register and use it. There are still -- seniors too, a lot of seniors are not comfortable using technology. A lot of them haven't even started using it.
4684 For myself, the seniors that I interact with, they weren't interested in using VRS, but as soon as I showed them that they could use it on their iPad -- but they couldn't see it on the iPad, so what I had to do was hook it up to an Apple television, for example, with a larger screen, and when they saw that they could see the interpreter very clearly that way, they started changing their mind about using it, because at first, they thought it wouldn't be accessible to them. They weren't comfortable using it.
4685 The point here, I guess, is that the deaf public has not been exposed enough yet to what VRS can do, what it will do, how to you use it; the educational piece is missing. And I think -- I just want -- we’re just at the beginning of video relay service.
4686 I think that more users will come onto the system ---
4687 COMMISSIONER MENZIES: Thanks. The -- I don’t want to belabour the point but to the extent that everyone can do something, whether it’s Text-to-9-1-1 or VRS, and not wait for VRS to try to handle it themselves, that would be useful.
4688 We had -- for instance, December 1st was Text-to-9-1-1 awareness day in which the CRTC did its bit to join in and try to raise that. It would be great to see those websites and other communications platforms that might be used by members of the deaf and hard-of-hearing communities to push awareness of that as well.
4689 I checked some of the websites, the Canadian Association -- and there may be there others better. And I apologize; I don’t to -- if there are and I’m sweeping them all together -- but the Canadian Association for the Deaf, there was nothing apparent or direct links. I did find under “Telecommunications” a phone number that I could call. Media Access, I didn’t see much.
4690 The Canadian Hearing Society was a little bit better; I did a search -- I could search 9-1-1 and it took me to a link that took me to another link to the textwith911.ca website.
4691 So, as you said, we all need to work together to enhance this.
4692 One of your aims was to clarify -- and this is again a point of frustration in terms of communication that you made regarding the nature of Text-to-9-1-1 and getting all this information clear so that the system doesn’t intimidate people. It may not be as people would most prefer yet, but you do not need a voice plan to call 9-1-1 to trigger the system.
4693 To be able to use the system, you will need to have a text plan and you do need to register. Those may be awkward and inconvenient but they are better than what was before.
4694 And I can assure that if you need clarity on any of those points -- and it’s difficult in a world of social media because rumours run rampant about what things are and they aren’t. Our staff is always available to assist. And participation on the emergency service working groups, or other working groups, is open and available to you.
4695 Just one last question, then. How many Text-to-9-1-1 calls are you aware -- oh, one point of clarity on Text-to-9-1-1, people have mentioned the two minutes, that you may have to wait up to two minutes. There’s a real failure to communicate.
4696 The two minutes is not designed to allow the operator taking the call a leisurly two minutes to take the call. The two minutes is designed so that -- is for the caller. It’s a drop-call point; it’s where you -- if you do not hear back within two minutes, call again because something has gone wrong. Don’t sit there waiting for five or ten minutes to get a text response. Everybody anticipates that you will hear back quicker but the point of it is -- the two minutes -- is that if you don’t get something back within two minutes, you have to call again; it’s the backup parachute to the process, to use that analogy.
4697 Anyway, my last -- my only question, then, on that is, are you aware of any Text-to-9-1-1 calls that have not been successfully handled?
4698 MS. ANDERSON-KELLET (by interpreter): I’m trying to remember all the points that you just made and provide comment.
4699 The first thing, on December 1st we didn’t have any information so we were a little shocked because it was Text-to-9-1-1 awareness day but we didn’t have any information. Someone reached out to Gary at CHS but we were not contacted, our committee, so we were kind of behind; we didn’t -- we weren’t up to date with the news as it went out.
4700 And we are busy responding to some of this proceeding so we have not been able to update all the resources on our website but we intend to, and we will. And we’ll make sure that CAD does that as well.
4701 In terms of Text-with-9-1-1 on the website, there’s two places where it’s explained in sign language where it says you have to dial -- you have to actually dial 9-1-1 and wait for a reply by the PSAP via text. It clearly says that in sign language. And so that’s where the waiting period begins, that two-minute delay where deaf people are confused and waiting for a reply to their call-out -- dial-out to 9-1-1.
4702 COMMISSIONER MENZIES: Sorry, can I just -- I don’t like interrupting. There is not a two-minute delay. There is a two-minute time period within which you should get a response. When you place a call, right, you do have to -- the call initiates a text conversation which will be initiated from the PSAP. And it will ask you for information and you will go back.
4703 There is not a mandatory -- there could be a delay of up to two minutes ---
4704 MS. ANDERSON-KELLET (by interpreter): Right.
4705 COMMISSIONER MENZIES: --- but there is not a two-minute waiting period which most people will experience.
4706 I just -- the reason I want to make that clear is because if people believe that they will have to wait two minutes, that that’s going to be the time that they wait, they will not sign up for this. They will not make the calls and someone may get badly hurt.
4707 So clarity of those points -- I take the point that you don’t like the two -- that there might be two minutes but when people -- when hearing people place calls, sometimes they have to wait, you know, a little bit to get an answer and sometimes there’s delays and that sort of stuff.
4708 So can we please make sure we get the accurate information out to people so that we don’t frighten them away from a system that might save their life?
4709 MS. ANDERSON-KELLET (by interpreter): I want to clarify something. And just let me clarify with Jeff.
4710 Didn’t you find that information somewhere?
4711 MR. BEATTY (by interpreter): Yes. And so Text-with-9-1-1, when it was launched and available, and the procedures and processes were explained, the very first comment says you dial 9-1-1; if you do not receive a response within two minutes, please hang up and redial again.
4712 And so I just want you to understand the position that we’re taking, that it’s a voice call. Like, with a voice call you will call and then someone may take your call and handle your call before you get to who you’re calling. But as a deaf person, because we can’t hear, we want to see what’s going on. And right now, with that process, we don’t see that someone has answered our call. That’s the point that we’re trying to make.
4713 COMMISSIONER MENZIES: I understand. And it’s the text that comes back to you that you should see that you will know that your call is answered, right? That’s where that gets ---
4714 MR. BEATTY (by interpreter): Right, but, I guess, like, do you have ---
4715 COMMISSIONER MENZIES: I mean I get -- I understand -- don’t get me wrong; I understand that there might be some frustration with the system, but it is the system as it stands and it’s -- and it will get better. But I just want to make sure that we are using the right set of information so that people do use it when they need to and people do get registered for it because if we -- if all the information people get is that it’s hard and it’s confusing, and it’s not fair, and it’s this and it’s not that, it’s not going to encourage people to sign up for it. And I think we all want to make sure that even if -- even if it’s like TTY that everybody hates but nobody wants to get rid of, or it’s like any other of these systems that are frustrating, it’s important that we don’t let our frustrations do us harm.
4716 Anyway, the question was are you aware of a Text-to-9-1-1 call or engagement that has not succeeded to date?
4717 MS. ANDERSON-KELLET (by interpretation): There are several comments within our report from our survey, a lot of personal stories about when work -- Text-to-9-1-1 did not work, either through Text-to-9-1-1, IP relay, TTY, all of the various -- we asked with all the communication available, technologies available, when did it -- didn’t happen? You can find those examples on page 123 of our report.
4718 And we got some information from Rogers’ website. It says you must keep your voice plan of your call connected to ensure that the 9-1-1 operator can send first responders on the way. And this is where the information gets confusing.
4719 And so Frank, I think, has been wanting to say something here so I’ll let him say something.
4720 MR. FOLINO (by interpretation): Yes, I do. It’s related to what Lisa just said. There is a lot of confusion, a lot of the confusion happening within the deaf community. Maybe the PSAPs are also confused. Maybe the CWTA is also confused. I don’t know what exactly happened.
4721 But I think the first step is to try and work this out in the form of a meeting and try and pinpoint where the confusion is stemming from. And once we identify that, then we can work on the solutions to reduce the confusion and work on making sure that people understand correctly what it is across the country.
4722 And the second point, during this presentation we mentioned the website that showed four different video clips -- one that was making a description about 9-1-1, Text-to-9-1-1 via images and pictures; then there was an ASL standalone video that was separate from that text. A lot of the deaf individuals didn’t look at the first one, the images with the texts. They just went straight to what was available in sign language. And that rings true for both ASL and LSQ.
4723 So the deaf users, ASL and LSQ, looked to the information in their first language, not to the image with text, to describe the process. And because the information is not collated, per se, I recommend that we develop a blended video of the ASL and the images and include text and make one video so we ensure that people are getting all of the information in the first language that they want, but also with the added descriptors via the images and other identifiers that currently are being used now that are not being viewed by the community. And this way we might get more attention to it.
4724 Elections Canada, the model that they have used is that blended approach within a movie, video format that ensures full access to the deaf and hard of hearing community because it includes captioning, deaf-blind, intellectual disabilities -- various disabilities within our community are able to access the information by utilizing a blended approach with image, text, and ASL or other -- LSQ. So I would encourage everyone to look at that. I think that’s where some of the confusions stem from.
4725 COMMISSIONER MENZIES: Okay, thank you very much.
4726 MS. ANDERSON-KELLET (by interpretation): Can I add one last point?
4727 COMMISSIONER MENZIES: Sure.
4728 MS. ADERSON-KELLET (by interpretation): We do encourage people to register for TEXT with 9-1-1. I want to emphasize that we are doing that. But at the same time, we’re getting feedback from our community. And that’s why we’re just giving you the feedback that we’re receiving. We are actively reaching out to our community and encouraging them to do that. We are not encouraging them not to register. We are doing quite the opposite. So I wanted to make sure that you were aware that we are working very hard.
4729 COMMISSIONER MENZIES: Okay. Thank you very much and you do not need to have a voice plan to call 9-1-1. Thank you.
4730 THE CHAIRMAN: Thank you very much. Certainly your experience with the current 9-1-1 system is informative as we look at what the key issues are before us in this proceeding. And that is the next-generation 9-1-1. So thank you very much before having participated in this proceeding.
4731 Those are all our questions from the Panel today. Thank you.
4732 MS. ANDERSON-KELLET (by interpretation): Thank you for having us.
4733 MR. FOLINO (by interpretation): Yes, thank you.
4734 MR. BEATTY (by interpretation): Thank you.
4735 THE CHAIRMAN: Thank you.
4736 So we’ll take just a short five-minute break just to set up the last intervenor before the mid-day break. Thank you.
--- Upon recessing at 12:18 p.m.
--- Upon resuming at 12:24 p.m.
4737 MS. ROY: Please take your seats.
4738 THE CHAIRMAN: Order, please. A l’ordre s’il vous plaît.
4739 Madam la secrétaire?
4740 MS. ROY: Thank you.
4741 We will now hear the presentation from CNIB. Please introduce yourself and your colleagues and you have 15 minutes for your presentation.
4742 MR. GRECO: Good afternoon. My name is Lui Greco; I’m the National Manager of Advocacy with CNIB. To my right is Janine Tucker, who manages our Emergency Services Deaf-Blind Program for Ontario. To her right is Jane Sayer, accompanied by her intervenors, Ms. Shaina Dumont and Ms. Tania MacNeil. Thank you for the opportunity to present and Ms. Tucker will begin our presentation.
4744 MS. TUCKER: Hello. CNIB would like to thank the CRTC for this opportunity to share our perspective on the future of next-generation 9-1-1 as it relates to the needs of people who are deaf-blind.
4745 First, my colleagues and I would like to show you just a very short video clip taken from a training DVD that CNIB developed in order to educate first responders about CNIB’s Emergency Intervenor Service. So if we could just show that short video clip now that would be great.
4746 (VIDEO PRESENTATION)
4747 MS. TUCKER: Okay, so this short video sort of demonstrates a few key things that we'll be talking about today. The first thing was just the limited amount of information this lady was able to provide to 9-1-1 because she had to do just a voice call and say "Help." She wouldn't have known when the operator was answering the phone, so she just would have to keep speaking and keep the phone live so that someone could find her.
4748 So it became a cold call, and so by default, two police officers showed up because they had no idea what the emergency was, what to anticipate, and no idea that this lady was deaf-blind. So that whole process of them trying to figure out that she's deaf-blind and how to communicate, that just takes away time from the actual emergency setting.
4749 So it's fortunate for this lady that she does carry her technology with her and she was able to then instantly sort of communicate with text, because the police officer had a cell phone and was willing to text with her to get information. But in a lot of cases, a deaf-blind person may not have their technology with them and so this communication would have halted if she didn’t have her Braille display and the police officer didn’t have a cell phone to text with her. In this instance, the intervention -- the intervenor was key for her to communicate with the police officers.
4750 For someone who's deaf-blind -- which really does mean that they're both deaf and blind -- in my career, so many people, when I say the word "deaf-blind", I think that they understand that it means both, but unfortunately, some people think it's one or the other. But people -- we're referring to people who are both deaf and blind.
4751 Real communication options are extremely limited, so every day people who are deaf-blind struggle to communicate with others and to access information. Every interaction, whether it be with a person, an object, or with technology, can be fraught with difficulty. And Ms. Sayer will elaborate on this a little bit further in a minute.
4752 So how does someone who is deaf-blind communicate and access information? Most people, very innocently, are not aware of how -- what accommodations are needed. If they've never met a deaf-blind person they wouldn't have any idea, and we understand that.
4753 We have a few possible ideas or solutions we'd like to propose to the CRTC which we feel would positively impact Canadians who are deaf-blind when they need to access 9-1-1.
4754 The first is the establishment of a user profile which would be linked with a subscriber whether it be a landline or their cell phone. And this user profile would allow the 9-1-1 operator to immediately know that the caller is deaf-blind, the communication method used by the person -- for example, if it's Tactile American sign language, as my colleague, Ms. Sayer is using right now with her intervenors.
4755 The 9-1-1 operator would know immediately who to contact to request an intervenor or an interpreter to come and facilitate communication, because in a lot of cases, there's no communication without that professional person being there to relay the information; also, information on how first responders could try to communicate in the meantime. Maybe they can write large-print notes, or maybe they can write print and palm so the 9-1-1 operator could relay that to the first responder just to facilitate that person getting help right away.
4756 By having a user profile, the 9-1-1 operator can immediately relay this information to the emergency service. The 9-1-1 operator could also initiate a call to the intervenor interpreting agency, as I mentioned. And this is important because communication otherwise is severely limited, and intervention services is required immediately.
4757 The second solution we'd like to propose is the establishment of some type of basic communication using the telephone keypad as a way of communicating. Specifically, I'm thinking if TTYs were phased out, if somebody was calling from their landline and they couldn't speak and they couldn't hear, they can't tell the 9-1-1 operator what services they want.
4758 So even if it's just that basic, that they could push 1 to indicate ambulance, 2 to indicate fire, and 3 to indicate police, and those words being in alphabetical order so it's easy for someone to remember, at least that way, they can say what service is required so that let's say in the video she really needed an ambulance but two police officers arrived, then there's another delay in her getting the appropriate help.
4759 We'd also like to stress the importance of having options to contact 9-1-1 in a way that allows information to be expressed. Every Canadian should be able to contact 9-1-1 and express what's wrong and where they are. For people who are deaf-blind, this includes the option of using a TTY. Some people who are deaf-blind only have a landline because cell phones may be too expensive, so it -- the more options the better, and as I think one of the other presenters said that a lack of options is not good. We need to have different options to communicate with 9-1-1.
4760 If the CRTC discontinues TTY access, please allow sufficient time for people to determine an alternate way to communicate with 9-1-1.
4761 Text-9-1-1 is a valuable resource for those deaf-blind individuals who can access it, and we want to thank all those involved in getting this service established so far. It would be beneficial to have more outreach in the deaf-blind community to inform them that the service exists and how it works, because it is confusing, as was mentioned with some of the other consumer groups.
4762 And with that, I'd like to turn it over to Jane Sayer.
4763 MS. SAYER: Thank you very much for inviting us today. I'd like to thank CNIB and the CRTC. It's 2017 and finally we’ve got some deaf-blind people here presenting. Thank you; it’s inclusive.
4764 I am a person with Usher's Syndrome, and that means I acquired deaf-blindness over a period of time. There's many different types of Usher's Syndrome, and it used to be said that it was the main cause of deaf-blindness. But with the aging population, they are overtaking us, and they'd be taking away from our number 1 status.
4765 I went blind -- lost my remaining vision a little over four years ago. If I thought having very limited vision was a bit of a stuggle, you are -- there's nothing can prepare you for losing all your vision and all these thoughts, what am I going to do if there's an emergency? And so honestly, it's a very challenging world out there -- I want you to know that -- without communication and vision.
4766 One of our main -- I do wear a hearing aid and I am oral. My hearing aid only picks up environmental sounds, so it doesn’t help me to communicate with you. And they're sort of picky about which environmental sounds that they'll pick up.
4767 As an example, it picks up my -- I can hear my phone ring, so I have four phones in my apartment because I can hear that. But I couldn't hear the fire alarm. Fire alarm sirens are too high pitched. Thankfully, the management in my apartment block changed the fire alarm to ring so it rang on my telephone, alarm (inaudible) then the fire alarm beeped. So now I know when there's the fire alarm in my apartment block, but reality is that only works when I have my hearing aid on. Once I have my hearing aid off, I don’t hear that at all, which is all night.
4768 I also wanted to bring up the fact that gone are the days when people go deaf-blind -- gone are the days you put us in personal care homes. We -- I live independently in my own home and I know people wondered what I was going to do when I finally went totally deaf-blind. But I said, "What do you mean, what I'm going to do? I'm going to keep living here."
4769 Life goes on. But it's only possible with the proper services. In Manitoba, which is where I am from, we have intervenor services and it’s so important. I have two intervenors here that made this meeting accessible to me today, which thank you.
4770 Anyways, so I feel 9-1-1 is also a very essential service and without the intervenor service, though, to help us communicate with the 9-1-1 first responders, life could be very challenging.
4771 I’d like to strongly recommend that -- Janine gave you two strategies. And the deaf-blind community that I -- I used to be the coordinator of the Resource Centre for Manitobans who are Deaf-Blind and I joined CNSDB and I’m very much part of the deaf-blind community. Everybody I talk to, we all strongly believe, the majority believe, in the “KISS” -- keep it simple.
4772 Janine has described to you very -- a simple two things, a profile and a touch pad where we can tell what emergency we need.
4773 My experience with technology is I don’t have -- I’m a pretty technology-illiterate person. All I want it to do is work for me. And over the years technology has changed and it hasn’t always been for the better for the deaf-blind person. For example, do you remember when we all had Blackberrys? I still have mine, a little tactile screen, a tactile keyboard. It’s so easy to type on. Then everybody decided to be like Apple and iPhone and have a flat screen and you can’t feel anything but a flat piece of whatever the heck it is. And well, you can’t find an “a” from whatever.
4774 So then people said, “Oh, that’s okay. You can just go out and buy a Bluetooth keyboard and you can have your keyboard.”
4775 “Oh, okay.” But only certain (inaudible) keyboards are (inaudible).
4776 “You have to find a certain company that sells a tactile keyboard and pay for that.”
4777 “Oh, okay.” So then I go blind, and they say, “Oh, now you can get a Bluetooth Braille display; you need Braille. You need that.”
4778 Do you have any idea how much these things cost? Most of the deaf-blind community can’t afford it. I’m from Manitoba. We do not have an assistive devices program in my laptop unlike many provinces do. So actually you can talk about technology until the cows come home, but if we can’t afford it it’s not going to be much help. And if you don’t understand it it can’t be much help.
4779 I wanted to also talk about the issue of TTYs. Before I went blind I used a TTY. Why? I could use voice carry over. Texting rules in Manitoba stated, “No texting slang. No abbreviations. And be clear.”
4780 I thought, “Well, you know, I think if I phone 9-1-1 I could very least say ‘ambulance’ a lot faster than I can type it without spelling errors or any slang.”
4781 But I’m also worried if I spoke then the 9-1-1 operator would think, “Oh, she can talk; she can hear.” So many people think that, if I can talk I can hear. And that is not the reality. I’m very profoundly deaf. In fact, somebody said I’m probably deafer than most of the deaf community. But I speak.
4782 Anyways, again I want to -- I think I made my major points. I don’t think you should get rid of TTYs. I think they should be expanded upon. I was thinking along the lines of, “Oh, (inaudible) I used want to want to -- if I could retain my vision I wanted real-time captioning instead of this operator typing things to me.” But now I’m feeling that since I’m blind I better be careful what I ask for because that’s probably not accessible in Braille.
4783 Your websites that you put up every -- I used to always run everything in closed caption. Now that I can’t see videos I can’t see closed captions. They’re embedded into the video so I can’t see it. And I can’t see feel it. So all those videos are inaccessible to me.
4784 And I will say CBC is a wonderful TV station and radio station because they provide transcripts. And I wish there was more transcripts. You talk about all these websites that -- all this morning I’ve been hearing about if you go to “www” -- well, if those websites aren’t accessible what’s the point of even going there?
4785 So anyways, once again I really appreciate finally you having deaf-blind people here to talk for ourselves; we can do that. And thank you for just hearing me out and thank you CNIB for including us.
4786 MR. GRECO: Thank you, Jane.
4787 Oh boy. The challenge facing the Commission today is not an easy one. You’ve got to migrate the regulatory landscape or framework in such a way that it keeps pace with the shifting technological realities -- not an easy task -- and we hope in such a way that it doesn’t continue to marginalize people with disabilities.
4788 I’ve sat here before and I’ve shared with your colleagues, if not some of you -- I can’t remember who was here -- but what makes this extremely difficult is that there’s no one-size-fits-all solution for people with disabilities. When CNIB presented on these hearings on CCTS last fall, we hopefully made that clear.
4789 We’re at a perfect storm as far as the regulatory landscape both internationally and domestically.
4790 The CRTC has already -- has issued many decisions, policies, which we’re extremely grateful for, that clearly state the need for accessibility to be part of Canada’s telecommunications landscape. Specifically, 2009-430, paragraphs 28 to 38 talks specifically about emergency services and their need to be accessible to people with disabilities.
4791 I guess all I can say to that is “thank you”. It’s a start. I think much has happened. Much more needs to happen but there are other similar-type decisions and orders that reinforce that and we hope to see more.
4792 Other regulatory or legal frameworks that we have to bear in mind? In 2010 Canada ratified the United Nations Charter of Rights on Persons with Disabilities. This is a first of its kind international treaty that seeks to provide and promote the rights of persons with disabilities in areas such as information communication technology -- I should have just said “ICT” -- of which Canada’s next-generation 9-1-1 system definitely falls within.
4793 In December, Minister Qualtrough, who we’ve heard about already today for sports and disability, and former Minister Dion, who used to be Minister of International Affairs, announced that Canada intends to accede to the CRPD. Well, like most legal things that doesn’t mean a whole lot to those of us who don’t really get that.
4794 Fortunately I can help us out a little bit by interpreting that. And what that simply means is that once Canada accedes to the treaty, discriminatory issues facing Canadians with disabilities not resolved through our existing regulatory landscape, i.e., the Canadian Human Rights Charters, or perhaps even the various mechanisms in place through the CRTC, that these issues can be brought before an international Committee of the CRPD.
4795 Unfortunately, I’m unclear exactly what that would look like as I don’t think any issues have currently been brought before that body.
4796 Finally, also under the auspices of Minister Qualtrough, as we’ve talked about, as other groups have talked about before, nationwide consultations on federal legislation on accessibility will likely be introduced within the current government’s mandate.
4797 CNIB, along with other disability organizations and Canadians with disabilities, have been active participants in these consultations -- in this consultation process.
4798 We are hopeful that the resulting legislation will bring about more robust legislative changes which will better enable federal regulators such as the CRTC, the CTA, Canadian Transportation Agency, and Canadian Human Rights Commission, to better mitigate accessibility barriers which continue to marginalize an estimated 4.3 million Canadians.
4799 I realize that that’s the same number that’s been quotes by other organizations, but statistics are funny things, as we all know.
4800 In conclusion, on behalf of my colleagues, Ms. Tucker and Ms. Sayer, as well as our intervenors, along with our respective organizations, we would like to thank the Commission for the opportunity to bring our prospective and share possible solutions for an inclusive next-generation 9-1-1 system.
4801 While we are not able to provide the CRTC with a complete solution to the challenges we have referred to above, we would encourage the Commission and its relevant bodies, such as the emergency services working group, as well as TSPs, to actively engage the community of Canadians who are deaf-blind and other disabilities.
4802 While the theme of consultation is persistent throughout many of the Commission’s decisions, we regretfully have not witnessed dialogues with stakeholders such as TSPs or broadcasters that have, to the extent we feel would feel would be necessary in order to eliminate some of barriers that we continue to face.
4803 So thank you for the opportunity to speak with you today.
4804 THE CHAIRMAN: Well, thank you very much for your presentation and your presence here today. And while we understand that the community often wants more and better, it’s nice sometimes to hear that there’s a recognition that we have, in good faith, tried to do better in the past. So I appreciate it.
4805 Commissioner Vennard may have a few questions for you.
4806 COMMISSIONER VENNARD: Thank you for coming to talk to us today. And I’d like to thank Ms. Sayer for taking the time to give us a glimpse into the type of communication-world that she lives in and tries to navigate on a daily basis. So please thank her on our behalf.
4807 I have just one question, and it’s actually just an invitation for somebody to comment, and anybody or all of you, if you like.
4808 In your intervention, you proposed adding a disability lens to the regulatory and design phases of next-generation 9-1-1. Can you elaborate on this concept of a disability lens? Who would develop such a lens, or does one already exist?
4809 MR. GRECO: I think I’ll start, seeing as I’m the one who wrote that.
4810 COMMISSIONER VENNARD: Okay, a good place to start.
4811 MR. GRECO: Yeah. It was a long time ago, though, several months ago.
4812 A disability lens does exist. There’s all kinds of public policy against which disability lenses are applied. In lay terms, simply, what that means is a consultative process so that solutions and problems aren’t addressed in absence of persons with disabilities and then the solution is brought -- a solution is brought forward and saying, “Here you go.”
4813 We, and other groups that you’ve heard from today, have talked about the need for consultation. As I’ve said, unfortunately, the consultation process within the telecom industry, and other industries within this country -- regulated industries -- has not been as robust as we’d like.
4814 But if we can address that in a meaningful way, where my colleagues and our peers across the country are active participants in a meaningful way through all phases of addressing systemic barriers, I think the end result may not be Utopia, but I think it will be far better than what we’ve done so far as a society in not including the voice of a population that’s bigger than the Prairie provinces.
4815 COMMISSIONER VENNARD: Okay. Well, thank you very much for that. And I do note that earlier you stated that there’s no one-size-fits-all when it comes to this, so certainly we take note of that.
4816 I have no further questions for you. I don’t know if my colleagues do.
4817 THE CHAIRMAN: Did you want to add something? I saw you reached for the microphone.
4818 MS. TUCKER: Yeah, I just wanted to add -- it’s Janine -- because the deaf-blind community is relatively small and they have a small voice compared to other groups such as the deaf community, and their access to information is so limited, if they have challenges accessing information on the computer, often it’s agencies like the CNIB who have a responsibility to share information with the deaf-blind community, and we definitely want to continue working as a team with all parties, including the CRTC, to advocate and spread awareness about Text-9-1-1 and so on.
4819 I think it’s -- it requires a team approach to educate people and we want to make sure that we have a part in that.
4820 So I know, in my role in coordinating the Emergency Intervenors Service in on Ontario, I’ve met with different first-responder groups to educate about our service, and also with consumer groups, to educate them about Txt-9-1-1. So we’ll continue to do that. Thank you.
4821 COMMISSIONER VENNARD: Thank you very much for that.
4822 THE CHAIRMAN: Thank you. I believe those are all our questions. You’ve been eloquent in your words and in your participation, so thank you very much for this.
4823 We will now adjourn for the lunch break until two o’clock. Thank you.
--- Upon recessing at 12:56 p.m.
--- Upon resuming at 2:02 p.m.
4824 THE CHAIRMAN: A l’ordre s’il vous plaît. Order, please.
4825 Madam la secrétaire.
4826 MS. ROY: Thank you.
4827 Before we begin with the presentation we would just like to announce that tomorrow morning the hearing will start at 8:30.
4828 We will now hear the presentation from Freedom Mobil Inc. Please introduce yourself and your colleague and you have 20 minutes for your presentation.
4829 MR. ANTECOL: Good afternoon, Mr. Chair, Members of the Commission. My name is Ed Antecol and I am the I am the VP Regulatory and Carrier Relations for Freedom Mobile. With me today is Magued Sorial, VP of Core Network at Freedom Mobile and Monica Song of Dentons Canada LLP, external counsel. We are pleased to be here today to provide Freedom Mobile’s views on the Canadian telecommunications industry’s migration to a next-generation 9-1-1 system.
4830 At the end of our presentation we have a short video clip from YouTube. It’s a next-generation type of 9-1-1-App that we refer to in one of our interrogatory responses earlier on. We will be presenting that, time permitting, merely to get people a little bit excited about the potential for next-generation 911 and what it could potentially -- how it could potentially help in an emergency situation.
4831 Freedom Mobile noted Commissioner MacDonald's question on Monday regarding the fact that Shaw and Freedom Mobile have intervened separately in this proceeding.
4832 Freedom Mobile supports and is aligned with Shaw’s submissions in this proceeding. At the same time, Freedom Mobile considers that there are unique considerations particular to wireless carriers that the Commission and stakeholders must not lose sight of in the design, sequencing, and implementation of the NG9-1-1 system. After all, many of the new, feature-rich communications that Canadians expect to be able to transmit have been developed for and will either launch exclusively on wireless networks or before they are available on wire line networks.
4833 Take, for example, Real-Time Text or RTT. RTT was developed as a replacement to TTY over VoLTE networks. TTY is not used extensively over wireless networks and it requires that users carry a second TTY mobile device that they plug into their mobile handset. Furthermore, TTY tones are generally not processed well over wireless IP networks. For these reasons, a new capability -- RTT -- has been developed to enable both voice calling and real-time texting over the same mobile voice connection.
4834 We understand that all of the large wireless operators in the U.S. are committed to RTT. For this service to work in the 9-1-1 context, the PSAP must be NG9-1-1 capable. At that point, the user will make a 9-1-1 call and then open a text window and can start Real-Time Texting to the 9-1-1 operator. And location information will come to the PSAP the same way it will to a voice call and the operator will be able to do in-call or in-text session location updates the same as they can do today on a voice call to 9-1-1.
4835 At the outset, Freedom Mobile would like to fully endorse the position already expressed by the Commission in the Notice of Consultation that:
4836 “Effective access to emergency services in Canada is critical to the health and safety of Canadians, and is an important part of ensuring that Canadians have access to a world-class communication system”.
4837 When the NG9-1-1 is in place, as noted in the Notice of Consultation:
4838 “Citizens could stream video from an emergency incident, send photos of an accident damage or a fleeing suspect, and send personal medical information, which could greatly aid emergency responders.”
4839 Our customers look south to the U.S. where NG9-1-1 is further along, and they have similar expectations from their Canadian wireless service providers.
4840 Most Canadians have enhanced E9-1-1 services so that the 9-1-1 operator is automatically provided with the caller’s phone number and address or location. Most Canadians with hearing or speech impairments now also have access to Text-with-9-1-1. The 9-1-1 system is very reliable and provides emergency assistance to the more than one million Canadians each year who call upon it.
4841 We cannot, however, rest on our past collective successes. We must now look to the future and bring even better emergency service capabilities to market.
4842 The wireless industry has already developed standard modules and features for LTE/IMS-ready wireless networks to enable NG9-1-1 services, including the transmission of feature-rich multimedia. We are confident that Freedom Mobile’s LTE/IMS network will be ready to deliver NG9-1-1 services as soon as (1) there is an operational ESInet with an agreed-to set of Canada-specific NENA i3 options; and (2) there is a sufficient group of NG9-1-1 capable PSAPs such that NG9-1-1 can be safely enabled in a region.
4843 Similarly, some wireless handsets may one day offer better indoor location services that rely on terrestrial beacons rather than GPS satellites for location information.
4844 Legacy POT lines may never be able to offer multimedia NG9-1-1 features. Thus, we are going to have to adapt to a world where certain types of network accesses will provide a richer 9-1-1 experience than others. Thus, variability in service capabilities may become the new norm.
4845 Whether we like this variability or not, we believe that as multimedia communications becomes the new normal for wireless communications, the public will increasingly demand that such capabilities be extended to 9-1-1 PSAPs.
4846 The Commission now needs to take the next step and set in motion the process to establish an NG9-1-1 system or core in Canada so that Canadians will have access to the best and most efficient next generation emergency services.
4847 One of the threshold issues that the Commission must resolve is to determine who will be responsible for establishing and maintaining the core ESInet databases, servers, application platforms, and transport, otherwise referred to as the “ESInet”.
4848 The other threshold issue is whether there should be a single national ESInet or several large regional ESInets covering one or more provinces with linkages between them. There is also the question of funding of the ESInets and managing the interface with legacy access networks, which may not be able to “speak the protocols” required by an NG9-1-1 PSAP.
4849 Who should provide the ESINets? Several of Canada’s incumbent wire line phone companies have proposed that they should be mandated to provide the ESInets and that wireless carriers, CLECs and Voice over IP providers should pay them to interconnect with the ESInets in the same manner that they pay for TDM-based legacy 9-1-1 service from the ILECs today. They argue that they have always provided access to 9-1-1 services, and that they have always done a good job, and they see no reason to change.
4850 With respect to my colleagues at the ILECs, doing it their way because that is the way it has been done to date is not sufficient for the profound transformation that is contemplated by the transition to NG9-1-1.
4851 It should be noted that since the introduction of competition in telecommunications markets, whenever a new function to ensure the continued or improved interoperability of telecommunications networks was required, this has often been accomplished through an industry-led or mandated consortium empowered to conduct a public tender process. Examples include the Canadian Local Number Portability Consortium, the Canadian Numbering Administrator, and the Canadian Video Relay Services Administrator.
4852 The ESInet would consist of a system to enable full interoperability of telecommunications service provider networks to an important public good service, namely telecommunications access to emergency services provided by PSAPs.
4853 There are other reasons to set up a NG9-1-1 administrator as opposed to an ILEC-centric model. The first is cost. With an administrator, an RFI and RFP process can be set up that will ensure that the ESInet is procured through competitive processes at the best possible price. When multiple suppliers submit bids to a neutral administrator, the administrator can make sure that it obtains all of the functionality it needs at the best price.
4854 Approving monopoly cost models and setting tariffs may be acceptable when there is no alternative. But no economist or policy analyst in the world would suggest that monopoly provision with costing studies leads to lower prices than a competitive process in a competitive environment. It reminds me of the arguments that the ILECs made in the 1980s –- the best, lowest-cost telephone system is a regulated monopoly. There is a reason that we didn’t listen to them then. Competition leads to innovation, increased functionality and lower cost.
4855 Second, an administrator is also important to enable direct participation into the design, cost, maintenance, and upgrading of the system by parties that are paying for that system. Today, Freedom Mobile pays into the 9-1-1 system but has no visibility into how the 9-1-1 access system is set up. We are presented with a bill, the location of the 9-1-1 access tandems we must connect to, and the interface specifications.
4856 Freedom Mobile alone cuts a cheque to the ILECs for access to their monopoly-mandated 9-1-1 access system of more than $1 million a year, with no explanation of how the funds are being used today to maintain and improve the 9-1-1 access system.
4857 Our experience has been dramatically different when working with the Canadian Local Number portability Consortium. There, the administrator works with us to ensure that the solutions that are adopted are efficient and cost-effective for the membership as a whole. We get a seat at the table, adequate disclosure, a vote, and the ability to provide meaningful input. We see no reason why the NG9-1-1 system should be organized any differently.
4858 Of course, if the ILECs really are the best provider at the lowest cost, then they are free to submit a bid to the NG9-1-1 administrator. If the administrator concludes that no one else can do a better job at a better price, the contract will be awarded to one or more ILECs. The ILECs are appearing before you at this proceeding saying that, “We should not have a competitive process because they would win it.” Well, let them prove it.
4859 Third, the ESINet consists of two major cost components: the core databases, servers, routers, and application platforms; and second, the data transport network. The ILECs may be qualified transport providers but they are far from the only choice. Unlike the legacy 9-1-1 system, core functionality in the NG9-1-1 system need not be geographically tied to ILEC-serving territories.
4860 More significantly, relying on the ILECs for the design of the ESINet core may preclude innovative capabilities or may produce a less flexible system than an ESINet procured using the databases and core functionalities of existing providers that have built similar core functions in a number of U.S. ESINets.
4861 Should there be more than one ESINet? Regardless of whether several interconnected regional ESINets or a single national ESINet is created, there should be a single standard set of interconnection requirements and common functions within the ESINets. This is necessary in order for service providers to deploy services nationally and to avoid confusion between elements of the NG9-1-1 system.
4862 Regional ESINets will each have costs for core functionality in their respective networks, but may perhaps attract more competitive bids from various transport suppliers that might not otherwise bid on a larger national network. A national ESINet may have a lower overall cost for core functionality. The final solution will depend on the results of a competitive RFI and RFP process.
4863 And I’m going to turn it over to Monica now.
4864 MS. SONG: Thanks, Ed.
4865 Creation of the NG9-1-1 administrator. The creation of the NG9-1-1 administrator could be mandated pursuant to sections 46.1 to 46.4, and in particular, paragraph section 46.2 of the Telecommunications Act, which authorizes the Commission to delegate to another entity, including one that it creates, any power that it could have exercised pursuant to section 46.1.
4866 Paragraph 46.1(a)(i) authorizes the Commission to administer a database, information, or administrative or operational telecommunications system related to the functioning of telecommunications networks, in this case the ESINets.
4867 Carriers and other network access providers offering outbound 9-1-1 calling capability could be mandated to become members of the NG9-1-1 administrator pursuant to sections 24 and 24.1 of the Act.
4868 In turn, the administrator may organize itself to exercise its delegated functions by procuring and administering contracts, and charging the members a rate to cover the costs associated with the exercise of delegated powers. There is a clear parallel with the CLNPC and the CNAC, which were created under the authority of paragraph 46.1(a)(i) and (ii), respectively.
4869 The NG9-1-1 administrator would develop an annual budget for the ESINet based on information collected in the RFI and RFP processes, and all network access provider members would contribute to the annual budget based on their percentage of total working telephone numbers capable of outbound emergency calling.
4870 ESINet Costs. As stated above, legacy 9-1-1 costs are high. There will be some period of time during which consumers will be paying for the vestiges of the legacy 9-1-1 system as well as for the ramping up of the NG9-1-1 system. As a result, the Commission must look for ways to minimize that burden. In particular, Freedom Mobile would be supportive of calls for a review and adjustment of legacy 9-1-1 costs and tariffs.
4871 The administrator should not cover the cost of any required equipment and facilities on PSAP premises. PSAPs will still need to cover their own costs of upgrading their equipment and servers to NG9-1-1-compatible systems.
4872 Freedom Mobile is not proposing any charges to PSAPs for connectivity between the ESINet and PSAP demarcation points, but this is only because they don’t pay for these circuits today as part of the legacy 9-1-1 system. Ideally, in an NG9-1-1 world, PSAPs could procure their own diverse local transport to the ESINet as part of an ESI sub-net, which also connects local downstream dispatch centres, such as police, fire and EMS responders.
4873 Also, network access service providers would continue to cover the costs of 9-1-1 access within their own network, and for transport to points of interconnection associated with the ESINets.
4874 MR. ANTECOL: I’m going to jump ahead in the presentation a little bit so that we can have some time for the video.
4875 But just I wanted to indicate that assuming the NG9-1-1 implementation is three to five years away, as discussed by some parties on the record of this proceeding, Freedom Mobile may not require a Legacy Network Gateway and other conversion functionality in order to communicate with the NG9-1-1 systems. And that’s because we see the legacy 3G networks phasing out beginning in 2020 or 2021.
4876 If we could cue the video, please?
4877 (VIDEO PRESENTATION)
4878 MR. ANTECOL: Mr. Chair and Members of the Commission, that concludes Freedom Mobile’s remarks and we would be happy to answer any questions that you might have.
4879 THE CHAIRMAN: Thank you very much. I’ll put you in the hands of Commissioner MacDonald.
4880 COMMISSIONER MacDONALD: Good afternoon. Thank you for being here today.
4881 Just before we start -- and I asked a similar question of Shaw earlier in the week and you touched on it in your opening remarks.
4882 I understand the value of having you here because although you’re interconnected with Shaw now you bring more of a focus on, and background in, wireless versus some of the other technologies that Shaw has had in the past. But are there any specific components of Shaw’s intervention or any of the questions that the Panel asked of Shaw earlier in the week that you’re not in total lockstep with?
4883 MR. ANTECOL: Well, I’m not sure I’d -- I mean, we're aligned, but there are differences for wireless, and if I can give you one example, and that is, you asked -- a question was asked of -- in terms of timing, should we get everybody moved over to voice and get the platform -- the voice moved over to the ESInet and to NG9-1-1, and then follow it up with perhaps text and then video?
4884 And one of the things that I would like to point out is that wireless networks, for the most part, and all of the major wireless carriers in Canada either have or will have IMS, which is IP Multimedia Subsystem cores in their network, and they will be ready to do voice and text and video in a single call in a single communication session.
4885 And I have certainly -- we have certainly heard various complaints about Text-with-9-1-1, and it's not new from this hearing -- and so our view is that things like Real-Time Text should be ready to go day 1 when we convert over an NG9-1-1 PSAP and shouldn't wait for a later date.
4886 The only constraint -- and we've said this in our interrogatory response -- the only constraint should be that there needs to be enough PSAPs in the region to safely transition to NG9-1-1, and -- if we're going to do that. And the example I would give you is Toronto. You can't have the Toronto PSAP NG9-1-1 ready and operating in an NG9-1-1 environment and not Brampton and Oakville PSAPs as well, because there'd be a huge amount of confusion in the GTA area, but when you can Text-with-9-1-1 or it's like Text-to-9-1-1, and when you can't.
4887 So the only constraint is that there'd be a sufficient number of PSAPs in a logical region. And then our view is that we should be able to launch other NG9-1-1 services.
4888 And it's -- it was a little concerning to hear some intervenors -- and not Shaw, but other intervenors that say, "Well, we'll build it for voice and then we'll see what else we're going to put on it." And you know, that sort of worries me. I'm worried about losing the potential that NG9-1-1 has to offer.
4889 So I don't know if that fully answers your question.
4890 COMMISSIONER MacDONALD: Yeah, thank you for that clarification, and I'll rely on you when we're going through the presentation if there are areas, questions that I ask that your response perhaps differs slightly or greatly from statements that Shaw made, just to highlight that for the purposes of the record.
4891 But let's start there. You said, you know, that a sufficient number of PSAPs would have to be NG9-1-1 ready before services should be transitioned over or new services launched. Can you help us identify what you think a sufficient number is? Is that a particular number of PSAPs, is it in a given geography, given province? What are your thoughts there?
4892 MR. ANTECOL: It would definitely be a given geography, and a fairly large geography. So it would have to cover overlapping communities of interest. So it would probably have to be an area the size of southwestern Ontario or eastern Ontario. So it would have to be a fairly large region covering a number of different PSAPs.
4893 So all of the PSAPs in, say, southwestern Ontario would have to be plugged into the ESInet and NG9-1-1 ready and at that point, you could start offering not only just plain ordinary voice but other enhanced features. And obviously, the larger the area, the better.
4894 COMMISSIONER MacDONALD: Are there any -- well, I guess, understand that obviously there would have to be public awareness campaigns of some sort put in place to make sure that the public was aware that a given service was available in southwestern Ontario, to use your example, but maybe wasn’t available in northern Ontario or on the prairies or in the Maritimes. Are there any technical safeguards that can be put in place to ensure that it's very clear for the end user that -- I guess, where that geography would be and when I'm outside of that geography that I may not have the ability to log on to the Reporty App that -- for example, that he showcased in the video?
4895 MR. ANTECOL: So -- and I'm -- I don't want to leave the impression that we're favouring -- I mean, there's pros and cons to apps, but in terms of, for instance, Real-Time Text, I guess the voice will always work. I mean, you would have to test and prove out the voice capability with -- of an NG9-1-1 PSAP before you, you know, let the public access that PSAP.
4896 So your fallback protection is your voice, and if you tried -- if you had a cell phone -- and this is wireless-specific -- if you had a cell phone that was riding on a IMS core network, you would be able to make the voice call. That's your safety fallback. And then if you couldn't open the text session, well, you couldn't open the text session, but you'd still have the 9-1-1 communication.
4897 Where the risk is is with the disabled community, because -- so we'll deal with it in two parts. So you enable Real-Time Text on your NG9-1-1 network. If not all the PSAPs have it, well, the person calling will still, you know, won't get a text back from the 9-1-1 station. They won't be able to open up the text communication window, so you still have the voice fallback.
4898 Where the educational challenge is is with the community that depends on the ability to have Real-Time Text, and so it presents a challenge if you can offer it in southwestern Ontario but you can't offer it in the Maritimes. And that's something that the administrator and the Commission would have to look at very closely, deciding when, you know, when to launch and what size area needs to be ready, because you don’t have the safety net of there still being voice if the rest of the features aren't accessible.
4899 But I guess -- I mean, if you have an NG9-1-1 compliant PSAP, it will support Real-Time Text by the time we've rolled our ESInet. All the standard vendors of the PSAP software will, you know, by 2020, will all have that inherently in their user work stations.
4900 COMMISSIONER MacDONALD: Do you see a scenario whereby a new service should potentially not be launched until all of the PSAPs in the country are ready and therefore we can flick the national switch and provide a next-gen service of a particular type across the country?
4901 MR. ANTECOL: Well, I mean, if time wasn’t important, that would be great. But it would really be unfortunate if there were a few lagging PSAPs and you couldn't launch certain services til 2028. So you -- it would really depend on the App or the feature you wanted to enable and where -- you know, where the PSAPs were capable of supporting it.
4902 But again, if the PSAPs build their work stations to the -- and their downstream dispatch centres to the NG9-1-1, the NENA spec, I don't think it really becomes a question of are there enough NG9-1-1 PSAPs in an area to launch the additional service. But yeah, it's going to be a challenge and it would be really unfortunate if a few lagging PSAPs didn’t convert to NG9-1-1 and that kept you from launching new services until 2028.
4903 COMMISSIONER MacDONALD: When you envision launching new services in a particular geography, again, let's say southwestern Ontario, do you envision both the primary and the secondary PSAPs having been upgraded to NG9-1-1?
4904 MR. ANTECOL: The short answer is yes, but let me just elaborate and clarify a couple of things.
4905 The first thing is, even we were confused by the term "secondary PSAP", and so one of the things -- and perhaps this group isn't aware -- but when we connect to the ILECs today, we connect to a primary and a secondary PSAP. So we connect to the Ottawa PSAP through Bell's 9-1-1 tandem. And we also have a trunk to Kingston, which is the secondary PSAP for Ottawa. And these are the -- they’re both primary answering centres but one backs the other up so that if the Ottawa PSAP goes down, they’ve made arrangements with the Kingston PSAP to take over their primary dispatch centres.
4906 So when we answered interogs early in the proceeding and people used the term “secondary PSAP”. We thought that’s what the Commission was talking about.
4907 But your question, and as it related to NG9-1-1, what they mean by “secondary PSAPs” is downstream dispatch centres. So the initial PSAP would take the emergency call; it would determine that EMS is required; they would send the call to Ottawa EMS. And EMS would do the dispatch of the ambulance to the scene that’s required.
4908 And similarly, if it was for police in Toronto, whether there’s probably 52, 54 different police divisions, they may send it to a centralized police dispatch or they may send it to the dispatch for a particular division. So there might be -- and I really don’t know the architecture in Toronto -- there would be 54 different dispatch -- secondary dispatch centres.
4909 And so I’m assuming your reference to secondary PSAP is with respect to the secondary dispatch.
4910 COMMISSIONER MacDONALD: M’hm.
4911 MR. ANTECOL: And so for next-generation 9-1-1 to deliver its promise of efficiency and an improved response time, this secondary dispatch centres would need to be on the ESInet in their own, sort of, sub-net space. And that’s how you take advantage of the video and the intel, or the picture, or what have you. You call the 9-1-1 -- the primary PSAP; they dispatch police; and then they can then transfer that video that you’re showing on your cell phone to the police of the suspect in the bank of the holdup or to the police that are en route via the police dispatch.
4912 So the primary call-taker is interested in one thing only, and that is, “Do you need police, fire, or ambulance?” And they’re also interested in where you are. And then they turn around and they initiate the dispatch.
4913 But the person heading to the emergency needs, or would, most likely, like a lot more information. Depending on the circumstance, they may want -- you know, if it’s an EMS, they may want some medical information. If it’s police, they may want a suspect picture.
4914 So the only way you’re going to get that information efficiently to them is if the secondary dispatch centres are connected to the ESInet and when that call is transferred to the secondary dispatch that that information can be flowed through because for it to sit at the PSAP centre without them being able to deliver it to the responders really doesn’t do a lot of good.
4915 COMMISSIONER MacDONALD: And those connections from the secondary PSAPs into the ESInet -- who do you envision funding that connection? Should that be the responsibility of the network provider or should that be the responsibility of the PSAP in question?
4916 MR. ANTECOL: We think it should be the responsibility of the community that’s providing the responder services. And it can vary a lot from community to community. I mean a large community may have a large number of secondary dispatch units. They may have a dispatch unit for each police station; or they may have one dispatch for police, and one dispatch for EMS, and one for fire; or they may have it separated in different regions.
4917 So different communities will have a requirement to link their secondary dispatch with primary dispatch and to link to the ESInet and, in some cases, those costs will be very, very large. It may cost a lot to build sophisticated local-data networks within cities. They may have already started building them; some cities may have them. And then other cities may have only minimal requirements for data networks linking all their public response centres.
4918 So to undertake to build an entire ESInet and sub-nets all the way to every level of dispatch, and given how frequently those architectures might change, would be a very, very large project.
4919 And I mean, ideally, you would want to build the core functionality with the databases and the application platforms. The carriers would design their own redundant -- the telecommunications providers would design their own redundant access facilities to the ESInet. And the PSAPS would do the same, although that would be a new burden they don’t have today.
4920 But then -- you know, I wouldn’t go any further than that; it would definitely increase the sophistication and the complexity of trying to build this next-generation 9-1-1 network.
4921 COMMISSIONER MacDONALD: Thank you. That’s very helpful.
4922 With respect the ESI network provider, we heard from Rogers yesterday and they were very much of the viewpoint that is should be one national provider that’s chosen to implement that solution.
4923 You seem -- you leave the door open to, perhaps, several larger ESInets that are interconnected and built to a certain standard across the country. What are your thoughts on which direction we should end up going? Is it critical to have one provider -- “one neck to choke”, is the term that we’ve been using -- or is the real importance on ensuring that it’s built to an exacting standard?
4924 MR. ANTECOL: Well, my first preference is a national ESInet, but I do have some caveats. I mean, first of all, we have to figure out, is the ESInet going to stop at the PSAPs, which means, you know, a fairly small data network? Or is it going to extent down to all the secondary dispatches, which means you need a complicated data network in most metropolitan areas?
4925 So depending on where you draw the boundaries of the ESInet, the project becomes more and more complicated. And then you have to wonder, does a national ESInet make sense at that point or are you better off on regional? I don’t know.
4926 But also, one of the -- there’s going -- as we’ve said in our presentation, there are two main significant cost groups. There’s the guts of the ESInet -- and in that market, there are a number of large providers in the U.S. that -- not a large number, but there are a few that provide the core services for this, for a NENA i3-compliant ESInet, and it’s pretty expensive, and it might be one of the larger cost components of an ESInet.
4927 And then there’s the transport. And the transport, you know, for the most part, could be subject to competitive supply. They’ll probably -- you know, in most markets there’s an ILEC and a cable co who could provide the Ethernet transport to provide the transport portion of the ESInet.
4928 So depending on the licensing conditions of the core, it may make sense for one bidder. But if the licensing costs of the core are not great, in that case, maybe you could license it four times for four different connected ESInets and make up the difference by getting more bidders for the local transport.
4929 As this point I really don’t know what the right answer is and we won’t know until someone starts negotiating with the folks who produce the guts of ESInet, the core systems, to figure out what the licensing costs and licensing conditions are.
4930 I understand from preliminary vendor discussions that there’s a fairly high initial cost to these systems and then they license it per database entry or phone number after that, so one network may make more sense, although there’s been no negotiations; there’s been no competitive tender. So I really can’t say at this point which should be the right answer.
4931 COMMISSIONER MacDONALD: If we remove the cost element for just a moment, because I know that’s the big elephant in the room when we’re talking about the current 9-1-1 system and moving forward to next-gen. But if you had to give a rating to the current 9-1-1 providers as to how they’ve done -- reliability, resiliency of their networks, public confidence in the 9-1-1 system, in general -- how would you rate them on a purely non-cost-related basis?
4932 MR. ANTECOL: Well, I would say that the networks they provide to date have been very reliable. As a wireless carrier per subscriber we produce more 9-1-1 calls than a fixed-line provider and in communities like Toronto Freedom Mobile is responsible for something like 18 percent of the 9-1-1 calls. So we’re a heavy user -- our customer base is a heavy user of the 9-1-1 system and the performance has been very good. And I have absolutely no complaints.
4933 But at the same time, the system was handed to us in saying, “This is the system. This is where you connect. Here is the spec of how you connect. And this is the functionality.” And that’s it. There’s no further insight that we have.
4934 So it’s a black box to us and I’m just worried that, you know -- we have no idea when this system is going to go out of date and when we’re going to have to start migrating users because they can’t maintain these switches anymore. We have no idea when they’re planning to do, you know, a major upgrade of the ALI database. We don’t control or we -- in terms of communicating to us as a customer -- and we spend over $1 million a year buying access to this 9-1-1 system -- there is no communication back to us about as to, you know, what’s happening in this black box.
4935 COMMISSIONER MacDONALD: So then, you know, if we assume lines of communication are open and there’s a competitive bidding process, which is where the whole idea of potential national RFP and consortium comes into play, if the end result of that was still a situation where the ILECs were still providing the service, you’re not morally opposed to that end result?
4936 MR. ANTECOL: No, I’m not. I’m not opposed at all. If they turn out to win an RFP and they’re the provider, that’s great. And hopefully -- I mean, if you adopt out proposal, hopefully the consortium would be contracting with one or more of the ILECs to provide this service and the ILECs would commit to meeting a design spec and a delivery timeline and they would -- you know, and they would be financially accountable to the consortium for that delivery. And therefore we could get ready in lockstep.
4937 As opposed to the alternative where they go, “Well, we’ll do a design. We’ll file a cost study. We’ll build it.” And you know, the amount of information we’ll get about what they plan to build, how they plan to build it, you know, who they’re going to choose for the core system vendor and what options they’re going to choose just in terms of being able to support future services -- that will all be a black box to us.
4938 What we’re going to see is a lot of hash marks on a cost study and a very skimpy description of what it is they’re going to deliver.
4939 So I don’t have a problem with the ILECs being the supplier, but it sure would be nice to, you know, hold them accountable to, you know, produce to a defined spec at a defined cost as opposed to, “Well, let us design it; we’ll tell you how much it costs.”
4940 COMMISSIONER MacDONALD: Now, I want to flip that very same question around the other way. In my experience, obviously cost is one decision point when trying to select a vendor. But oftentimes, a concern on the part of the customer with respect to lost relationship with a trusted provider or loss of subject matter experts that that provider may employ that the users have become dependent upon -- those are also significant bars to making a selection to change your vendor. So would you be concerned if the ILECs were not at the table at the end of the day?
4941 MR. ANTECOL: Well, let me take a first shot. I mean, it’s very easy for a PSAP to say, “Well, you know, one of the advantages of the ILEC is we have this great relationship with them.” But I would be willing to bet that if you made a rule that the PSAPs have to connect to the ESInet and pay for their own connections to the ESInet -- so they have to go and procure diverse, reliable connections to this ESInet -- so if you shrunk down the size of the ESInet, I bet you those same PSAPs that are extolling the virtues of a reliable, trusted partner would put that bid out to tender and see who could supply the best reliable, diverse interconnection in each of their own local markets and would put aside this -- the familiarity and would put it out to an RFP.
4942 So I’m a little sceptical about the -- you know, it’s very easy to say, “Well, we like them and we’re comfortable with them and we’d rather stay with them.” I’m a little sceptical about giving that a lot of weight because if the shoe was on the other foot and they had to acquire a diverse, reliable transport, they would also put it out to RFP.
4943 But at the end of the day, both the RFI and the RFP is going to have to go out with reliability specs and it’s probably going to have to go out with requirements that require trusted network elements from trusted vendors. And so I would be very reluctant -- I mean, no one’s talking about throwing trust, you know, out the window here in the pursuit of the lowest possible price.
4944 COMMISSIONER MacDONALD: You touched on a couple of them; lowest possible price perhaps isn’t always the organization you want to select to provide a service like this. You have price. You mentioned trusted parties. Are there other specific criteria that should be in the RFI, in the RFP that should work their way into the waiting criteria?
4945 MR. ANTECOL: Well, as I said before, one of the major cost components of this ESInet is not the transport, but it’s really the databases and application platforms and servers that are going to form the guts of the ESInet. And what you want to make sure there is that the equipment provider that’s chosen has a track record. So you know, in a process you would rank your vendors according to experience to deliver, track record, and et cetera.
4946 So clearly you would look at the designs that are presented in the RFI or RFP and you would rank them. And you would actually look and see how it was being put together. And if one of the most components was the guts of the ESInet, then you know, the reputation and experience of those suppliers would figure very, very highly in any evaluation process. You wouldn’t choose a vendor who, you know, was planning to build for the first time a NENA i3-compliant ESI core. You know, a vendor like that wouldn’t win.
4947 COMMISSIONER MacDONALD: In your opening remarks today you mentioned, you know, being able to look at multiple competitive bids. Do you have any concern that we may go through this process -- it could be a lengthy process; we’ll discuss that in a minute -- and then we’d end up at the end of the day with just one bid?
4948 And by “we” I mean obviously the national consortium or whoever, the national body that would be doing it.
4949 MR. ANTECOL: So there’s clearly a risk that that could happen. And I think the RFI process is one way to minimize that risk. And one thing you have to carefully consider as well is what is the scope of the ESInet? Is it primarily the core and the limited amount of transport to a few dozen primary PSAPs in a region or is it a sophisticated network that connects, you know, hundreds of secondary PSAPs and complex local data networks and multiple sites where you’ve got battery backup and generators?
4950 So part of it is what is the scope? And if your scope of your ESInet is very, very large, you might only get one bidder because there might only -- you know, and that bidder might be a consortium of all the carriers in Canada that have gotten together in saying, “Well, in this city I can do that” and another vendor is saying, “In this city I could do this local network” and another is saying, “I can do that one.”
4951 And they might team up and you might just end up with one bid. And that could be an unfortunate situation and you’d quickly figure that out hopefully in the RFI process.
4952 So I guess all I can say is the success or failure of the process will in part depend on what you define as the scope of the ESInet.
4953 COMMISSIONER MacDONALD: I had this conversation with Rogers yesterday, and depending on the results that come back from the RFI, the results could be very favourable, the results could not. Do you think if we were to move in the direction of this model that you are proposing that we'd need to also build in some necessary on ramps if we get 6 or 18 months down the road and the writing is on the wall that this new model isn't going to provide the benefits that other -- you and others are suggesting that it could?
4954 MR. ANTECOL: Absolutely, you're going to need off ramps through the process. You're going to need checkpoints before the RFI goes out. You're going to need to have a checkpoint when the responses come in and the RFP is being prepared, and you'll need a final checkpoint when the -- when all the bids come in. But absolutely, throughout the process, you're going to need checkpoints where you decide to go or no go.
4955 COMMISSIONER MacDONALD: With respect to timing -- because many people have suggested that time is of the essence. We want to move to a state of next-generation 9-1-1 as quickly as possible, both because of the benefits that it will provide to Canadians but also so Canadians have supporting -- a legacy and a next-gen service at the same time.
4956 What are your thoughts on if we were to follow your suggestions on how long it would take? We'd need to issue a decision from this hearing; a new national coordination body, consortium, whatever the term is -- would have to be established; members would have to be appointed; governance structure set; RFP drafted and issued. How long are we talking about from a timing perspective there, just on all of the necessary work that would go into creating this new model?
4957 MR. ANTECOL: I think I'm going to agree with the time estimates that Dave Watt put on the record yesterday for Rogers. I think that -- I think we could have a sort of a different Coalition of the Willing -- not the group participating as a party today -- but a Coalition of the Willing who could, you know, have counsel produce a proposal for a consortium and file with the Commission reasonably quickly. The Commission can put it out to comment, hopefully, quickly so that there be broader comment on the nature of the consortium, and that can be put in place.
4958 And perhaps that whole process could be done within six months and then you -- or perhaps this Coalition of the Willing could also start the -- you know, hire a -- I'm going to say hire some professionals, and I'll just throw a name like Deloitte or somebody, but hire a group of professionals who've had experience putting RFIs like this out in the U.S.
4959 And so have an experience so the Coalition of the Willing would hire sort of a consulting-type firm to begin drafting the RFI in parallel with the process to finalize the constating documents of the consortium so when the consortium is finally put in place, they could review the draft of the RFI vote, ask for changes, talk to the consultant, and then put the RFI back to the Commission for signoff fairly quickly after the consortium is formed.
4960 So I think it's possible to sort of -- depending on the ability to form a Coalition of the Willing, you can shave some of the time off on the time estimates that Dave Watt provided.
4961 COMMISSIONER MacDONALD: What are your thoughts on if an RFP were to be issued, what the optimal contract terms would be with respect to timing? You don’t want it so long that the contract can't be effectively adapted on a go-forward basis, but you don’t want it to be -- the timeframe to be so short that the migration is just completed and all of a sudden it's time to issue a new RFP.
4962 MR. ANTECOL: So I'm going to use the CLNCP example. As you know, the guts of all the routing in our Canadian network is -- every carrier, before they route a local call, does a dip to a -- what's called an LSMS. And it says, "This number has been ported. Route to Carrier X, route to Carrier Y, route to Carrier Z."
4963 And we -- Freedom Mobile operates one of those LSMS's and it gets its feed from a central database operated by New Star. And New Star contracts with CLNPC, so -- and we recently had to go out to contract again. The contract that was set up previously came to -- it was coming to an end and so several years before the end of that contract, the CLNPC started another RFP process.
4964 I had the good fortune of participating in that process and meeting with vendors and was part of that decision process. And when our Freedom Mobile really did, you know, benefit from participating. And they selected another vendor.
4965 The -- personally, my view is 10 years is a good timeframe, because it allows a vendor to amortize the start up and development work, and produce overall lower going -- lower costs on a monthly basis. So I'm in favour of a long period, but not like, super long, because, you know, 10 years is actually a lifetime as well in the telecom business, so there's a trade off. But personally, I would see nothing wrong with a 10-year term and 4 or 6 years into it, you begin thinking about what you're going to do for the next 10 years.
4966 COMMISSIONER MacDONALD: So at the end of the 10-year term, you would see a new RFP put on the street that again would be open for providers to respond to?
4967 MR. ANTECOL: Oh, I'd see that RFP going on the street in year 7.
4968 COMMISSIONER MacDONALD: Okay.
4969 MR. ANTECOL: I wouldn't see it going on the street in year 10, because then you'd be stuck with nothing.
4970 COMMISSIONER MacDONALD: I guess what I was -- I take the point you'd want it out on the street so it could be evaluated well in advance of the end of the current contract. You -- but you wouldn't build into that initial contract any type of renewal mechanism? If at the end of 10 years things are working great and people think the costs are still fair, you know, we'll give you another 5 years.
4971 MR. ANTECOL: Well, if I could get away with it, I would put in an option for renewal and extension at my option. But parties, I think, are a little more sophisticated than that, and so if you're the service provider, you might not buy into that idea, only because at the 10-year mark, there's going to be probably some major renewal that's required. There's -- you know, certain equipment only has a certain life and requirements might be different in 10 years. So as a supplier, you might not agree to give the consortium an option to renew it, their sole option, for another five years at the same price. It’s nice to ask for, but I think the business reality might make that ask a bit difficult.
4972 COMMISSIONER MacDONALD: So that touches on a couple of points that I want to dive into. Ten (10) years is a long time. It is an eternity in telecom, to use your words. You know, we can easily see that there may be new forms of technology, new forms of communication, that people want to incorporate into an NG9-1-1 platform at some point in the 10 years. I'd be surprised if there weren't.
4973 How should that be calculated and who should fund those additions over the life of a contract? Should the service provider chosen be able to bill for that and if so, are there any provisions that could be put into such a contract that would ensure that no price gouging was going on, because there'd just be one provider, potentially, that could charge whatever they wanted for the next add-on of the next feature.
4974 MR. ANTECOL: Well, first of all, I agree with you. Today, we're working with the NENA i3 spec. In 10 years we might be working with NENA i27 in a whole different paradigm. So we just don’t know. But I guess I can speak from my experience with a consortium monitoring other vendors.
4975 And so throughout the life of a contract, the -- in the CLNPC world, the vendor would come forward with proposals, with statements of work for new features. And in the U.S. they developed new features as time went along. They develop capabilities for CLECs to share number blocks. So today each CLEC gets their own number block, but when you start to run out of numbers they have provisions for smaller blocks, to subdivision of blocks.
4976 So the vendor or the consortium would -- the consortium would go to Neustar or Neustar would come to the consortium and say, “Here’s a statement of work for some proposed changes and here’s the cost.” They would negotiate back and forth and sometimes they would agree to take a new feature; sometimes they wouldn’t. Sometimes they would compromise on what the feature would look like.
4977 So similarly, you have to have a process when you contract for technology like that, to have evergreening going on at you go along. It may be that the consortium wants a change and they put forward a statement of work to the vendor saying, “This is the feature set we want and, you know, give us a price.” And at the end of the day there would be provision for the price to be paid in terms of -- if you couldn’t agree on the price, there could be provisions that -- it would be based on time and materials.
4978 And similarly, if you’ve got a big experienced U.S vendor of the database and platform, as the U.S. system evolves, that vendor, you know, may want to make changes to their software and application platforms, and they may come back to the consortium saying, “I want to make this change to the system because I don’t want to have four different streams of software that I have to support.”
4979 And the consortium would look at what the vendor is proposing and say, “Yes, we’ll accept that feature in the Canadian system” or, “No, we won’t.” So there may need to be an evergreening, but it may work both ways.
4980 COMMISSIONER MacDONALD: Okay, thank you for that.
4981 With respect to a 10-year contract -- I mean, different equipment has different life spans -- do you see at the end of a 10-year contract there being any residual value in equipment that’s deployed to support this network? And if there is value in that equipment and the facilities are still of use, should they be required to transition to the next provider 10 years down the road?
4982 MR. ANTECOL: Well, for the core components, as opposed to the transport components, the company that’s bidding to supply the core components will probably -- when they do their pricing they’ll probably assume there’s no residual value or they may assume some residual value. But it’s likely not going to fungible or reusable. So I think the pricing you’re going to see is going to be based on the life of the contract.
4983 The transport may well be fungible. So if the ESINet is going to be built with least transport, least GigE circuits and stuff like that, then the carrier supplying them can reuse them for other customers to the extent that they’re -- to the extent -- or at least maybe the last mile might not be fungible, but the rest of it can. Any long haul will certainly be reusable. And so hopefully when they price the cost of the least transport, they will -- if they’re bidding in a competitive environment, will assume a residual value.
4984 COMMISSIONER MacDONALD: Should there be a requirement that if we are talking about the transport layer or the last mile physical access going into a PSAP, that access to those facilities should be mandated to whomever the next provider is?
4985 MR. ANTECOL: It’s certainly something that you should perhaps consider including in the RFP. You know, it’s hard to forecast who the last mile providers are going to be in the next -- in 10 years from now and what technology they may or may not want to use. They may be using new 5G, point-to-point, higher-frequency microwave for connectivity. They may be using completely different types of transport, you know, different -- so I guess most of the transport that we’re talking about is forborne right now.
4986 What we would be buying to build this ESINet presumably would be GigE circuits and perhaps 10-gig circuits in some cross-sections and, you know, maybe 40-gig or 100-gig cross-sections. But it would be Ethernet transport. And today there is no tariff on any of that Ethernet transport.
4987 So both the ILECs and the cable companies, you know, can bid any price they want for this transport. At the end of the day if the winning bidder is unable to secure the transport that they assumed in their bid, they of course would take the risk of having to secure transport at a higher price. And if they couldn’t do that, they would have to do the build, the last mile build.
4988 So yeah, you could have a provision in the RFP that says, you know, any last mile provider that you use for this ESINet has to make that facility available, you know, at the same price or within a certain price range to the next bidder. You can absolutely do that. Whether it takes away from the willingness of parties to bid, I’m not really sure.
4989 COMMISSIONER MacDONALD: Okay, thank you.
4990 What happens if we get into a 10-year contract situation and there are problems with the service provider -- the service is performing poorly; there have been outage situations? Should the consortium have the ability to terminate such a contract?
4991 MR. ANTECOL: So sometimes -- and Monica might be able to talk more about this -- but sometimes in a commercial arrangement having a termination right is a meaningless right because terminating is just not going to make any sense.
4992 So depending on -- well, first of all, you wouldn’t select a vendor without the means and the substance to deliver the critical systems that you need, but realizing there’s different components, right? So if it’s transport failure that’s happening and shouldn’t be happening, if the design was supposed to be redundant and the circuits aren’t redundant and one circuit goes down and they all go down, well, that transport -- the consortium could require the vendor to redesign and reinforce the network that’s being provided.
4993 You can force a supplier to reengineer a circuit. And if they miss performance objectives they could also face financial penalties. So at the end of the day if it was a transport problem, I think it’s fairly easily dealt with in the contract.
4994 The bigger problem, I think, is the databases and application platforms. And I don’t really want to name a particular vendor, but if you went for Vendor X to supply the core systems and it turned out that their system really didn’t work as advertised, well, that’s a bigger problem because you just can’t throw them out and put in another system overnight. So there, I guess, you rely on financial but you also have to be very careful in who you choose to supply the core intelligence.
4995 And I might also note that the ILECs don’t have any experience in building this core intelligence either and I don’t think there’s any Canadian vendors that -- I assume for this ESINet we would look south to a major system vendor to supply the core intelligence.
4996 COMMISSIONER MacDONALD: So do you expect the consortium to obviously review and monitor the service quality? And would you see them making that information public on perhaps an annual or semi-annual basis?
4997 MR. ANTECOL: Well, I think one of the reasons for having a consortium is you then have a legal entity that can do the contracting and monitor the performance. And certainly with CLNPC as a consortium they do monitor Neustar’s performance. And they do more than that. They also do contingency planning with the vendor to, you know, make -- the database is replicated and what would happen if one site went down or what happens if both sites go down? What is the contingency plan?
4998 So monitoring the vendor, yeah, and the vendor’s performance would be one of the key functions of the consortium and one of the more important roles they have to do once the system is in place. In terms of publicly reporting that, I’m indifferent to whether you want the consortium to report to the Commission in confidence or you want it done public. I guess I don’t really have a view on that.
4999 COMMISSIONER MacDONALD: Okay, thank you.
5000 Currently, we’ve set a list of some trust identities that can connect into the 9-1-1 network. How do you see that list of trusted identities changing in a next-generation environment? Do we need a list at all; should it be open to everyone; and what criteria should be put in place?
5001 MR. ANTECOL: So first of all, no entity should be allowed to connect to the -- no telecom service provider entity should be allowed to connect to the ESInet without signing an access agreement. So -- and that access agreement is necessary in order to protect the ESInet and to keep -- you know, protect individual privacy, protect how the ESInet is used, to protect the ESInet from harm that may pass through from the access provider’s network.
5002 So every entity would need an access agreement, and that’s no different today than with the Neustar Database that the industry uses; you sign an agreement to get access to that database. It turns out you have to be a CLEC so the Commission -- and then the consortium has developed over time other types of access agreements for other types of providers.
5003 So I see a similar arrangement where the consortium might develop other kinds of agreements for other kinds of providers. And yes, you’re going to have to change -- absolutely you’re going have to change; you’re not just going to let CLECs and ILECs use this system. Eventually you’re going to have to let monitoring companies and automobile companies or -- and you may have to let application providers like Facebook access the system.
5004 How people communicate, how they use the services, that’s all going to be radically different and you’ll need a flexible approach. And the consortium will periodically have to review their standard-form access agreements, probably get them approved by the Commission, and then allow additional forms of access providers onto the network.
5005 COMMISSIONER MacDONALD: So given that who would want to connect is going to change and evolve over time, are there certain base criteria that should or should not be put into place? Does being a Canadian-owned organization matter for connectivity into the 9-1-1 network. Does currently supporting a minimum level of Canadian subscribers, should that be a criteria?
5006 MR. ANTECOL: Okay. Well, first of all, that last criteria, I wouldn’t agree with. But absolutely there needs to be criteria. I mean, first of all, today, if you’re a service provider and your users don’t have telephone numbers, then question whether you should be accessing the ESInet at this point in time.
5007 So presumably you’re a CLEC or an ILEC today because you’re offering services with phone numbers. If you’re a reseller of a CLEC, well, if you’re riding on the underlying CLECs platform, then you don’t need your own access.
5008 If you’re this -- if you’re sort of a half facilities-based provider and half reseller -- you might see some hybrids there where they sell services that use phone numbers but they only have part of their own network and they use part of someone else’s network -- then you got to think about, well, will they be able to deliver the -- deliver location information that’s required? Will they have a proper border gateway so that the ESInet doesn’t have to put itself -- doesn’t have to open its network up to accommodate itself to system vulnerabilities, I guess?
5009 So it’s hard to -- I mean right now, here on the stand, it’s pretty hard to devise an access agreement, but there’s a lot of things you need to think about including security and capabilities of the provider, and do they have any business delivering information to a 9-1-1 PSAP today.
5010 COMMISSIONER MacDONALD: Okay. I’m going to ask you a question that is difficult to answer. But we’ve asked everyone else so it would just be unfair not to ask you.
5011 Knowing that we don’t exactly know what next-generation 9-1-1 is going to look like, can you put any educated guesstimate on what the cost is going to be? Is it going to be 50 percent more expensive than the current system is today? Is it going to be three times as expensive? I know the more bells and whistles that it has, the greater the costs go up.
5012 MR. ANTECOL: Yeah, and also depending on the scope of how you define ESInet. So if you define ESInet as including local city fibre networks that connect, you know, multiple dispatch centres, well, that’s a very much more complicated network than one that’s sort of bare bones, a core network and 20 or 30 access points. So that kind of network would be significantly less.
5013 If I was guessing, I would say that a data network is cheaper than the TDM network with all the selective routers that exist today with -- by “selective router”, I mean the ILEC 9-1-1 access tandems. I mean those switches and expensive to maintain, and the TDM transport is relatively expensive to maintain.
5014 Could you develop a data network with a series of servers and application platforms that’s cheaper than the selective routers and the ALI database that exists today? Probably.
5015 So if I was guessing, I would say the ESInet, itself, could potentially cost a little bit less than the current TDM-based 9-1-1 network but, again, it depends on how far we’re going to extend the ESInet, and it really is just a guess because I haven’t -- I’d have to see a design and then go out and ask people for pricing in order to come up with a cost estimate.
5016 But just from a technology perspective, data networks should be a lot cheaper then TDM networks and TDM switches.
5017 COMMISSIONER MacDONALD: And what are your thoughts on who should fund this? Should the vendor to provide the network charge a fee to everyone that wants to connect? Should -- you know, in a next-gen environment, you know, I can potentially contact a PSAP without use of traditional telephone line; I can do it over the internet. Or, you know, potentially, even my car could notify a PSAP that I’ve been in a car accident when my airbags deploy. So how do we fund this and where are the different areas that we need to pull those funds from?
5018 MR. ANTECOL: The ESI core, itself, is the glue that binds the carriers and the PSAPs. And, you know, I think 9-1-1 is valuable for the community, but it’s also valuable for the service provider. I think that people would be disinclined to by a service that didn’t provide 9-1-1 access.
5019 I couldn’t imagine trying to sell a cell-phone service without 9-1-1 service capabilities. So it’s valuable to the carrier and their customers and it’s also valuable to the community.
5020 So I don’t have a problem extending the current model mostly because -- for the only reason that we’re experienced with it, and we’re comfortable with it, and we know it. So I don’t have a problem initially basing the funds for the ESInet paid for out of a fee per working telephone number and then modifying that as other service providers come on line.
5021 But to the extent that we start extending the ESInet deep into the cities and integrating them with city functions, at some point it’s really not the carriers that should be paying for that infrastructure that joins all 52 divisions of a police force and all the fire stations. I don't think that the carrier should be paying that, and that should really be the local taxpayers that pay for the police, fire, and ambulance in the first instance.
5022 So again, I don't have a problem with the working telephone number, but I do have a problem with -- if that is being used to fund infrastructure deep into the emergency response network ---
5023 COMMISSIONER MacDONALD: Okay.
5024 MR. ANTECOL: --- of communities.
5025 COMMISSIONER MacDONALD: So starting out, it would be based on per telephone number. As functionality increases, do you see or do you think it would be appropriate for internet service providers to start charging NG9-1-1 fees if they're non-voice providers?
5026 MR. ANTECOL: Well, I don't think so initially. They're not even -- internet service customers won't even be able to access the ---
5027 COMMISSIONER MacDONALD: And I should have -- just to clarify that -- I meant in a future state, where I would not -- you know, if I were the individual calling in, I would not actually place in a traditional telephone call, I'd be connecting to the PSAP through my internet connection as my only link to the outside world.
5028 MR. ANTECOL: Well, you'd have internet providers, but you'd also have Ford and BMW and GM that would have chips in their cars. When the airbags deploy, they perhaps will call -- want to call 9-1-1 and signal their position. So you might have car makers and others.
5029 So you know, over time, the cost model will -- or cost recovery model will have to change, absolutely. How it changes and how it should change, I really don’t -- I really can't say at this point. Maybe it becomes too impractical to start, you know, counting the number of iPads and or Mac addresses or what have you. Maybe those models don’t make any sense in the future, so I guess I -- all I know is the model may have to -- will have to change, but I can't really -- I don't know at this point how it should change.
5030 COMMISSIONER MacDONALD: Okay. With respect to new forms of communication -- and you know, many have suggested that it should be up to the PSAPs, which type of communications that they want to receive -- what are your thoughts on where the focus should be? We touched on it earlier. Some have said that, you know, start with migrating voice services over to IP and after that, everything seems to get a little bit fuzzy and people's opinions seem to differ. Could you explain to me what your thoughts are in that regard?
5031 MR. ANTECOL: Yeah. First of all, I don’t agree with move all the voice services over and then we'll figure out what else. And I don’t agree with that because that will inevitably delay any improvement in 9-1-1 response capabilities for more than a decade. So it's why I don’t agree with that.
5032 I think what you want to do is, you want to first of all, allow wireless carriers, who have built and are building IP multimedia networks to allow users to contact the PSAPs. I think initially, the PSAPs should support voice and they should also support Real-Time Text, which means the user would dial 9-1-1, okay, so the location information would go to the PSAP, the next-generation 9-1-1 PSAP, and the user should be able to open up a text window. So if they cannot speak or -- because they're incapable or because they're in an environment where they don’t want to speak -- they should be able to open up a text window and have a Real-Time text conversation.
5033 So I think the initial launch should be both, recognizing, of course, that the POTS telephone line providers won't be able to offer the Real-Time Text capability but the -- and Magued can speak to this more, but you have an IMS core network. You add a RCS server to your IMS core, and then you enable Real-Time Text features and you're off to the races.
5034 The gating element there is the operating system developers are building the Real-Time tech. Today, it's an app, and the problem with Apps is that very few people will end up downloading them and it will be a bit disappointing.
5035 So what you want to do is, you want to have the Real-Time Text native to the operating system part of the phone's dialler where you, you know, on the dialler there might be a button you can push to open a text window and it would be common across -- you know, there'd be a native capability in Apple's phones and there'd be a native capability in Google phones, in Android phones.
5036 And so that is coming. All the major carriers in the U.S. and the operating system vendors have committed to building native RTT support. So that's going to be around. I think we saw a presentation today where that's going to be around in two years' time. There are -- it's already app-based, but it will be native in the phones in two years' time.
5037 And so by the time we're ready to turn up NG9-1-1 here in Canada, we should plan for a launch of the RTT text at the same time. And that would solve -- well, first of all, it would give users other ways to communicate with the PSAPs, but it might go some way to solving some of the -- not all, but some of the issues that the disabled community has with the current 9-1-1 system.
5038 Magued, do you want to add anything on RTT?
5039 MR. SORIAL: No, just I want to say that if we are building an IMS, which is the IP multimedia system, on top of it, we can add a lot of services. So normally, for example, Voice over WiFi, Voice over LT, as well as RTT. So there are three component devices to be able to have this native app on the OS and IMS and an application server or the application server connected to the IMS. So again, if we have the infrastructure built, we can add to it.
5040 COMMISSIONER MacDONALD: So NG9-1-1 is coming. Thanks to our friends to the south, the capability is going to be enabled in customers' phones. From Freedom's standpoint and also from the standpoint of other Canadian wireless providers, do you see any significant challenges with implementing RTT in Canada, say within the next two to three years?
5041 MR. ANTECOL: Magued's going to answer, but if it's over the next few years, I don’t see a challenge. I think all the pieces will be in place, but the only slight challenge I have is legacy networks. Legacy wireless networks will not have this multimedia capability and I don’t know if we've -- you know, we're not sure whether -- like, you know, we’ll have to explore the gateway capabilities or maybe we'll phase out the legacy networks faster. But that's the only issue I see.
5042 Magued, do you have -- see any impediments to having RTT in place in a couple of years?
5043 MR. SORIAL: No, as long as there is a device that's supported on a native app. This is important, to have a native app. It's not over the top app because over the top is -- we're not controlling it, right? It goes to the internet directly. So it has to be a native dialler and we have to connect to an application server, RTT application server connected to our IMS. So if this is happening next year, that's it. So we can start testing and we can internet.
5044 COMMISSIONER MacDONALD: Thank you. Given that there would be challenges, if not being totally impossible to do it with legacy networks, does that mean that we should perhaps put a sunset date on legacy 9-1-1 networks to help push the entire ecosystem along to next-gen?
5045 MR. ANTECOL: Well, especially if you're worried about user confusion. So you want to get as many NG9-1-1 network PSAPs on the ESInet as quickly as possible because if you've got a holdout and that holdout is part of a larger metropolitan area, you've got a huge user problem, because you'll have people who think they can text to 9-1-1 when, in fact, they cannot.
5046 So you know, you'll have the fallback that the window won’t open in the session, the data session won’t initiate, and they’ll still fall back to voice. But again, that’s not going to help people who are hearing impaired get assistance, et cetera.
5047 You know, one hold out PSAP in one area could hold back NG9-1-1 services for millions of people. So yeah, if you can put a sunset on it -- and I’m not sure the PSAPs would agree to a sunset -- but if you could put a sunset on it I think it would be awesome.
5048 COMMISSIONER MacDONALD: Just a couple of questions with respect to the App and the tie into privacy.
5049 If there was a next-gen 9-1-1 App, it has the potential to store a significant amount of very valuable but very specific and confidential information. It could have information on the individual; it could have past health history, health records, allergies, many different aspects. Do you see such an app as providing value? And if so, does it raise any specific privacy concerns for you?
5050 MR. ANTECOL: So there’s a couple of parts to that question.
5051 The first thing is there’s good apps and there’s bad apps. And in States there’s some PSAPs that are just going absolutely crazy with problems caused by bad apps or apps doing things that aren’t good from a public safety perspective. And there are other apps that are really good.
5052 And I’m happy to talk about some examples if you want, and I know NENA has put out guidelines for app developers to not cause problems with 9-1-1 responders. And then a classic example is the app that not only calls 9-1-1 but sends a text message to your 20 closest friends that you’re in trouble and you need help. And they might be in other cities and they’ll pick up the phone and call 9-1-1 in their cities and those responders, you know, won’t know how to get dispatch on the other side of the country.
5053 So you know, apps can do a lot of bad things and they can do a lot of good things. So that’s the first part.
5054 Now the second part is that some of these apps as a commercial proposition are based on selling your personal information. So they might be free to download but they might track your whereabouts all the time and sell that. So some of the business models of some of the apps, you know, could be suspect and that could create a giant privacy issue.
5055 And then the next thing that I want to point out -- and I’m going to refer to Magued on this -- but as I understand the way our network is being developed, there is an additional data store that’s intrinsic to our network that’s designed to work with a next-generation 9-1-1 PSAP; it’s part of the NENA i3 spec.
5056 So we heard a very compelling example today where if a person is both, you know, deaf and blind and needs special assistance that, you know, the user could potentially enter their special assistance requirements into our addition data store. And that information, using the standard i3 specs and protocols, could be transferred. And then the way it’s done is in the SIP invite message we have a pointer into our data store. So we send that to the PSAP and then the PSAPs can pull it out of our data store based on the pointer that we send.
5057 But I don’t know if you want to talk about that?
5058 MR. SORIAL: Yeah. In fact, we have this. We can store some data information, like the information for a subscriber like health records, some additional information, and give access to the PSAP. If they need to pull this information, they can go and connect to our server and pull this information. So this is available, again, with our next-generation implementation for the 9-1-1.
5059 MR. ANTECOL: It’s a standard part of the NENA i3 specification as built by most wireless carriers in North America. They built it to a spec to the ATIS spec. And having this data store and the PSAPs being able to pull from it is a standard feature. It’s required by the specification. What it doesn’t specify is what information will be in there.
5060 COMMISSIONER MacDONALD: With respect to what information would you think that that should totally be on the onus of the potential end caller to go in and populate that data and by doing such opt in or choose not to and opt out of using the service?
5061 MR. ANTECOL: Not exactly. I agree that the user should decide whether to put stuff in there or not. But in terms of the permissible kinds of information for the user to put in, I would suggest that the PSAP community should be involved in deciding the kinds of information that they might be interested in pulling and then working with the carrier community educating customers as to the availability -- the ability to put information in, what kind of information you can put in, or what information you should put in.
5062 I wouldn’t leave it random that people can put anything they want in. I think what should go in there is useful information as defined by the PSAP and then it’s really up to the customer at that point whether they want to add that useful information or not. And then it’s an education process.
5063 COMMISSIONER MacDONALD: So the PSAPs decide the must-have or nice-to-have information; the wireless service provider potentially selling the iPhone that the app will end up being loaded on inform their customer at the time of purchase; but the I, as the user, it’s totally up to me as to whether I want to share that information or not?
5064 MR. ANTECOL: Correct.
5065 COMMISSIONER MacDONALD: Okay, thank you.
5066 MR. ANTECOL: Oh, sorry. Monica, did you want to -- normally when you buy the phone out of the box it would typically run through a script and prompt you, you know, whether you want to “enable this feature now or later” and if you said “now” it would probably take you through a script that would encourage you to put in the kind of information that would be useful. But you know, it’s a little bit hard to envision yet how we would want to set that up in Canada.
5067 COMMISSIONER MacDONALD: But if that were running through a script potentially on the phone, automatically if that were the case it shouldn’t put much extra burden on you as the service provider at the time of setting up the phone?
5068 MR. ANTECOL: Yeah. That wouldn’t be a big burden. And neither would providing an interface on our customer portal. Today we have a customer portal where the customer can log in and put information in. So it wouldn’t be that big a burden to create another tab in the customer portal when the customer logs into their “My account” to click on the tab and add that information sort of offline as well.
5069 So there’s a number of ways that customers can input their information into the data store.
5070 COMMISSIONER MacDONALD: Just one final question and then I’ll hand you back over to my colleagues. I’m just wondering, in your experience do you have any background in inclusive design that could help provide some guidance on different approaches as to how we may want to design NG9-1-1 to be of maximum benefit to Canadians with disabilities?
5071 MR. ANTECOL: Well, we’re a fairly lean organization so while I don’t have any specific expertise -- we talk to a lot of smart people every day that are involved in designing. We’ve met with operating system developers working on RTT and we’ve attended presentations by handset vendors that are trying to get us to buy the next version of their phones. And we spend millions of dollars with these vendors.
5072 So we talk to a lot of smart people who are thinking about these things. But generally we don’t really get a chance to input into the design of the data functionality that’s being put forward. I think that’s being driven by various groups out of the U.S. and with larger customer base. So while we don’t have any specific knowledge -- we do, I guess, through infusion because we’re talking to the people who are actually working and thinking about these designs. So we get a perspective of where it’s going and what’s good and what’s not so good.
5073 COMMISSIONER MacDONALD: Not to put you on the spot today -- I mean, maybe you can take that away and think about it -- but if there are some companies doing innovative things or interesting conversations you’ve had, perhaps you can point us to that information.
5074 MR. ANTECOL: It’s going to be a little difficult only because I -- for instance, I attended an RTT workshop session with one of the operating system developers but the problem is we had to sign NDAs when going in there ---
5075 COMMISSIONER MacDONALD: Okay, understood.
5076 MR. ANTECOL: --- so that we wouldn’t disclose how they’re planning to change their operating system. So, unfortunately, it’s kind of difficult for us to do that.
5077 COMMISSIONER MacDONALD: Okay, I won’t have you violate any NDAs today.
5078 Thank you. Those are my questions.
5079 THE CHAIRMAN: Although we could.
5080 MR. ANTECOL: Absolutely.
5081 THE CHAIRMAN: You can’t contract out of regulatory obligations. A lot of people seem to forget that.
5082 When Shaw appeared earlier this week, we asked them some questions -- some threshold questions about Section 46.1 and they agreed to respond through and undertaking. I think it’s at page 261 and 262 of the transcript from the first day.
5083 Would you undertake to provide the similar answer, including that you agree with Shaw’s answer, if that is the case? It’s about whether -- because it’s about Section 46.1 and where there’s two of the condition precedents associated with its applicability in light of your arguments here today.
5084 MR. ANTECOL: Yeah. So we will either provide our own answer or confirm that we agree with the Shaw answer.
5085 THE CHAIRMAN: Either one.
5086 MR. ANTECOL: Yeah.
5087 THE CHAIRMAN: And your answer could be you would agree with ---
5088 MR. ANTECOL: Yeah, chances are they will have thought about it more than we have and we will agree. But we will -- one way or the other we will respond.
5089 THE CHAIRMAN: Thank you. And that’s for the 24th of January, okay? Thank you.
5091 THE CHAIRMAN: I believe legal counsel might have a question.
5092 MR. LY: Thank you, Mr. Chair.
5093 I just wanted to seek to clarify one point in your written submissions where you propose that the Commission establish a national consortium that would establish an annual budget for the development and operations of the NG9-1-1 services and that it would disperse the funds for both the development and ongoing operation of the ESInet and NG9-1-1 facility.
5094 So you said that the Commission would be approving the annual budget since it would be submitted to the Commission. Can you clarify, besides approving the annual budgets, would the Commission have any role or oversight in the above process, for example, ensuring funds are spent for the purposes for which they were dispersed, or is just up to the consortium to enforce this?
5095 MR. ANTECOL: Well, the consortium is going to contract with the vendor. So the consortium will be on the hook to pay for the services contracted.
5096 But in addition to that, the consortium is going to need staff. And one of the advantages of the consortium over ESWG is there’s paid dedicated staff who will supervise the vendor and -- so the President of the consortium or the CEO of the consortium, along with some staff members, and perhaps a budget officer -- those costs will need to be recovered in addition to the contracted costs.
5097 So from my experience -- and I wrote that -- my experience is you can’t really have a -- I mean a consortium needs to budget its own internal costs, and those need to be approved by the members who are ultimately responsible for those costs.
5098 So at the end of the day, the Executive Director or CEO of that consortium will put forward a budget to the Board that says, “I need three members to do this, this, and that. I need one member in the east, one in central, and one in the west,” or “I need X, Y, and Z,” and the consortium may need some money for some education and advertising, or whatever.
5099 So whatever that budget looked like, it’s going to have to get approved before the members are going to be required to pay into it. So I’d envisioned a process where -- and I was trying to convey that there needed to be some checks and balances on that budget and on the proposed scope of work for the executive director, and I just assumed that the Commission would want some visibility into that and to make its views known that this was adequate or inadequate and perhaps suggest a change of emphasis, if required.
5100 So that’s what I was thinking of.
5101 MR. LY: Thank you.
5102 THE CHAIRMAN: Thank you. Those are our questions for you. Thank you for your helpful participation in the hearing.
5103 We’ll take a short break until four o’clock and continue with the next, and final, intervenor for today. Thank you.
5104 --- Upon recessing at 3:49 p.m. / La séance est suspendue à 15h49
5105 --- Upon resuming at 4:02 p.m. / La séance est reprise à 16h02
5106 THE CHAIRMAN: À l’ordre, s’il vous plait. Order, please.
5107 Madame la secrétaire.
5108 THE SECRETARY: We’ll now hear the presentation of Bell Canada. Please introduce yourself and your colleagues, and you have 20 minutes for your presentation.
5109 MR. MALCOMSON: Thank you Madam Secretary, Mr. Chairman, Commissioners and Commission Staff. My name is Robert Malcolmson; I am Senior Vice-President of Regulatory Affairs at BCE. It is my pleasure to introduce Bell's panel.
5110 To my right is Phil Gauvin, Senior Legal Counsel, Regulatory; and to Phil’s right is Fadi Dabliz, Director 9-1-1 Emergency Services for the BCE companies. To my immediate left is Guy Caron, Senior Network Architect; and finally, next to Guy is Denise Potvin, Senior Manager, Regulatory Affairs.
5111 Both Guy and Fadi are certified Emergency Number Professionals and have long been recognized, both nationally and internationally, for their leadership and expertise with regard to emergency services.
5112 By way of background, Fadi serves as the Canadian Director on the NENA Institute Board and he runs a team of over 60 people dedicated to the support of over 270 primary, secondary, and backup PSAPs that we serve across our territories and those of the many ILECs, big or small, which have outsourced 9-1-1 to us. Fadi's team also provides support to over 150 telecommunications service providers that interconnect to our 9-1-1 facilities.
5113 Guy has over 35 years of experience at Bell. He is responsible for the evolution and development of the 9-1-1 data and voice systems used by Bell. Guy has been actively involved in CISC and NENA technical committees since 2004, including the i3 standards development, and he is recognized as one of the foremost experts on the next-generation 9-1-1 architecture, having won several awards for its outstanding contributions.
5114 Phil and Denise serve as our regulatory 9-1-1 primes. You may recognize Phil from other recent proceedings. Denise is a professional engineer; we greatly benefit from her ability to translate complex architectures and issues into concepts our regulatory minds can actually understand. She is also responsible for 9-1-1 compliance at Bell and is an ongoing contributor at CISC ESWG for Bell.
5115 I will now begin our presentation.
5116 It is clear that all parties agree that 9-1-1 services play an important role in the everyday lives of Canadians, and our respect and admiration for the important work that PSAPs and first responders do is immense. At Bell, we take our role in the provision of 9-1-1 service seriously. This is why, throughout the years, Bell and other ILECs have built and maintained reliable and resilient 9-1-1 networks.
5117 The transition to next-gen 9-1-1 will offer many benefits to Canadians. However, if done wrong, the transition could jeopardize the security, reliability, and resiliency of 9-1-1 in Canada.
5118 As such, rather than attempt to fix what isn't broken, we believe the Commission should continue to leverage the current model, which makes ILECs responsible for the provision of 9-1-1 service.
5119 We also agree with Calgary 9-1-1 that we shouldn't talk about new forms of communication as future services. That future is now. Canadians already have expectations that 9-1-1 can directly receive videos, pictures, and text to 9-1-1, and we should leverage our model, a model that has stood the test of time, to implement NG9-1-1 capabilities as soon as possible.
5121 MR. DABLIZ: Thank you. The Current Model is successful. Canadian 9-1-1 providers have built meaningful relationships with primary and secondary PSAPs, municipalities, provincial governments, local services Boards, First Nations communities, as well as other emergency service organizations and other entities such as the Ministry of Health, Office of the Fire Marshal, and Ministry of Community Safety and Correctional Services, to name a few.
5122 These relationships have allowed us to gain an in-depth understanding of the specific requirements of the Canadian emergency response ecosystem, streamlined response times, and play a leading role in the deployment of new E9-1-1 features and functionalities.
5123 You heard on Monday from Chris Kellett of the Coalition of the Willing, that, and I quote:
5124 “Bell rolled out in a year and a half and took six provinces and made them IP-capable because we decided that it was an important thing that had to happen for text with 9-1-1. You would not -– if you went through an RFP process to get that done we’d be still talking about who’s going to get the contract. It was done in a year and a half. So the ability to be agile, working with partners who know what they’re doing, and can deliver and can be regulated in terms of those costs back through a regulating body, is as transparent and as straightforward as you can get.”
5125 It is thanks to these strong and meaningful relationships that we have managed to plan and coordinate the rapid deployment of In-Call Location Update and TEXT with 9-1-1 across our 9-1-1 serving territory. This deployment included migrating all primary, secondary, and backup PSAPs onto an IP network secure and dedicated VPN circuits to support E9-1-1 data, wireless features, and T9-1-1. This monumental undertaking was completed within a short deployment window and allowed for complete interoperability between both networks throughout the migration.
5126 PSAPs also recognize the value of these relationships. Over the past 15 years we have conducted annual surveys via independent third-party surveyors among our stakeholders, be they PSAPs or Telecom Service Providers, which have demonstrated our successful management and support of E9-1-1.
5127 While these surveys provide a helpful snapshot of our overall 9-1-1 service with partners, it is often the survey follow-up and recurring engagement which ensures that all 9-1-1 needs are met and expectations exceeded. In the past year alone, we handled over 7.2 million 9-1-1 calls and assisted hundreds of PSAPs in the process of doing so. With such a vast operation, our survey provides invaluable insight.
5128 We take great pride in the fact that our Operations, Service Management, and 24/7 support teams have consistently achieved an overall score of over 90 percent customer satisfaction among centres, PSAPs and 9-1-1 Authorities, both municipal and provincial. In fact, last year overall satisfaction was at 98 percent. CLEC and Independent Telephone Companies satisfaction was at 95 percent.
5129 The transition to NG9-1-1 will rely on the current expertise of all stakeholders, longstanding personal relationships, ongoing interactions, and existing support models. These are all especially important considering the complexity and the interoperability that next-generation 9-1-1 requires.
5130 The current ILEC model also operates in a cost-effective manner. Compared to the United States, Canadians pay lower 9-1-1 fees for better 9-1-1 service. For example, in Ontario, E9-1-1 service fees are currently set at 13 cents per month for wireline service and 10.53 cents per month for wireless service, which includes TEXT with 9-1-1. These fees are lower than those of other 9-1-1 providers in Canada that have conducted more recent cost studies.
5131 To draw another parallel, in the state of New Jersey the 9-1-1 fees they apply to wireline and wireless and VoIP access per month are 90 cents U.S. And, similar to our own tariffed 9-1-1 fees, these specifically exclude operational, equipment, and personnel costs which are the responsibility of the PSAPs.
5132 New Jersey processes approximately 8.7 million 9-1-1 calls per year, which is only slightly more than we process on our network annually. However, when considering the scope of the network, New Jersey is approximately 22,000 square kilometres whereas Ontario alone is over 1 million square kilometres. And that is only one of five provinces we currently provide E9-1-1 to.
5133 Given the vast Canadian expanse and limited customer base, we believe the facts speak for themselves. Canadians are getting excellent service at low cost.
5134 ILEC-managed 9-1-1 networks have also proven to be highly resilient and reliable. The resiliency of 9-1-1 networks in Canada was confirmed by the Commission’s recent resiliency proceeding, where the Commission concluded that there had been very few 9-1-1 service outages that impacted the delivery of 9-1-1 voice calls. The Commission also recognized that the current, and I quote:
5135 “…9-1-1 network providers have the willingness, capability, and expertise to design high-quality 9-1-1 networks.”
5136 As a 9-1-1 service provider, we offer a qualified workforce, expertise in building and maintaining a robust core network, support functions, extensive monitoring processes, dedicated 9-1-1 24/7 support, as well as several NENA-certified Emergency Number Professionals. All of these elements can be seamlessly and efficiently leveraged in next-generation 9-1-1 if the current model is maintained.
5138 MR. GAUVIN: Thanks, Fadi.
5139 Certain parties have recommended that the Commission create a National 9-1-1 Consortium which would oversee the transition and undertake other additional roles and responsibilities.
5140 First of all, we note that not all parties seem to mean the same thing when using the term “National Consortium”. For example, certain PSAPs and 9-1-1 authorities endorse the existing ILEC model but suggest that a consortium could play a role in funding, act as a catalyst for model legislation, and coordinate the transition for the PSAPs themselves. We certainly understand these objectives and we would be happy to participate should PSAPs and 9-1-1 authorities feel they could benefit from our expertise beyond what we already offer through ESWG as well as through the many training information seminars and webinars that we offer.
5141 Conversely, a handful of service providers suggest that a National Consortium could manage the NG9-1-1 core or create and administer an RFP for a national NG9-1-1. Therefore, we caution against drawing simple conclusions in terms of support of this proposal.
5142 With regards to a national consortium that would assist in the development of standards, coordinate stakeholders and perhaps manage the NG9-1-1 Core, we ask: to what end? Such a consortium would largely replicate the work that is already being done at the ESWG. The ESWG has been very successful in coordinating past national roll-outs of new 9-1-1 features as well as the adoption of technical standards for such deployments.
5143 In fact, Shaw states that ESWG has done an excellent job guiding us through the previous improvements to 9-1-1, but they are not well equipped to oversee the fundamental change contemplated by NG9-1-1. This statement is made as there are six different TIFs nearing completion regarding various standards and processes required for the transition to NG9-1-1. Not only are such statements unfair to the many experts that volunteer their time, their own proposal would only lead to delays and increased costs.
5144 Contrary to the claims of certain parties, such as Rogers, Videotron and Shaw, we don’t need a series of RFIs, RFPs, regulatory reviews, new national administrative bodies, a new contribution funding regime, and layers of bureaucracy to operate 9-1-1 or to migrate to NG9-1-1. It's already happening and it’s occurring at no additional cost to Canadians.
5145 Make no mistake, the proposals for national administrative bodies or national 9-1-1 providers will add complexity, create delay and potentially carve our holistic 9-1-1 system into piecemeal parts operated by different players because no one has an end-to-end solution for PSAPs. All of this will dilute accountability and heighten the risk of failure.
5146 To the extent parties have proposals for change, the onus is on them to demonstrate that their proposal is to the benefit of Canadians. In our view, no party has met this burden.
5147 We have over 30 years of trusted relationships with various emergency response stakeholders. And contrary to what some parties appear to think, the majority of Canadian PSAPs are currently served with an IP data network which can and should become an ESInet. Let’s leverage this in order to maintain 9-1-1 service continuity through the multi-year migration we are contemplating. And let’s start the migration rather than engaging in further discussions regarding potential changes to the current model on the basis of ill-conceived proposals.
5149 Mme POTVIN: La transition. Le 9-1-1 prochaine génération fournit une excellente occasion d’intégrer les formes modernes de communication à l’environnement 9-1-1. Cependant, nous devons nous assurer que les nouveaux services conserveront les niveaux d’exactitude et de fiabilité auxquels les Canadiens se fient aujourd’hui.
5150 Comme l’ont systématiquement fait valoir les CASP dans plusieurs de leurs présentations, il faudra que le 9-1-1 prochaine génération continue de se fier d’abord et avant tout aux communications vocales et à la transmission des données de localisation, comme cela se fait actuellement pour le service 9-1-1 évolué.
5151 D’autres modes de communication, comme le multimédia et la télématique, pourraient éventuellement être incorporés à l’environnement 9‑1‑1, mais seulement si ces modes fournissent de l’information que les CASP jugent utile pour la prestation des services d’urgence et seulement lorsque les CASP auront adopté les méthodes et procédures qui conviennent à ces nouveaux modes. De plus, les modes de communication qui seront introduits dans le 9‑1‑1 prochaine génération devront être conformes aux normes.
5152 Il est essentiel que tous les modes de communication qui seront intégrés au 9‑1‑1 prochaine génération tiennent compte des besoins d’accessibilité afin que tous les Canadiens puissent profiter du 9-1-1 prochaine génération et qu’il n’y ait pas d’interruption pendant et après la transition.
5153 Nous avons entendu à ce propos des discussions sur le texte en temps réel, certains ayant demandé pourquoi il n’y avait pas eu d’essais sur ce nouveau mode de communication. La réponse est simple. Il n’existe actuellement pas d’appareils mobiles ni d’applications capables de prendre en charge le texte en temps réel.
5155 M. CARON: Merci, Denise.
5156 Rôles et responsabilités. Comme les ESLT fournissent aux CASP la connectivité physique à partir des points d’agrégation, la simple logique exige que les fournisseurs d’accès gèrent également les services de connectivité et le soutien pour qu’il soit possible de mettre en place un modèle rationalisé de soutien de bout en bout.
5157 De cette manière, il sera possible de fournir de façon transparente des fonctions d’automatisation et de tolérance aux pannes, d’adapter le service aux différents modèles de déploiement des CASP, d’augmenter la sécurité des modes de changement et d’assurer la pleine interopérabilité entre les CASP du service 9‑1‑1 évolué et les CASP du 9‑1‑1 de prochaine génération.
5158 Certaines parties ont proposé d’abandonner l’architecture actuelle et de la remplacer par un seul fournisseur 9-1-1 de prochaine génération offrant le ESInet/Core. Nous voulons souligner à ce sujet que les CASP et les autorités 9-1‑1 ont systématiquement déclaré dans notre sondage annuel qu’un point de contact unique pour l’ensemble du réseau 9‑1‑1 était un élément primordial pour le maintien du service 9‑1‑1 et le rétablissement approprié du service après une défaillance ou une panne du réseau ou de l’équipement des CASP.
5159 La désagrégation du modèle actuel compromettra le maintien d’un point de contact unique, capable de résoudre rapidement les problèmes du service 9‑1‑1 à mesure qu’ils se présenteront.
5160 Pour uniformiser le 9‑1‑1 de prochaine génération, il ne sera pas nécessaire de construire un réseau national ESInet car il suffira d’appliquer les normes de la solution i3 de NENA.
5161 Dans l’ensemble du Canada, la plupart des CASP principaux, secondaires et de secours sont actuellement desservis par une forme quelconque de réseau IP pour la transmission des données du service 9‑1‑1 évolué. Cette infrastructure physique pourrait former la base des réseaux ESInet nécessaires pour la mise en œuvre du 9‑1‑1 de prochaine génération.
5162 La décision la plus coûteuse et la plus inefficace concernant la réalisation du 9‑1‑1 de prochaine génération pourrait être de ne pas tenir compte ou de rejeter carrément cette robuste infrastructure existante et son rôle de soutien.
5164 MR. GAUVIN: NG9-1-1 roadmap. In short, we do not believe that it is necessary to engage in lengthy and likely pointless proceedings to develop a national administrative body, a detailed RFP that could be put to tender, or a change to the funding model. We have the tools we need to move forward. In the next few months a series a TIFs related to next-generation 9-1-1 will be finalized or near completion.
5165 Our hope is that by the time the Commission issues its decision, they will be completed or that enough consensus will be reached to get started on a technical trial.
5166 As such, in our view, the Commission should: 1) Confirm that the current ILEC model and roles remain appropriate for next-generation 9-1-1 going forward; 2) Approve the ESWG TIF reports regarding NG9-1-1 in 2017; 3) Order CISC ESWG to report, by the end of 2017, on the requirements of an next-generation 9-1-1 trial; 4) Order the implementation of necessary next-generation 9-1-1 features and functionality to allow for the initiation of a trial of next-generation 9-1-1 service in late 2018 or early 2019; and 5) Order the complete roll-out of next-generation 9-1-1 service and the associated next-generation 9-1-1 tariff by the end of 2020,,assuming no delays in the timelines, which coincides with PSAPs’ "Vision 2020" goals.
5167 Mr. Chairman, Commissioners, this is an aggressive timeline. It would enable PSAPs, such as Calgary 9-1-1, which announced that it would have necessary NG9-1-1 equipment available in mid 2018, to avail themselves of the latest technologies and take advantage of these new world-class networks.
5169 MR. MALCOLMSON: Thanks, Phil.
5170 In conclusion, we firmly believe that maintaining the current model will enable us to leverage our past successes for the efficient and orderly development of next-gen 9-1-1 in Canada. Deviating from the current model in favour of the untried and untested models that have been proposed by some will jeopardize the resiliency, security, and reliability of next-gen 9-1-1, prolong the transition process, increase the complexity of the transition, and would quite likely be more expensive.
5171 Rather than lobby the government in the hopes of changing the funding system for 9-1-1 through new federal taxes or dedicate time and resources for the development of a contribution fund administrator or engage in a lengthy and detailed RFP process for a potential national provider, let's leverage the current model that is known to work well and move forward.
5172 Thank you for the opportunity to share our views and we look forward to answering your questions.
5173 LE PRÉSIDENT: Merci beaucoup.
5174 Je vous mets entre les mains de Conseiller MacDonald.
5175 COMMISSIONER MacDONALD: Good afternoon. Thank you for your presentation. Over the last four days, if there's one thing that parties have generally agreed to, it's that the current ILEC stewardship of 9-1-1 has resulted in a reliable and resilient 9-1-1 system. And although past success may potentially be an indicator of future success in this regard, let's park that for a moment, because in our conversations with other intervenors, although they would say the system has been reliable and works well, they do have concerns and think that a new model should be explored because it may reduce costs, improve collaboration, and so forth.
5176 Can you outline for me, if we did go in the direction proposed through a national consortium model, what specific harm you think could be introduced into the system and why you think the potential for that harm exists?
5177 MR. MALCOLMSON: Thank you, Commissioner MacDonald. I'll start and I'm sure others on our panel will want to contribute.
5178 We've listened quite carefully to the proposals and read the submissions, and at the end of the day -- and it's -- it was mentioned in our presentation, really, I think we're all listening to people trying to fix something that isn't broken. And you know, given the importance of 9-1-1, it's our view that it's simply too risky to put that system at risk.
5179 So when we hear about an RFP for example, and an RFI process, and you know, a multi-stakeholder governance structure in which -- you know, in Rogers' view of the world, you would have five classes of voting shares, you would have a tangled web of veto lights and governance provisions, you'd have conflict of interest rules -- we immediately say to ourselves, "Why are we doing all this when the existing ILECs have the obligation, are well aware of the obligation, are taking the risk of brand damage every day that, you know, they provide 9-1-1 service, and aren't we risking delay? Aren't we creating complexity, and aren't we potentially increasing the cost of providing 9-1-1 service?"
5180 So it's really a combination of cost, complexity, delay, and increased risk.
5181 And then when I listen to the evidence about this new model, you canvassed the various telecom service providers that appeared in front of you and you asked each of them, "Would you be interested in being the national provider in this new model?"
5182 And the evidence you got back, I think I would describe as lukewarm at best. Shaw said they weren't interested. Perhaps they'd be interested in doing some pieces of the puzzle. TELUS was sort of non-committal, said they'd need to look at a business model. Rogers was non-committal. Videotron said, "No, we wouldn’t do it. We don’t have the expertise."
5183 So I think we might create this model, run a process and then find out that the TSPs or the ILECs that are probably most qualified to bid may, for whatever reasons, not be interested. So to us it seems like fixing what isn’t broken and taking greater risk. And obviously 9-1-1 is a service that none of us should be taking risk with. Others may wish to add.
5184 MR. GAUVIN: Yeah. I just want to opine on timing for a little bit.
5185 So one of the first things I did when I first joined Bell was assist in the creation of the creation of the CCTS. And I think that sounds more important -- I was fairly junior at the time but I was fairly involved.
5186 And we heard from Rogers that the development of the constating documents was six months, which is true. So from the time we gave a blank sheet to Gowlings and the time that we had constating documents, it was six months. But there was a period before then that we all discussed what should be involved in the CCTS. And that’s how it led to the constating documents that we actually received.
5187 After that there was a proceeding at the CRTC to review the constating documents and that took about four months. And then once you have an approval you actually need to look for the board, right? I’m assuming -- although it hasn’t really been described this way -- but I’m assuming that we’re talking about some independent board that would review 9-1-1. So the hiring process for -- it turned out to be Howard Maker at the time -- took about eight months.
5188 So add all that -- and you know, you’ve heard some parties talk about having an RFI ready in six months. Think about what’s involved in creating an RFI and an RFP for 9-1-1. So we’re talking about extracting the special sauce of what is 9-1-1 and for Bell, for MTS, for SaskTel, for TELUS. And there’s some complexities just by the very nature and the fact that it’s 9-1-1.
5189 So think of the fact if someone mentioned that, you know, Ericsson might be interested in participating and bidding -- so think of Ericsson that -- I don’t want to speak for them, but I’m assuming they don’t know a lot about the 9-1-1 networks in Canada so we need to give them enough information to actually have an informed bid.
5190 How do you convey where the PSAPs are and the amount of network that’s necessary to connect to the PSAPs while protecting national security? And I’m not saying that it’s impossible, but you need to have some type of process where you’re not putting a map of all the Canadian PSAPs out there that’s publicly available.
5191 So there’s enormous complexities and enormous processes that have to be distilled into an RFP. And you have to have enough detail in an RFP that actually tells the bidder exactly what their obligations are, what their standards are they’re going to be held accountable to, and the actual consortium needs to be comfortable that they’re going to get a good provider just based on the RFP.
5192 So if you think of the resiliency proceeding and the fact that it’s a reasonable measures test for ILECs, you know, in terms of safety measures for 9-1-1 -- ILECs have 30 years of history, 30-plus years of history in managing 9-1-1 network. That might be sufficient for the ILEC model. But once you move to a third party, an unknown third party, you actually need to define those measures.
5193 So defining those measures is going to take time. And six months -- for sure we’re dreaming in six months. I think we might be dreaming if we think it’s going to be done in two or three years.
5194 MR. MALCOLMSON: Sorry, if I could just add? At the end of the day when we look at the current model, it seems -- from a regulatory, supervisory standpoint and from a performance standpoint it seems to be a model that’s working. You have a model in which the ILECs are obligated -- it’s not through contract or through negotiation; there are no commercial elements to it. There’s a regulatory obligation upon the ILECs to provide 9-1-1 services within their footprint. And it’s subject to Commission oversight.
5195 I worry about creating this RFP outside of the Commission’s oversight process or with light Commission oversight, introducing a commercial element to it because you’re creating a bidding process on a very important public good. So in my mind, the current model of regulatory oversight and imposed obligation, and a track record of the ILECs doing it over time, tips the balance in favour of maintaining the status quo.
5196 COMMISSIONER MacDONALD: When you envision keeping the current ILEC model in a next-gen situation, do you also believe it’s going to be the same ILECs around the table that are actually providing that service across the country? Or do you see any type of consolidation whereby, for example, instead of providing it themselves, everyone would just go to Bell to provide it or to TELUS?
5197 MR. MALCOLMSON: We wouldn’t presume to speak for other ILECs. Certainly in the current configuration, the way things have evolved, Bell does it within its own operating territory and then has accepted outsourcing assignments from others. But on a going-forward basis I don’t know if that’s the pattern that would continue.
5198 I don’t know, again, if others want to add? Fadi, did you want to add?
5199 COMMISSIONER MacDONALD: Do you think that by opening it up to a competitive bid, that it may entice some providers to get out of that business? You know, would Bell, for example, not want to respond because -- a few moments ago you outlined how complex it is to offer the service and you’re taking a potential risk to your brand every day if there were an outage or a situation. Do you think that by opening that door we run the risk that people may step back?
5200 MR. MALCOLMSON: The short answer, Commissioner MacDonald, is yes, I do worry about that. And you heard the responses from others when you asked if they would, sort of, step up to the task.
5201 When I hear the vision of the next-generation configuration -- you know, a 10-year model, a bidding process, a requirement out of necessity to lease facilities from other providers because none of us have a national 9-1-1 network -- it does start to sound complicated, risky, and full of potential liability. So certainly anyone before they stepped up to the job would have to think long and hard about it. So that is a risk, yes.
5202 COMMISSIONER MacDONALD: I asked some questions earlier in the week of different providers and it was with respect to whether we actually thought that the costs would be lower, going with a competitive bid process. I think it was Rogers that noted that even if there was one bid, only one bid, that wouldn’t necessarily mean that was an uncompetitive bid.
5203 Why are you of the viewpoint that a competitive process would not yield lower costs at the end of the day?
MR. GAUVIN: Sure. And I’ll link this with a question that I think Commissioner Menzies asked as well earlier this week in terms of motivations:
5204 “So you’ve heard from cable carriers. What’s your motivation for your proposal?”
5205 And they’re convinced that costs will go down. And we’re concerned that costs will go up. And you know, based on our knowledge of the network -- and we’re thinking if there’s a national provider that bids, how can it possibly go down?
5206 And just to give you an example, we serve a very large portion of the country now and I think there’s an expectation that if it went to a national model Bell would, you know, look at the bidding process and potentially submit a bid.
5207 Now, think of what’s involved. So we don’t know exactly the configuration of TELUS’ network. We don’t know exactly the configuration of the other ILECs’ networks. In order to put in the bid we have to find that out. So unless the RFP, you know, has all that detail available and we don’t have to look into it more than that, we actually have to hire consultants and try to find that out.
5208 Then in terms of actually serving the PSAPs, we have to look at leasing facilities and probably building. And if you’ve read our reply comments we talked about the fact that if there’s a third-party provider instead of the ILEC while the E9-1-1 network is live during the transition, chances are you need to build new facilities to a PSAP at that point in time because as a live network is going down it’s still ongoing; you still need to build a new network for NG9-1-1.
5209 So if you’re leasing facilities or you’re building facilities, obviously it’s going to cost more than facilities already exist. And you know, I just don’t see and I don’t think any of us see how it could possibly be cheaper -- certainly not quicker -- if it went through a national model.
5210 MS. POTVIN: Oh, if I can add something?
5211 COMMISSIONER MacDONALD: Yes, please.
5212 MS. POTVIN: We seem to be thinking of this as two different things. Like, on one side the E9-1-1 network remains as is and then we’re all going to go in a bidding process for something completely new and sort of detached.
5213 But the reality is, those two networks have to interact together. And there are some costs there, and they would not be insignificant, to operate the two networks with two different providers operating them together in parallel. So as soon as it’s not the ILEC, this has to be considered.
5214 And there’s also the labour involved. So Fadi runs a team of people working on 9-1-1, responding to calls. If there’s another provider, we have to staff- up for all of the calls, the labour, and the monitoring systems. So all of this has to be considered as additional cost.
5215 So while you’re going into a process of RFP, and you’re thinking the cost will be lower, there are some additional costs that have to be considered separately.
5216 COMMISSIONER MacDONALD: What changes, from an architecture standpoint, if we went with a hypothetical new player versus the ILECs, moving forward, and implementing next-generation 9-1-1. Can you educate me to -- obviously, they’ll have to talk to each other; there will have to be interconnections.
5217 I don’t know whether that means there’s another physical access connection going into every PSAP in the country, whether there’s just a gateway at 151 Front Street in Toronto to tie the two networks together. What would actually be required?
5218 MR. CARON: First, we have to understand that the current E9-1-1 network is still functioning, right, so every facility that we have in place in the PSAP for data transmission and voice is already in use. So in the eventuality of having a brand new provider, they will obviously not be able to use those facilities and would have to build their own.
5219 So we will end up in two completely different networks being integrated in all the PSAPs, for the duration of the transition, up to a time that we can, you know, get rid of the legacy 9-1-1 network. But also, this puts the burden on the PSAP to manage the transition.
5220 So we would have, potentially, calls coming from the new provider on the next-generation 9-1-1 side, but also calls are coming from the E9-1-1 side for a period of time, and therefore this PSAP would have to incur actual cost to have this dual-mode type of operations for a period of time because they are stuck with calls coming from the IP side and the TDM side for a period of time.
5221 It also puts additional complexity because now they have to be capable of transferring calls, a call, say, that’s coming from the IP, but they have to transfer that call to a secondary PSAP that’s still on TDM. All that complexity is now on the PSAP.
5222 MR. GAUVIN: This might be a good place -- we actually -- we anticipate, potentially, getting questions on gateways. And there’s actually three different types of gateways. We prepared diagrams because on the record right now from Bell, there’s an E9-1-1 architecture diagram; there’s an end-state NG9-1-1 architecture diagram; and we’ve talked about gateways in paragraph 75 of our reply and, potentially, elsewhere; but we don’t have a transition diagram. And if you want that, we have that prepared, or we’re just happy to talk the parallel networks; it’s up to you but we have it our disposal.
5223 COMMISSIONER MacDONALD: If you could provide that, I think the visual may be helpful.
5224 MR. GAUVIN: I’ll just walk it to you.
5225 COMMISSIONER MacDONALD: Oh, sorry, we’re missing a player right now.
5226 MR. CHAIRMAN: Yeah, we don’t have a secretary. Perhaps somebody from staff could help along here.
5227 We haven’t had a lot of extra documents so why don’t we just call -- it’s one document? So why don’t we just call it ---
5228 MR. GAUVIN: One document, two pages.
5229 MR. CHAIRMAN: So why don’t we call it Bell Number 1 -- Exhibit Bell No. 1.
5230 MR. GAUVIN: Not to worry; it’s the only document that we brought.
5231 MR. CHAIRMAN: Okay.
5232 MR. GAUVIN: So just to -- and we can speak to everything on this diagram, if you have questions, but I think we just want to focus on the gateways. And there’s really three types if gateways that I know of -- and I know I’m -- Guy can correct me; he knows this way better than I do. But there’s -- on the first diagram, which goes to your question -- we heard questions from counsel earlier this week on why we need to charge the full tariff for each network.
5233 And if you look at the transition diagram -- so the top portion would be the E9-1-1 network. The lower portion is the next-generation 9-1-1 network. And in the middle is what’s called a Legacy Selective Router Gateway. Guy is nodding so so far, so good.
5234 And let’s take, for example -- let’s say Shaw’s customers -- Shaw has done the conversion to NG-9-1-1, so all of their customers are on NG9-1-1.
5235 You have some PSAPs which might be -- let’s say Calgary seems to be chomping at the bit to be an NG9-1-1-capable PSAP -- and chances are they’re going to be one of the first PSAPs NG9-1-1-capable. So they might be in the lower-right corner; and NG9-1-1 PSAP, and other PSAPs might still be E9-1-1, and they’ll be at the top.
5236 So the Legacy Selective Router Gateway, what it does is it enables -- when an NG9-1-1 caller calls 9-1-1, and they’re in an E9-1-1 PSAP area, their call actually goes to the Legacy Selective Router Gateway and it’s ultimately routed through the tandems, the existing E9-1-1 network, to the legacy PSAP.
5237 So far I’m not corrected.
5238 And now the other way around, let’s say there’s a provider that hasn’t done the switch to NG9-1-1 yet -- although, there are strong incentives to do so and we can get into that later. But let’s say haven’t done the upgrade to NG9-1-1 but Calgary’s already NG9-1-1, they decommissioned their legacy equipment and they’re completely NG9-1-1.
5239 Well, it’s the same thing; it goes through the tandems -- or it might go through the tandems. It goes through the legacy -- okay, so yes it does. It goes through the Legacy Selective Router Gateway and out to the PSAP.
5240 MR. CARON: That’s correct. So, essentially, it follows the -- you know, completely different path, from legacy to tandem to the LSRG. The SRG goes through NG9-1-1 core system that will eventually find it’s path to the next-generation PSAP that is serving that particular customer, all of that completely transparent for the caller and for the PSAP.
5241 COMMISSIONER MacDONALD: It’s times like this it would be beneficial to have a steel ring on my little finger.
5242 The gateway between E9-1-1 and NG9-1-1, is that a single gateway for the company? Would there need to be -- for the country, rather. Would there need to be one gateway for each ILEC network service provider, one for each PSAP? How would that work?
5243 MR. CARON: So the legacy -- first of all, just to back up a little bit, the Legacy Selective Router Gateway is a functional element that was defined by NENA as a transitional element. If was not defined as a gateway for the end-state. And its function, as Phil will explain, is to bridge the legacy network with the NG9-1-1 network. It does not have any direct interfaces with originating networks or PSAPs. It’s simply a bridge between two types of networks to interoperate between each other.
5244 To answer your question directly, it’s not per PSAP; it’s, typically, per network. So in the model that we propose, Bell would have an LSRG between its E9-1-1 network and its NG9-1-1, one gateway, obviously fully -- geo data and so on and so forth, but one functional element called LSRG. Telus would have its own and so on and so forth.
5245 COMMISSIONER MacDONALD: So ---
5246 MR. GAUVIN: And just to add to that, we’re really talking only about the Legacy Selective Router Gateway because, to your question, if you go to the second diagram, you can see two other types of gateways there.
5247 So there’s a white box on the lower-left corner, which is called the LNG; that’s Legacy Network Gateway. And that would be, for example, what Freedom Mobile was talking about earlier today. If you have a legacy network -- let’s say you have a CDMA network -- and you need to interface with NG9-1-1, you would need one of those gateways.
5248 And on the right side, the LPG, that’s the Legacy PSAP Gateway. And that would be the conversion -- let’s say we're now in an end-state NG9-1-1. E-9-1-1 is decommissioned because maybe there was a sunset date or something like that, and now PSAPs would have this legacy PSAP gateway. And I -- based on the questions I've heard this week, I think you've heard -- you seize the ups and downs with that gateway. It obviously removes incentives to do the conversion to NG. And beyond that, it's not just a flip of a switch. It's actually going from one transition to two transitions.
5249 And I'll let Fadi explain that in greater detail.
5250 MR. DABLIZ: Right. So from what you’ve heard this week, it sounds like, okay, put the gateway here and everything should be okay. That is not the fact. You put the gateway there for that -- for the PSAPs to use, you have to cut over each and every single PSAP; primary, secondary, backup site in order to get that. You have to test every single line, line-by-line to ensure that all the features on those continue to work. That's on top of any testing you did on the network and features ahead of time. Every single PSAP needs to be cut over.
5251 So the conversation becomes, "PSAP, we need you to transition to NG9-1-1. Okay, you can't do it for whatever reasons, we have this gateway."
5252 "Okay, what do I get when I use the gateway?"
5253 "You get absolutely nothing except for another transition some time in the future to actually get you to NG9-1-1."
5254 So all this to say, when you do this legacy gateway, this legacy PSAP gateway, all you're actually getting is using the new network, none of the new features. So the PSAPs that actually want the NG9-1-1 features, after they've done this cutover, have to cut over again. So you're forcing a second cutover to these PSAPs, additional cost, additional time, additional complexity. This means that they may have to go to their backup sitess so that they can do the cutover at the primary site, a whole bunch of other things. It is not as simple as some parties have made it out to be.
5255 COMMISSIONER MacDONALD: So -- and this gets to risk of an outage and resiliency -- the -- I would -- would I be under the correct assumption that the more gateways, the more equipment, the more vendors that are involved, the more points of failure that are being introduced into the potential network, more pieces, more things to go wrong?
5256 MR. DABLIZ: So strictly speaking on its surface, absolutely. You have five boxes, you have five times more possibility than if you had one box. However, there are all sorts of contingencies and design elements to ensure that resiliency is maintained. So yes, you do have additional points of failure, but you also have additional options of interconnection or bypass, in some cases.
5257 COMMISSIONER MacDONALD: Would those additional points of failure just be for the transition period, or would it be a permanent element risk in the network that would exist as long as there are non-NG9-1-1 PSAPs out there?
5258 MR. DABLIZ: Yes, so that gateway will be required until the last PSAP would be actually cut over properly onto NG9-1-1. So they will remain. However, as I mentioned before, it really depends on the architecture, the configuration design as to how redundant that is, and so on. But they will remain until that last PSAP has properly cut over to NG9-1-1. I hope that answers your question.
5259 COMMISSIONER MacDONALD: And when you say "last PSAP", do you mean last PSAP in all of Bell's serving territory, or do you mean within a given province or ---
5260 MR. DABLIZ: So again, we're looking at this holistically as a network, so it would be the last one on our network.
5261 COMMISSIONER MacDONALD: Because you would need to continue supporting legacy 9-1-1 for as long as anyone within your serving territory was using it?
5262 MR. DABLIZ: Yes, sir.
5263 COMMISSIONER MacDONALD: With respect to the cost, if we did go with the -- you know, the hypothetical new player providing the NG network, who do you envision paying for those new gateways that would need to be installed to allow the PSAPs to connect into the network? Is that going to be the responsibility of the service provider or the responsibility of the PSAP?
5264 MR. GAUVIN: That's a very good question. We -- charging the PSAP for the gateway is one way to do it. But we sort of joked around together. That's sort of like when the bank charges you money because you don’t have enough money in your bank accounts, right? If the PSAP isn't doing the conversion for a certain reason, chances are it's funding, but on the other hand, you also don’t want to make it so easy to get the gateway that there is no incentive at all.
5265 We could have it right now, just to be clear, because it’s not the same as in the U.S. at all. Right now, the PSAPs don’t pay for connectivity. They don’t -- the tariff pays for everything up to their D-mark and all that stuff. So in order to have a fee for a gateway it would be completely new fee that they don’t pay at all today. It doesn’t mean that it's impossible, and we certainly -- I don't know what the cost of a gateway is. I'm not sure if anyone knows what the cost of a gateway is at this point, but we could have a fee for those PSAPs or maybe we could develop a tariff with a monthly fee for those PSAPs. But that's something that could be explored at a further date.
5266 I think, as an industry -- and especially you as policy makers -- you just need to keep in mind the incentives to do the migration and the importance of everyone doing the migration, because there is network affects, and if you can, you know, throw calls from one PSAP to another and information from one PSAP to another, there's benefits there. And if everyone doesn’t do the move, those benefits are lost. And we need to find out clever ways and we haven't really found the exact perfect clever way just yet.
5267 I'm also thinking of that conversation that we're going to have with the PSAPs that, "Okay, so you cannot or for whatever reason cannot do the proper transition to NG, so here's the gateway. By the way, you have to pay for it." That's not a lot of incentive because remember, we still have to cut over with that PSAP, and if they choose not to, they're not going to. So again, what is the incentive for the PSAP to do that if all they're going to be doing is paying for the same thing they get today, paying more for it than what they get today? I just - I don’t see them accepting those terms and volunteering to cut over.
5268 COMMISSIONER MacDONALD: Paying more, do you have any -- without me holding you to a specific dollar figure -- do you have any concept as to how much a gateway would or could cost? Are we talking about $1,000 Cisco switch that's being installed at a PSAP or are we talking something more significant than that?
5269 MR. CARON: I'll take that one. Well, I cannot provide you with a specific figure, but I can tell you some of the criteria that goes with that. Those gateways are not the regular, you know, commercial off-the-shelf gateways, PSN gateways. They are specialized products specifically designed for 9-1-1 purposes. 9-1-1 is a niche market, right? It does not benefit from a large case market for economy of scales.
5270 And also, the LPG specifically must mock and alley in its function. It must mock an ALI, because it interferes with the legacy PSAP that is expecting to receive the data packet that it received today in E9-1-1. And also, it mocks the E-now in tandem. In that sense, you also can expect there's going to be some form of customization required because as we all know, there's -- but is all the same in Canada.
5271 So if you put all that together, without putting a price figure on it, it's certainly something that will cost more than a regular PSN gate which it could find on the market today.
5272 MR. DABLIZ: And Guy had also mentioned those -- some of those ancillary costs, so we went and we transitioned those -- or the other PSAPs onto the NG9-1-1 network, which doesn’t have an ALI, and then we put it on the gateway just to introduce ALI functionality, which everybody else has gotten off of. So I'm not sure if it's actually a step backwards, but it's certainly not a step forward.
5273 COMMISSIONER MacDONALD: Thank you for that. That -- and the diagrams are helpful.
5274 With respect to the RFP, people have suggested different term lengths. They seem to be circling around the 10-year mark as a nice round figure. But you have experience in supporting 9-1-1 networks, in deploying the facilities for fire and to support 9-1-1, life spans of equipment.
5275 What is the right term for an RFP if we decided to go in that direction? Presumably, we may potentially as one option, may want to follow the life cycle of equipment that's being deployed.
5276 MR. GAUVIN: Sure. I don't know if there's a -- 9-1-1 is here to stay, so whatever term that you put in there, you just have to consider the fact that whoever's going to bid is going to bid knowing that let's say it's 10 years, 10 years from now, whatever they invest might go to someone else. So that just means that when you bid, you want to make sure that you're profitable at the end of your bid. If all that goes to someone else, it's going to increase the costs.
5277 So I don't know, you know? We could say 5 years, we could say 10 years, we could say 15 years, but at the end of the day, it's a consideration in the RFP process, as a bidder, if your network and your equipment is going to someone else at the end if you’re not chosen again.
5278 COMMISSIONER MacDONALD: With respect to facilities going elsewhere, I’d like to get a better understanding of what circuits you actually have deployed in your network. Obviously there’s a transport component and then there’s the physical access layer going into the PSAPs. Are those copper-based solutions? Are you running fibre to all of the primary and secondary PSAPs? What’s actually deployed out there?
5279 MR. DABLIZ: So are you talking about the voice network or the data network or both?
5280 COMMISSIONER MacDONALD: Both.
5281 MR. DABLIZ: Okay. So on the voice network it is, as you’ve heard, legacy. It’s based on TDM technology. So those could be individual DS-0s, trunked T-1s that are brought into the PSAP. But it is TDM. And that is done -- the transport can be done over all sorts of different facilities. So it could be fibre; it could be copper. The same thing as the last mile transport. So when it comes to the voice it very much is a legacy environment.
5282 On the data side, contrary to what you might have heard, it is entirely different. It is an IP network. So what we have at every single primary, secondary, and backup PSAP in the five provinces where we offer E9-1-1, and in SaskTel for the data portion, what we have is redundant circuitry in there to be able to provide IP functionality. Now, some of it is copper; some of it is fibre; sometimes it’s a mix of both, one or the other as well depending on the redundancy available in that area.
5283 So on the data side it’s a mix of modern technology in order to support the IP and on the voice side, legacy, TDM, and what you would expect to see there.
5284 COMMISSIONER MacDONALD: So are all of those existing circuits easily upgradeable to support increased demand from NG9-1-1? You may be challenged with what you can get out of copper, but where you have fibre deployed, would I be correct in assuming you can just install a new box and go from 100 meg to a gig or 10 gig or whatever may be required?
5285 MR. DABLIZ: So you’re speaking specifically of the data side here?
5286 COMMISSIONER MacDONALD: M’hm.
5287 MR. DABLIZ: Absolutely. That’s it. Now, in some instances there may need to be additional bonded T-1s or whatever facilities need to have. You’re right in terms of whether it’s going to be a 20-meg box or a 40-meg box or something like that. But yes, that’s how the upgrade could and would happen. And they are all scalable.
5288 COMMISSIONER MacDONALD: And from a networking standpoint, is this just an MPLS network?
5289 MR. DABLIZ: Yes. The core is an MPLS network and the way that we’re interconnecting to the PSAPs is via an IP VPN or Virtual Private Network. And it terminates on a CE or Customer Edge router, which is located at the PSAP and what we consider the demarcation point.
5290 COMMISSIONER MacDONALD: So you can prioritize on MPLS networks. Would I be under the assumption that 9-1-1 traffic is in the top priority queue for your services?
5291 MR. DABLIZ: Absolutely.
5292 COMMISSIONER MacDONALD: Okay.
5293 MR. DABLIZ: It would be when it’s tagged, when that kind of service is voice-tagged for 9-1-1, yes.
5294 COMMISSIONER MacDONALD: When I was chatting with Rogers yesterday and they -- obviously if we did go the route that many are suggesting and issue an RFP to get a competitive bid, whomever the successful bidder would be would no doubt have to rely on the networks of multiple different providers.
5295 From a contracting standpoint, would Bell have objection to making those facilities available on a lease basis to another provider and does that add any extra complexity?
5296 MR. DABLIZ: So if I may answer that in reverse? I’ll let him speak to the policy about leasing and so on and so forth.
5297 But in terms of the complexity, absolutely it would add complexity. See, what happens is if you divorce the virtual from the physical, then that thing that the PSAPs like, the one throat to choke -- by the way, I am that throat -- what you do is you end up making a call to somebody and they’ll say, “Okay, we’ve checked this; the application or the virtual part is okay. It must be a physical cut.”
5298 “Okay.” Who do you call now? Well, call Bell or whoever it is that’s in charge or that or vice versa, whatever the scenario.
5299 So again, it’s that line of sight to say, “Hey, something is not working.”
5300 “Okay, why isn’t it working?” And you want to work it backwards. You can only get to a certain point if you’re providing the virtual side or the app side, the application later. You really need to get down through every layer to be able to do a proper -- or at least an efficient job at assessing a network trouble.
5301 Now, when it comes to the actual leasing of the lines ---
5302 MR. GAUVIN: Yeah, just to add to that point, in the U.S., because they do have a model where there’s competition amongst 9-1-1 providers, the FCC had some recent decision or decisions -- Denise knows better than I -- but that actually reviewed and discussed what they call “sunny day outages”. So sunny day outages are outages that aren’t caused by fire, storms, disasters, or other damage, the backhoes. It’s damages caused by errors in interoperability between providers.
5303 And they’ve had some, I guess, newsworthy outages, you know, outages for over six hours. And I think some of them were multi-day outages of 9-1-1, which is a huge issue.
5304 So I think there’s that policy angle and public-safety angle that needs to be considered.
5305 Now, in terms of Bell saying, “No, we’re not going to lease you because we’re bitter; we’re not the 9-1-1 provider” and all that stuff, I don’t think that’s going to happen. But one thing to consider, though, is what we’ve been mentioning before. We have a live E9-1-1 network. So in terms of leasing facilities to a new provider during the transition, that’s very difficult because the 9-1-1 network is being used today.
5306 COMMISSIONER MacDONALD: But if we’re talking the physical fibre facilities going into a PSAP, couldn’t you keep, you know, your existing service up and running and just lease a couple more fibres in the sheath going into the PSAP from a physical layer?
5307 MR. DABLIZ: So this is if you wanted to have someone else pipe in some data or ---
5308 COMMISSIONER MacDONALD: Yeah. So if Chris MacDonald Telecom was the successful bidder in this RFP process but I didn’t have connectivity into the -- or I couldn’t build my own fibre facilities into the six PSAPs in New Brunswick, could I go to Bell’s carrier department, wholesale department and lease facilities into those PSAPs?
5309 MR. DABLIZ: So could you? Absolutely. Technically, yes. In terms of supporting that afterwards? It would be questionable how efficient that would be.
5310 COMMISSIONER MacDONALD: Do ---
5311 MR. CARON: Can I add to this?
5312 COMMISSIONER MacDONALD: Yeah, definitely.
5313 MR. CARON: You may have capacity on your access network, but you may have different capacity entering the customer premises, right? So we don’t overbill, right? So there could be something, you know, that the new provider would still have to build to enter the premises in order to drop, if you will, right?
5314 I would also want to reiterate in that mode of operation the PSAP would be stuck with a dual mode of operation, right? So this is a concern.
5315 MR. GAUVIN: Just to clarify that point. A dual mode of operation means that the PSAP, instead of buying NG-9-1-1-capable equipment, would need to be equipment capable of both E9-1-1 and NG9-1-1, which is more expensive, presumably.
5316 COMMISSIONER MacDONALD: Complexity would increase under that type of scenario. Does the function of leasing that physical access going into the PSAPs if a future provider came to Bell -- does that have an impact on things line mean time to repair and availability? How much is the process slowed down by a PSAP having to call Chris MacDonald Telecom and then Chris having to call your knock to get a circuit repaired?
5317 MR. DABLIZ: So it slows things down considerably and here’s why. When we’re looking at a network outage today we get an end-to-end view. So unfortunately outages or troubles or issues that happen on facilities, they don’t always present in the same way. Depending how things fail -- so for example, today if you have a short versus an open it’s going to present very, very differently. If you have a swinging short versus a partial open or a non-steady state, different things happen.
5318 Well, in digital you can look at it exactly the same way. Depending what’s happening end to end, you may get alarms or trends that say something is happening. If you don’t have that end-to-end view, all you know is that, “Well, my network looks okay. Okay, I’ll look a little deeper. Yeah, I see some slippage over here” or whatever the issue has to be. But again, without that end-to-end view now you’re either making assumptions or having to bring somebody on board.
5319 Now, if this is Monday to Friday between regular business hours it may not be too, too bad. But what happens at Sunday at 4:00 in the morning? And that’s typically, unfortunately, when failures seem to occur. So when you actually want to go and do this, and even during regular business hours, it can double, and possibly even more, the mean time to repair when you have to involve another party.
5320 So is this going to be my truck that rolls or somebody else’s truck that rolls? Do I control that?
5321 Today, when there is an issue with 9-1-1, there is no higher priority that you can assign to a ticket. So if a PSAP loses 50 percent of their lines, there are people on it yesterday. When I have to start doing a measure or at least seeing what’s coming in, what’s going out, and figuring that out, there is going to be an inherent delay.
5322 And that is going to propagate down the line through all the different steps. So you know, it may start at a test board and then it will go to perhaps a field dispatch and whatever else. Every time you don’t have that end-to-end view, you’re putting inherent -- or potentially adding delays to each step of that as well.
5323 COMMISSIONER MacDONALD: Okay. Thank you.
5324 MR. CARON: If I may ---
5325 COMMISSIONER MacDONALD: Oh, sorry.
5326 MR. CARON: If I may add to Fadi? This also brings the point of support systems. So obviously Bell has 9-1-1 support systems that looks after our 9-1-1 network from an operational perspective. And I will draw your attention, if you still have the diagram, on the green components in both the end-state diagram and the transition diagram, which constitutes a provisioning side aspect. But you can also see that -- and it’s the same perspective as operational systems -- that we would leverage, you know, obviously in next-generation 9-1-1, to be able to monitor both the legacy and the new network.
5327 So if you separate those two, it means that the new provider will have to build its ONMP platform, right, on top of everything. This is often and often. You know, nobody is talking about that piece. But there is a significant ISIT costs in building those operating systems, you know, support system, for any network. So that’s another thing that, you know, we see as a potential cost that a new operator would have to incur but nobody wants to talk about.
5328 COMMISSIONER MacDONALD: Thank you for that.
5329 Just to change focus for a bit, notwithstanding we may not know exactly what next-generation services are going to look like. In the current system we’ve established certain trust identities that can connect into 9-1-1 networks. And I’m wondering, as we move forward into a future state with more ways to connect into 9-1-1, potentially moving into the world of “Internet of Things” and connected cars, what other trusted entities do you see needing to be added to that list and what criteria should be used to determine who can connect and who can’t?
5330 MR. CARON: So definitely we see that new parties would eventually have to come up and interconnect with next-generation 9-1-1 networks. We heard, you know, alarm companies, automatic crash notification providers like OnStar or Ford Sync and things like, social media platforms, applications, sensors, and so on and so forth. But as you pointed out rightly is that there’s certainly some criteria to meet in order to be able to interconnect and then to work with NG9-1-1 systems.
5331 I do believe this is the type of thing that should be discussed at CISC. However, I can provide an example of what I think should be some criteria to consider.
5332 First and foremost, whatever service -- new service or entity -- would have to be supported by an i3-compliant PSAP, both technically and operationally. And by that I mean that a PSAP should be part of the decision-making process to onboard a new form of communications to NG9-1-1.
5333 Obviously that new entity or service would have to be capable of 9-1-1 calling. And I’m using “calling” in a very broad term knowing that some application is not really a call as we know it traditionally.
5334 It would have also to be an identifiable provider with contact information. We want the PSAP to be able to contact a provider if anything goes wrong with a call or a session. So I think this would be, you know, another criteria.
5335 We also think that it should provide a traceable source. So in today’s world we’re talking about call-backs. So you provide the calling telephone number. So in the IP world this could be a telephone number, could be something else, so it could be called back or traced back. So “capabilities”.
5336 Also we think that it should have dedicated interconnection. We heard Freedom Mobile mentioning, you know, agreements, formal agreements to interconnect, though that goes in line with that. So dedicated interconnections to the next-generation 9-1-1 infrastructure at designated point of interconnections.
5337 Also, it would have to be compliant with the network-to-network interface or application programming interface, technical specifications, with the requirements to provide trusted, reliable location or provide an access to that information with the call. Also provide actual data such as subscribedrname, type of service, et cetera, as PSAPs that are joined through the ALI or an access to that. And obviously 60 requirements that would come with connecting to an NG-9-1-1 core system.
5338 We may want to think about -- and I think that was brought by some of the Commissioners -- we may want to think about whether those entities would have to registered Canadian companies. I’m throwing that out there. I think it’s something that needs to be thought about.
5339 And as I mentioned, those are only example criteria and I think it would be a proper place at CISC to develop that list a little bit further.
5340 COMMISSIONER MacDONALD: Thank you for that.
5341 MR. DABLIZ: If I may just add just an operational twist to this.
5342 In terms of the Interconnection Access Agreements, it’s a good way to be able to ensure compliance as well. So this isn’t only for us to be able to make sure that things are happening or whoever they interconnect to. But what happens when a call or some type of event goes to the PSAP and they want to know how to contact this person? If we don’t know where it originated from, if we don’t know how it got there, who is ultimately in charge of that, how does the PSAP actually follow up if they need to?
5343 Today we provide contact lists for all the people that interconnect so that they can reach their 24/7 centre. And if for some reason they can’t do it, they can contact my 24/7 centre directly and then we’ll get them in contact with those other people, be it a reselect or a collect WSP or whoever it is.
5344 So in the future that continuity of operation is paramount because these calls can really -- it’s expanded quite a bit from who can make the calls and where they can come from.
5345 COMMISSIONER MacDONALD: Okay, thank you.
5346 Just switch over to funding for a moment. Obviously under your model we would continue with a tariff-based system. Do you envision that being one global tariff for both current and NG9-1-1 or two separate tariffs, one for each?
5347 MR. GAUVIN: So good question. The end state -- so when everything is done and E9-1-1 is gone, we do envision one tariff. To get there we envision a new next-generation 9-1-1 tariff.
5348 So like we said in our opening statement, we recommend there be a trial. Based on the trial results we’re going to have a better understanding of the costs of NG9-1-1. And then we would do cost studies and issue the tariff so that it becomes available to all the PSAPs in our territory. And that would be all the new components for NG9-1-1.
5349 So Fadi’s team that supports 9-1-1 calls, you know, if the centre is on NG9-1-1, that’s already covered by the E9-1-1 tariff and those costs wouldn’t be already converted to the NG9-1-1. So when we decommission E9-1-1, we would have to do a complete new cost study to reassess nuts to bolts what’s left. So the tandems, all the legacy equipment that we decommissioned would no longer be there and we would have a nuts-to-bolts tariff with a cost for everything, including his team, in an NG9-1-1 tariff. So ultimately one, initially two.
5350 COMMISSIONER MacDONALD: Would some of the E9-1-1 facilities be leveraged for NG9-1-1?
5351 MR. GAUVIN: Well, some for sure -- and Fadi touched on this already -- for example, for the ESInet a lot of the equipment is already there; the physical connectivity to the PSAPs. There might be other things. I’ll just pass it on to Fadi.
5352 MR. DABLIZ: Certainly. So things like the customer edge router, pretty much the entire data network that’s out there today that’s something that will be reused.
5353 But if you’re talking about more of the voice components and so on, there are some. The majority of it does go away. So the big ticket items, those 9-1-1 tandems and so on and so forth, the lines, the trunks to the PSAPs, those types of things ultimately do disappear. But there are some back end systems that will continue to remain, and a few other minor systems.
5354 But again, the majority of E9-1-1 does get decommissioned.
5355 COMMISSIONER MacDONALD: So during the transition, if certain elements can be leveraged and others can’t, do you have any idea how much more expensive it’s going to be than the current state? As we move through are we going to -- if we’re not -- are we doubling our costs, are we tripling our costs?
5356 MR. GAUVIN: So we’ve had a lot of internal discussions on that. I can’t say it’s going to be $0.05 because if it’s $0.06 I’m going to get fired five years from now. What we can confidently say is that it won’t be a doubling of the cost. So, you know, it’s $0.13 per line now with the accesses today. We anticipate that the end state is going to be that or less, probably less. How much less, we don’t know.
5357 But we’re talking, you know, in terms of burden on per access lines we’re talking maximum another $0.13 per access line and likely somewhere less than that.
5358 MR. DABLIZ: However, that does assume that we are talking about the model that we proposed. As soon as we start putting RFPs, RFIs or other types of things it really becomes an unknown and swells.
5359 COMMISSIONER MacDONALD: Understood.
5360 Certain parties have expressed a concern that there may be a lack of transparency from their standpoint, and into the costing process because certain elements need to be kept confidential, especially elements that may -- and your networks -- that may support more services than just 9-1-1. Is there anything that could be done either within Bell or within the Commission that can help remove those fears or perhaps increase the level of transparency into the process?
5361 MR. GAUVIN: Well, in terms of fears, I think it’s important for those parties to understand that the Commission actually has access to all of that information, including the confidential information. We’re not hiding those costs. The Commission actually sees all the costs and who the vendors are, and all that information, and they can make decisions based on that.
5362 But in terms of confidentiality, unfortunately it’s true, some things have competitive sensitivities. And in terms of putting it down on the public record, there are sensitivities there. And I don’t think an RFI or an RFP would necessarily be more transparent. You would know what the ultimate cost is. So the vendor would say, “I’ll do it for $50 million; do you want to pick me?”
5363 Unless the RFP is way more detailed than one would think, I don’t think the RFP would say, “And by the way, my vendor is going to be this and my cables are going to cost this” and all that stuff. The RFP winner wouldn’t put all those costs on the record either.
5364 MR. MALCOLMSON: Just to add, Commissioner MacDonald, I think in terms of relative transparency, we have a tariff process now with regulatory oversight, and the regulator looking at the costs and validating them and issuing a regulatory decision versus, as Phil says, an RFP process where you’ve introduced a profit motive and the successful bidder to his or her credit is going to want to make money off of the project. And I think, you know, the element of transparency, as Phil says, probably more transparent through a regulatory process that’s supervised.
5365 MR. GAUVIN: And in our opening statement we referenced New Jersey, and there’s a footnote referencing a report, an FCC report. You might think that we cherry picked New Jersey because it’s a high rate or something like that, but it’s actually one of the lower rates. And some of the states they just say, “I don’t know what the costs are”, right, in that report.
5366 So in terms of transparency, I think we’re very much ahead of the game, especially with the tariffing process because there is someone that vets the costs. But just looking at how it is in the U.S., it’s mind boggling and eye opening.
5367 MR. GAUVIN: So perhaps just a little add-on statistic there -- and again, this report is a great, great source of information. So in New Jersey $121 million was collected for 9-1-1, 12.5 went on network.
5368 COMMISSIONER MacDONALD: So two tariffs to start out during the transition. Ultimately we’ll get back to one. And I may be able to predict your response to this question; if we’re going through that process does it also make sense -- as some have suggested -- to open up the current tariffs given that they were done a number of years ago, and move forward with a new cost study?
5369 MR. MALCOLMSON: I’ll start, Commissioner MacDonald.
5370 Our answer won’t surprise you. The answer we think is no, but the reasons behind it are as follows. You’ve had lots of evidence. I guess I would call it -- a suspicion may not be the right word, but a concern by some customers that perhaps their current rates are too high. And it simply seems to be because the cost study hasn’t been updated, and that’s fair.
5371 It’s likely that with respect to the current costs, the cost studies, some costs have gone up some costs have gone down. But I think more importantly, over the intervening 18 years since the cost study was done, there’s a bunch of costs that haven’t been accounted for.
5372 And I’ll ask Fadi to speak to those in a minute. Those aren’t factored into the current rates that are being charged today. And I’d also note that -- and you heard this evidence -- the ILEC with the most recent cost study that was done, I think, in 2010 has a higher rate of $0.17 than the current Bell rate of 13 and 10 for wireline and wireless.
5373 So at the end of the day, a new cost study doesn’t always yield lower costs. There are costs that haven’t been accounted for and would be factored into a new cost study.
5374 And then when you think of the resources, effort, time both from the Commission and from the applicant doing the cost study that are required, I wonder if at this stage in the game that should be our focus or whether we should be focusing on transitioning the next-gen 9-1-1.
5375 At the end of the day you’d be doing a cost study on a network that I think we all hope is going to be decommissioned shortly. So from that perspective, I don’t think it makes a ton of sense but it is worthwhile having Fadi speak to some of the costs that aren’t present in the current model and would be present in a new one if we went through that process.
5376 MR. DABLIZ: So I can give a few examples here. One of them would be the lat long layer that we introduced about five years ago. So we had PSAPs come to us and say, “Well, we’re looking at this GIS and we understand that’s sort of the next iteration of the M saga, the master street address guide which takes care of addressing today.” So they wanted to be able to put a lat long layer, so we modified our mapping system so that those that are ahead of the curve and actually have GIS systems and have these lat long coordinates can put that layer and that would be transmitted as part of their ALI record, their 9-1-1 information record. That’s just one example.
5377 There’s all the support testing that we do today that was never envisioned back then. So today we have contingency plans for every single PSAP, which was not the case back then. Some of these PSAPs test it every month, some of these test quarterly; sometimes it’s bi-annually or annually.
5378 We’ve got new PSAPs. As a matter of fact, there are double the PSAPs today than were envisioned or calculated back then. We also have the scope of the PSAPs, where they’re located. They’re going up to -- we have them in Hearst, and Thunder Bay; high cost serving areas.
5379 The amount of lines that they have. The amount of lines in the network alone has expanded a lot more than ever anticipated, and most of it to do with the introduction of wireless. There’s a lot more telephone numbers out there than ever anticipated when this was done.
5380 There’s also the access. There’s a myriad of things that have been done over the past 18 years that are not calculated in there. And I could probably talk until this evening, but I’ll stop there. Thank you.
5381 MR. GAUVIN: I just want to do a quick addition, correction. I think it’s more of an addition.
5382 When we say “not accounted for by the current rate system”, it’s worthwhile to quote from the Commission. There were two decisions in November regarding rate increases by TELUS and MTS related to 9-1-1 rate increases. And in that decision, I’m just going to read two paragraphs. This is from the TELUS one. And there’s nearly identical wording in the MTS one. They were issued on the same day. And it said:
5383 “The Commission’s general practice has been to establish rates based on costs. However, the Commission chose to adopt the frozen-rate treatment described above for rates for 9-1-1 services and other services that provide important public safety and social benefits. The frozen rate treatment does not contemplate a price ceiling, as submitted by TELUS; therefore, any change would be an exception to the existing policy. The key benefits of this treatment are (1) stable revenue for 9-1-1 service providers so that they can plan and pay for ongoing maintenance and investments in their 9-1-1 networks, including maintaining functionality and upgrading equipment; (2) no tracking by the Commission of 9-1-1 service providers’ year-to-year costs, regardless of whether these costs increase or decrease; (3) administrative efficiency for 9-1-1 service providers; (4) regulatory certainty for interconnecting competitive local exchange carriers and wireless service providers; and (5) high-quality public good services for consumers at stable and reasonable rates."
5384 And by the way, for the record, this is Decision 2016-455.
5385 So it is accounted for. It's a frozen rate. We win some, we lose some. In this case, you know, TELUS and MTS lost some because they had some increased costs and they were denied their increased costs based on the fact that it was frozen.
5386 We had a rate increase denial, you know, on ICLU features fairly recently as well, so as we move forward, you know, we might win some, because at some point, the costs will go down, but we've certainly lost some as well over the years. So it's a stable-rate treatment and it is going to be decommissioned fairly soon. You know, hopefully, in five years, it will be decommissioned, potentially earlier than that and potentially later than that, depending on PSAP migration and gateways and all those issues.
5387 COMMISSIONER MacDONALD: Well, thank you, that's -- it's helpful to understand some of the new inputs that would go into a cost study and it does my heart good to know that you review our decisions so carefully.
5388 With respect to other potential contributors, do you see or believe that it would be appropriate at some point for non-voice providers to contribute, given the new functionality that will be coming with NG9-1-1? And if the answer to that question is yes, then my follow up would be, at what point?
5389 MR. DABLIZ: So the answer, I think, would be yes, that would certainly follow the traditional method of, you know, if you're using the network, you pay for it. If you have access to the network, you should pay for the network. Now, I think part B was when?
5390 COMMISSIONER MacDONALD: Yes.
5391 MR. GAUVIN: So it would be likely when the PSAPs have made the changes that they need to make in order to consume -- if we're talking about -- let's use an example, perhaps telematics, right? So today we know if something happens in the car it goes to an operator. Well, in the future -- and there's a lot of work being done at NENA and a whole bunch of other places to look at what happens if we can automate that and send that 9-1-1 call through and then PSAPs could hear what's in the car, automatically get some telematics data to say there were two people in the front seat, one was wearing their seatbelt. It helps to figure out what they need to do in terms of getting the ambulance there and so on.
5392 So when would that be appropriate to start charging them? I would say when the PSAPs are able to start consuming the data and we can start running it through the network. Then it will actually be of use to somebody and that's when I think it would be logical to start charging.
5393 COMMISSIONER MacDONALD: Okay. In your opening remarks, you touched on Real-Time Text, and you note that the devices aren't actually out there on the market yet. They are coming. From a network standpoint, are there any challenges that you think should be highlighted, with respect to what would be required, at least on the Bell network, to make use of Real-Time Text once those devices are available?
5394 MR. GAVIN : So I'm going to pass it over to Denise and Guy. And just to give some background here, you might be asking yourselves or some people might be asking themselves, "Why don’t we support every single means of communications in the 9-1-1 network?"
5395 I think Guy gave a very long list of how he would choose a trusted entity. A lot of that has to do with having location information and traceability associated with the call. And there's challenges associated with that.
5396 So I'll hand it over to Denise to talk about the RTT and then with the rest of the current challenges, Guy can take over.
5397 MS. POTVIN: In terms of RTT, we envision that as a replacement for TTY. So we know that TTY is a technology that's been around for a long time, and it's no longer working very well in IP. So we know we have to go to RTT, and we will start to see some products next year. This year they're talking about over the top applications for RTT, but those solutions don’t provide location, and one of the key critical things for 9-1-1 is the ability to be able to locate a 9-1-1 caller. So next year we will start to see some products.
5398 But what is important -- and it's been touched on by some parties -- we need to be -- we need a plan for transitioning to that, so it's not just a matter of looking at whether you have devices or whether we as a wireless service provider when we operate them over (inaudible) network, so we need to know when the PSAPs are going to be ready.
5399 So our recommendation in this proceeding has been let's have the Commission task the ESWG to have this full view to how do we migrate to RTT? And it has -- the ESWG has looked at that in the past in 2009 and came to that conclusion that when it becomes available, it will be time to transition to it. So I think the timing is getting -- we're getting there.
5400 COMMISSIONER MacDONALD: A question -- and I guess I'm asking you to look a little bit into a crystal ball, but you're a large wireless provider as well, and based on your experience with how quickly new devices are adopted by Canadians, how long do you think it would take once the devices are available in Canada, how long it would take for say, 50 percent of the population to have a device that is enabled with RTT?
5401 MR. GAUVIN: Well, so that's quite the crystal ball. I can tell you when it's going to start. So we know that in the U.S. they're doing trials of an over the top application later this year, and ATT and Verizon are expecting devices with native applications in 2018. So initially, the devices will support those, you know, next year. In terms of 50 percent, you know, look at cycles of adoption for cell phones. You know, two, three years after that, we might see a majority.
5402 If you want a more detailed estimate, we can take an undertaking for next week, but I would think that as devices converge or get transitioned, you know, it would be three, three, four years after that.
5403 COMMISSIONER MacDONALD: Yeah, if you do have some thoughts that you could undertake to provide us, understanding that, you know, like I said, you are looking a bit into the crystal ball, so you can't be too exact, but it would be nice to get a little bit of visibility into that.
5404 MS. POTVIN: We will undertake this.
5406 But I wanted to add something. It's important to see where -- like, we know the FCC has looked at the transition to RTT, but there is a -- what they call a "safe harbour". They don’t plan on leaving anyone behind, so that if someone was still on TTY, for example, they still have service. So it's not a question of waiting until you have critical mass and then cut off people. So it's a smooth transition so no one is left without a service during this transition.
5407 MR. GAUVIN: I just want to highlight something about RTT as well, because RTT, when I first heard it, I heard Real-Time Text and I was thinking of you know, the nineties, ICQ. That seemed like Real-Time to me, and how come we're still talking about Real-Time Text now?
5408 And Real-Time Text is going to be integrated with the voice service on wireless, so RCS -- and we heard yesterday, you know, someone say that RTT is a subset of RCS, but it’s not quite accurate, and if you want more details on that, Guy can get into that. But RCS is an evolution of texting SMS and RTT would be integrated in voice, at least, the way that they're implementing in the U.S. and that we anticipate to implement, you know, in 2018, 2019.
5409 And the big advantage of that is that you have location information associated with the voice call with the RTT session. So from the 9-1-1 perspective, that becomes very interesting, which you wouldn't have with RCS, at least not in the -- it's not specified this way for now and we could have CISC ESWG look into the stuff for RCS. But RTT, we expect to have location information associated with it.
5410 COMMISSIONER MacDONALD: Okay, thank you.
5411 We've talked with other intervenors about the possibility of an app, and all of the important information that could be made available to PSAPs and first responders through the app. But you proposed an “Application Programming Interface” to guide the development of 9-1-1 apps. I’m just wondering if you could explain that concept to me?
5412 MR. GAUVIN: Sure. In short, it’s setting up standard which explains to app developers what they need to develop their app towards in order to be compliant with the NG9-1-1 network. So the vision would be instead of having a next-generation 9-1-1 app developed by, you know, someone to be used with the NG9-1-1 network, you would develop the NG9-1-1 network and the application developers will develop whatever they want to develop.
5413 And just to give an example, let’s say I’m an entrepreneur and I approach the Rideau Centre and building owners and say, “At times of emergency I’ll get your schematics from you and I’ll distribute those to PSAPs.”
5414 So I might develop, you know, the building schematics app and accumulate those schematics and I’ll be responsible to getting those consents from the schematics providers and provide those to the PSAPs. And I’ll have to develop my app using the API to meet those standards. And if it’s an Apple app, it will have to meet those standards as well, and it’s an Android app, it will have to meet the Android standards as well.
5415 And that app developer will have a new source of information available for PSAPs. And you know, it’s outside of our control but it enables those types of innovative services out there. So it could be a pet lover that says, “Tell me if you have a pet and then I’ll let the emergency services know that you have a pet, you know, on the 9-1-1 call so there will be the information there.”
5416 COMMISSIONER MacDONALD: Where would you place that on the wish list or on the priority list? Do you think that should be early in the deployment of NG9-1-1 or are there more pressing issues that need to be addressed before that?
5417 MR. GAUVIN: Well, I think the benefits of NG9-1-1 are new types of communications. So in terms of the API, fairly early in the transition. I don’t know if it would be day one but not too long after day one. But in terms of actual applications being developed, you know, that depends on the needs from PSAPs. And there are some vendors out there -- you know, you had Freedom Mobile who put one and there’s other vendors as well that are out there. So you know, they would probably develop apps fairly soon after the API is developed.
5418 COMMISSIONER MacDONALD: And how do collectively we educate Canadians and manage expectations? Because I can see a scenario whereby an app or a particular NG9-1-1 feature may be available in the GTA; it may not be available in Prince Edward Island.
5419 MR. GAUVIN: Yeah. So different PSAPs will likely adopt different applications at different times. We’ve heard from Calgary earlier this week and they said they’re already, you know, getting text messages and stuff like that. So I’m expecting -- not through the 9-1-1 network, through their -- they basically use -- it’s not personal devices, but they have devices, basically tablets in their PSAP centre. So I’d expect them to be an early adopter of, you know, the texting-provider’s app, for example.
5420 I don’t think we want necessarily to cater to the lowest common denominator and say, “Calgary, yeah, well, you think you can save lives? Don’t do this because not everyone is ready.” If they want to do it they probably would. And Calgary as a city and the PSAP would have a public information campaign around that and they’ll say, “In Calgary you can now text 9-1-1.”
5421 So hopefully by saying, “In Calgary you can now text 9-1-1” people in Montreal won’t necessarily get that impression. And hopefully it will put pressure on all the PSAPs to raise their games and develop new services.
5422 The beauty of this system is that new ways of communicating will evolve and people will try new things. And you know, maybe Calgary will try or some other PSAP will try something and it doesn’t very well and the PSAPs will discuss together and they won’t want to use that anymore. But that experimentation and those new services, in terms of the apps and the new means of communications, I think that’s something to encourage.
5423 We don’t necessarily want to standardize across the country. And I’m just saying that in terms of what I expect. Because as carriers, you know, truthfully we don’t really care because we’re agnostic; we’re just supporting the network and taking the communication from point A to point B.
5424 COMMISSIONER MacDONALD: Okay, thank you. Just a couple of more questions and then my colleagues may have some follow-ups.
5425 Whether it be a 9-1-1 app or an interface or what have you, there’s the potential for a lot more information to be coming to the PSAPs and the first responders. And much of that information will be confidential in nature and raise some privacy concerns. So in your mind, can you shed some light on what specific privacy measures should be put into place? Some have suggested an opt-in or an opt-out of particular services, that an individual could decide to be part of it or not. Should express consent be given for the use of specific information? Do you have thoughts on that?
5426 MR. GAUVIN: Sure. So we have different roles, right? So we have a role as a 9-1-1 provider, in which case we don’t necessarily have that much information. We have a role as an origination network. So Bell Mobility or Bell Canada, one of our callers calls 9-1-1. So in that case the originating network might have customer name and address.
5427 And I’ll give an example. A few years ago there was an incident where someone cut their leg with a snow blower and they couldn’t get an accurate location. And Bell Mobility actually managed to find the brother of the person through the account information and they called the brother who then sort of knew where he was and they found the appropriate person.
5428 So in terms of that information, first of all, Bell is allowed to convey information in emergency situations under PIPEDA in order to save lives in direct emergency situations. So I don’t think that’s going to change and I don’t think we need new legislation or new rules for that.
5429 But then take another example, let’s say the building schematics example that I had before. So let’s say someone cuts their leg or whatever and they’re in a building and they want the building schematics of getting in the building. Then they might contact Bell Mobility for information if they don’t have the best accurate location information. They might see a flag saying, “Oh, I have some schematics information from this app that I have.” That consent would have been gotten by the schematics acquirer, whatever, the schematics co. app provider. And they would have whatever consents that they need.
5430 So I gave the example of going to the Rideau Centre and signing an agreement saying, “The Rideau Centre --” which is a shopping mall, by the way, for those that don’t know, in Ottawa -- but go to the Rideau Centre; get their consent, written consent for the schematics, and they’re responsible to abide by privacy legislation for that use. And PSAPs will have their own concerns as well because they have their storage of information and all that.
5431 So there’s different components of the network and there is different legislation that applies and there is different puts and takes. But all of that is already there. So I don’t think as part of this proceeding -- and yes, there’s going to be new forms of information in the future. The rules are fairly clear in terms of privacy in that respect. It’s just that the players might be slightly different.
5432 COMMISSIONER MacDONALD: Okay, thank you.
5433 Bell has extensive relationships with a large number of Canadians, obviously, and we heard from a number of disability groups earlier today. And I’m just wondering, is there anything in the support of your clients or things that are on your radar or changes that you feel are coming that could improve accessibility in the design and the implementation of 9-1-1 that we should take into consideration?
5434 MR. GAUVIN: Sure. I’ll give an example. This morning we saw the CNIB with their video of a deaf-blind person that had a paper saying, “I’m deaf-blind. I can’t speak. Call this number.”
5435 Last year -- or I think it might have been two years ago -- we actually made a contribution to CISC ESWG on enhanced wireless subscriber data for the current network, so not necessarily for next-generation networks.
5436 And we said that right now -- and just some context. Right now with a wireless call, when you call 9-1-1, you get the X and Y location or the lat/long on a map with a certain radius of certainty. You don’t have a name and customer address.
5437 And we said, “Well --” because we’ve actually had discussions with PSAPs and with other groups -- “We have concerns about this especially in urban environments,” just exactly like was described this morning.
5438 And we said, “Well, it would be possible to implement something where it would be user-inputted data.” So saying, “I actually live in this location, in an emergency situation.” And that information will be conveyed to the PSAP.
5439 Certain cable carriers -- Rogers, Videotron, and Eastlink -- wrote in to say, “That would be an RNV of a 2003 decision, which says that wireless service providers shouldn’t have to update the ALI database.” And that TIF was basically closed because TIFs the way that they work, they work by consensus.
5440 So we actually think that there is a solution out there. We’re more than willing to develop it and have it in play, even before next-generation 9-1-1 is developed and in place. We think there’s a solution out there that would allow for -- just like this morning what you saw on the video -- user-inputted data that would say user is deaf, blind; call interpreter. So that when the PSAP gets the call, they would call the interpreter so that it’s on the way as the first responders are on the way.
5441 MR. DABLIZ: If I may just add a little bit onto that.
5442 I think you were looking for sort of what’s coming down the pipe in the future for these services. Well, in terms of what’s here right now with the TEXT with 9-1-1 service, I’m happy to report that as of right now there are four primary PSAPs across our entire network -- actually, three -- who do not have T9-1-1 enabled. At the end of this month there will be one left, and at the end of the first quarter, we’re told that that last PSAP will migrate, meaning every single primary PSAP -- so wherever E9-1-1 is available across our territory, PSAPs will support T9-1-1.
5443 Further to that, next week we have a team of eight PSAPs across the country that will be testing T9-1-1 -- or sorry, a PSAP registry, registry of Canadian PSAPs for TEXT with 9-1-1. So the scenario we heard this morning where someone calls 9-1-1 on behalf of somebody else -- perhaps in a different city, they couldn’t contact this place -- all of that is a thing of the past with this new system.
5444 Every primary PSAP will have access to this registry of Canadian PSAPs for TEXT with 9-1-1 and give them the ability to do these lookups. Not only that. A new feature that was recently introduced call three-way calling -- or three-way transfer I should say -- for text messages will allow 9-1-1 calls to have those text messages or text sessions actually transferred across the country.
5445 So this is a wonderful example of full end-to-end coast to coast to coast interoperability for TEXT with 9-1-1. And that’s a product of what’s happening over the next couple of weeks with some of these new improvements.
5446 MR. GAUVIN: I just want to seize on that interoperability point. So this registry of PSAPs, which is first all -- it’s a directory of all the PSAPs in Canada so that PSAP can transfer a T9-1-1 session to another PSAP. So if they’re calling and if they reach the wrong PSAP -- right now it’s possible to transfer the text session but not the voice session. So ideally, you know -- well, more than ideally, they will be able to transfer the voice call in the future based on this registry.
5447 But I remember attending a CITIG conference two years ago, I think, and they spoke of interoperability issues in terms of radio frequencies when you arrive in a certain area.
5448 And by that what I mean, well, think of Lac-Mégantic, for example. There’s a huge disaster. A lot of help is sent to the area. So you have military that goes there, and you have even U.S. responders, and you have responders from everywhere around trying to arrive to help. There’s no national database of radio frequencies to use so that fire talks to fire and police talks to fire in a certain area.
5449 You would think it’s an easy solution, you know, there should be an easy solution. But, no, there’s a fear that the feds will fund something for a certain period of time and then it’s not kept updated and stuff like that.
5450 So this database and registry that Fadi is actually talking about can evolve over time. When we go to NG9-1-1 there’s probably going to be phase twos and phase threes and phase fours of this database, which has more and more information that’s of use for interoperability for Canadians.
5451 MR. DABLIZ: And this will evolve as part of NG9-1-1. We know that there is this concept. And Guy will refresh my memory on the acronym, PSAP agency locator.
5452 MR. CARON: Yeah, the NENA i3 standards define the agency locator service, which allows PSAPs to find primary and secondary agencies. They are registered through that mechanism. So it’s an i3 defined mechanism which will come with our i3 compliant NG core since the Commission agreed that i3 was the way to go.
5453 MR. GAUVIN: So this work isn’t a dead-end, it’s evolvable. And it will evolve as part of NG9-1-1.
5454 COMMISSIONER MacDONALD: Thank you. And I appreciate the real time update on your activities in that regard.
5455 Thank you very much, those are my questions.
5456 THE CHAIRMAN: Thank you. We’re almost done.
5457 I think legal has a few questions for you.
5458 MR. LY: Thank you, Mr. Chair.
5459 At paragraph 9 of your presentation, you note that Canadian 9-1-1 providers have built meaningful relationships with -- amongst other entities -- primary and secondary PSAPs.
5460 Does your company provide connections for all secondary PSAPs in your territory?
5461 MR. DABLIZ: Yes. And there has been some confusion. I’ve heard a few different definitions so please let me ---
5462 MR. LY: Yeah.
5463 MR. DABLIZ: --- if I can just take 30 seconds to be very clear on what that means.
5464 So obviously primary PSAP is pretty straightforward. That’s the person that takes the first call. That’s the one that says, “Do you require police, fire, or ambulance?” That’s the primary. So, yes, they’re all interconnected.
5465 The secondary PSAPs that we’re talking about are the police, fire, or ambulance. So those people that would receive those calls or the calls would be transferred to. And also, as I mentioned, the backup sites. Yes, primary, secondary, and backup under those definitions, all of them are IP-enabled at this time, and have been since early 2016.
5466 MR. GAUVIN: Just to clarify that primary PSAP definition -- which never happens, I never clarify Fadi. The primary PSAP isn’t just the first one that gets the call. Because if you think of a nomadic VoIP, for example, they actually divert a call centre and then that will go to the primary PSAP.
5467 And if you think of the single PSAP proposal that was on the record, that’s also -- in our view -- not a primary PSAP. It would be a PSAP of last resort, or a third-party responder or call centre that would then route to the appropriate PSAP. The primary PSAP is the one that when you get the call is automatically routed to the correct primary PSAP.
5468 MR. DABLIZ: Yeah, I should have said E9-1-1 PSAP to be more precise. Thank you.
5469 MR. LY: So do you know if this approach to a connection of your secondary PSAPs is unique to your company, or are you aware of whether TELUS does this as well, or other companies?
5470 MR. DABLIZ: Similar but not exactly the same. I would ask that you follow up with TELUS specifically; they’ve got a bit of a different arrangement.
5471 With SaskTel, we actually partnered with them. So when we deployed our IP network, we worked with Sask because they have to provide the direct interconnection to their PSAPs through our network. So we did work with them on that so I know that they are. Aside from that, I can’t say with absolute certainty.
5472 MR. LY: Okay. One final question on that point. Are these connections for secondary PSAPs commercial arrangements?
5473 MR. DABLIZ: So they’re exactly the same as the primary PSAPs.
5474 MR. LY: Okay.
5475 MR. DABLIZ: So the IP VPN that we put in place terminating to a CE or customer edge router, that is exactly what we have for the secondary PSAPs.
5476 But to your point about commercial arrangement, I mean, this is all part of the E9-1-1 tariff, or the 9-1-1 tariffs that are in place today. They don’t pay for that out of pocket.
5477 So same for primaries and secondary. If they move from this location to that location, everything is taken care of. If the municipality who actually designates who the PSAPs are decides we’re not going with this primary anymore we’re going with this one, all of that work -- or changes secondaries, or there’s amalgamation, or demalgamation -- whatever the scenario -- when it comes to primary, secondary, and backup PSAPs that are on the current E9-1-1 network, all of that is taken care of under the tariffs.
5478 MR. LY: One last question. Some parties of this proceeding have advocated that an NG9-1-1 service be funded by way of contribution fund. In order for this to occur, the Commission would have to first determine that access to 9-1-1 is a basic telecom service, a term that isn’t defined in the Telecom Act.
5479 Regardless of your position on the appropriateness of funding by a contribution fund, do you have any views on whether or not 9-1-1 access services, in particular NG9-1-1 access services should be considered a basic telecom service?
5480 MR. GAUVIN: Sure. I’ll still opine on my position if you just allow me.
5481 But in terms of our position, we just think that’s just adding administration and the tariff is already clear.
5482 But in terms of just legally, we actually had a very similar conversation in the context of the Basic Telecommunications Services proceeding. “Basic telecommunications services” appears only three times in the Act. So the definition of TSP in section 33, which is about affiliates and making sure that your affiliates are captured by the basic telecommunications services clause in 46.5. And 46.5 says that a fund can be established to provide continuing access to telecommunications services.
5483 So in the context of NG9-1-1 where we’re talking about new investments in a new network, it’s not clear that it’s applicable.
5484 That being said, our reasons for not being in favour of a contribution fund are purely practical, right? It’s not just the jurisdiction. We think that the current system is working well; the payees are working well. It’s not an undue hardship on a per-access-line basis. And why fix something that’s not broken and why deal with a transition and an administrator for a contribution fund?
5485 THE CHAIRMAN: That wasn’t actually the question. It was all assuming all that. We know what your position is. Do you consider it to be basic or not?
5486 MR. GAUVIN: Well, I think I would say 9-1-1, yes; establishing a fund for NG9-1-1 investments, probably not.
5487 MR. MALCOLMSON: The answer to his question is “yes”.
5488 THE CHAIRMAN: Thank you.
5489 MR. LY: That’s all my questions.
5490 THE CHAIRMAN: I mean, the preamble was -- we know your position on whether it was a good. It wasn’t an opportunity to reiterate your position; we understood that. We ask questions to get -- especially at 5:59 after a very long day. Thank you very much.
5491 Anymore questions?
5492 MR. LY: That’s all.
5493 THE CHAIRMAN: Thank you.
5494 So we’re adjourned until 8:30 -- I repeat, 8:30 tomorrow morning. On recommence à 8h30 demain matin, merci.
--- Upon adjourning at 5:59 p.m.
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