National Emergency Number Association
ONTARIO 9-1-1 ADVISORY BOARD
Letter to CRTC Addressing Decision 97-8 and 97-9
May 20, 1997
Mr. Allan J. Darling
Canadian Radio-television andTelecommunications Commission
Dear Mr. Allan J. Darling:
I am writing on behalf of the Ontario 9-1-1 Advisory Board, an entitysanctioned to serve and represent the 9-1-1 providers and users in the Provinceof Ontario. The recent decision of yours, (Canadian Radio-television andTelecommunications Commission, CRTC), of Telecom Decisions 97-8 and 97-9 fail toaddress adequately some of those decisions that effect the provisioning andoperation of 9-1-1 in our Province.
The Ontario 9-1-1 Advisory Board, (Board), is filing this appeal and/orclarification to you, (CRTC), so that these issues are clearly understood by theCommission to be of great concern to us. I want to make it quite clear that ourBoard does not oppose any telephone unbundling, only clear and decisive rulesthat insure the standard of 9-1-1 in the Province of Ontario remains the same,and has the ability to be improved in the future.
I along with another Board member have represented the Ontario 9-1-1Advisory Board at the majority of meetings under P.N. 96-28 9-1-1 sub-workinggroup stating the same concerns that we believe were either not addressed orleft open to interpretation by the telephone industry.
The following items are being appealed to the Commission for review,comment, and decision
- Telecom Decision 97-8, Section A, Item 9, Line 113.
The Commission has agreed with the Stentor submission that 9-1-1 is not anessential facility. As technically defined we would agree, but the argument isreally what the public perceives as essential when it comes to an emergency. TheCommission has recognized the importance of 9-1-1 but has left the rules ofinterconnection of 9-1-1 very vague.
We do not believe this is your intent and would request a review of thisstatement. A clear set of rules for all Local Exchange Carriers (LEC’s) must beestablished for interconnection and termination at Public Safety AnsweringPlaces (PSAP’s). There can be only ONE interconnectionto 9-1-1 and PSAP’s, not a multitude. This is clearly stated by the NationalEmergency Number Association, (NENA), for interconnection rules.
We would strongly recommend that the CRTC review this section and clarifytheir statement. We would suggest that the CRTC clearly state that 9-1-1interconnection must be through a single source as proposed by Stentor. We donot believe the words “to be appropriate” gives the LEC’s adefinite direction as to how 9-1-1 should be connected. PSAP’s cannot affordmultiple 9-1-1 providers terminating with different telephone lines, equipmentand software.
- Telecom Decision 97-8, Section B, Item 3, Lines 285,286 and 287.
In your decision you have indicated that “all service providersmust ensure, to the extent technically feasible, that the appropriate end useris provided etc.” without stating clearly who these service providersare. Do service providers mean LEC’s, resellers, or wireless providers?
You also indicate that the CISC 9-1-1 sub-working group is considering thisservice but do not give a clear mandate as to what “consideration”means. The CRTC must direct this 9-1-1 sub-working group on what interconnectionof 9-1-1 means and a definite time line to complete this work. This wouldinclude selective routing, call control features, public telephones and 9-1-1database standards.
The direction given by the CRTC must include ALL PROVIDERS OFTELEPHONE SERVICE and define who those telco’s are! They must not onlyinclude those that are determined to be LEC’s but must include all providers oflocal telephone service.
In Ontario the responsibility for the initial answering of 9-1-1 calls hasbeen contracted to a “neutral answering point” of which the telephonenumber and address determines who the 9-1-1 caller will be transferred to. As isthe case today some resellers do not provide the 9-1-1 callers telephone numberand address and this then causes errors to occur not only at these neutralanswering points but also at municipally run 9-1-1 answering points.
We urge the CRTC to clarify this decision that would then provide clearlydefined 9-1-1 rules for all telephone providers and the 9-1-1 answering points.
We would also insist that a definite time frame be established for the CISC9-1-1 sub-working group to establish these rules of interconnection. Resellersare already here and more are immerging each day without a clear understandingof the consequences of improper 9-1-1 interconnection.
- Local Number Portability (LNP)
This issue has been addressed through another Public Notice which will havea dramatic effect on the operation of 9-1-1 in this Province. It is the positionof the Board that this issue must also be addressed through the CISC 9-1-1sub-working group or to have this group given an opportunity for comment andinput.
The Board does not have adequate funding to attend another working group andwas of the understanding that ALL ISSUES relating to 9-1-1 were to bedealt with under 96-28! We have indicated to the LNP sub-working group of ourinterest to participate, but due to the financial restraints will not be able toattend any or all meetings. Our only involvement may be that of written comment.
We do not believe this will be sufficient for those to understand ourconcerns and would request that the CRTC allow the CISC 9-1-1 sub-working groupto have input and dialogue on this very important issue. These recommendationscould then be forwarded to the LNP working group.
- Telecom Decision 97-9, Item 18
The CRTC has stated that rates for 9-1-1 will be frozen at the levelsapproved, as at January 1st, 1998.
The Board has a concern on this issue in that we represent not only themunicipalities but also the citizens of this Province. We want to have anassurance that these rates will be discussed prior to any ruling by the CRTC.
We would recommend that the present rate for any 9-1-1 service in thisProvince be frozen for a minimum of 5 years.
- Wireless 9-1-1
The Board understands that under 95-36 and 96-28 that the issue of wireless9-1-1 telephone service was not a part of the Public Notice process. Wedisagreed with this position and we firmly believe that the time hascome for the CRTC to take a stand on this very important issue.
The Board has agreed to work with the Canadian Wireless TelecommunicationAssociation, (CWTA), on this issue. We do understand that this is a Canadianissue to the CWTA but the Board is concerned as these wireless calls areincreasing each and every day in this Province. The Board would like to havesome form of closure on this matter for the safety of the citizens of Ontario.We request to have a clearly stated Public Notice issued by the CRTC addressingthe interconnection of 9-1-1 and PSAP’s..
The technology is already here and PSAP’s want the time and opportunity toacquire the necessary interfaces once a decision of wireless interconnection isissued.
Also of concern to the Board is that one or more of the wireless carrierswill be determined to be a LEC and that the same rules of interconnection forthe other LEC’s will put the PSAP and the public at risk.
We urge the CRTC to respond to these issues in a timely manner. The safetyof the citizens of Ontario and the potential for a disaster becomes greater eachand every day without clearly defined rules and decisions on the interconnectionof 9-1-1.
Board members can be available to discuss these issues further or appearbefore the Commission for clarification. We assure the Commission that we willwork together with the telephone industry so that all aspects of 9-1-1interconnection are clearly understood by all those involved.
The safety of the public is of great importance to all of us and we knowthat a satisfactory decision that everyone will accept can and willbe achieved
Prepared and Submitted by:
Deputy Chief Derek Denson, DurhamRegional Police Service
Member Ontario 9-1-1 Advisory Board