Timothy M. Denton

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Next generation 9-1-1

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The CRTC has seized the issue of next generation 9-1-1 services, made it its own where it could, and has firmly laid out guidance for other actors where it has no jurisdiction. What I asked for in my report of 2013 has very largely come to pass. More remains to be done, however.

When I was asked to examine the issue back in 2012, no one had ever been tasked with taking a comprehensive look at the entire system. To his great credit, JP Blais and my fellow commissioners empowered me to do so. It was apparent that important issues were falling between jurisdictional cracks. It was equally clear that the devices in our hands were far in advance of the capabilities of the telephone-based 9-1-1 system to respond.Hence the hearing and report which is the subject of this blog.

The CRTC holds powerful tools in relation to 9-1-1, but the provinces, municipalities and other parts of the federal government, such as Public Safety, hold the others.

The situation was characterized by rapid technological advance, obsolescent infrastructure, unchanged mandates, and a failure of Public Safety to do what it could to achieve national coordination. Possibly its failure to act was caused by a disinclination of provinces to coordinate their activities. For whatever reason, the parts of the 9-1-1 system outside CRTC jurisdiction remain less well organized than one would hope. Progress may be underway there too.

The Commission has chosen not to innovate in some crucial respects. The incumbent telcos will remain the masters of the NG 9-1-1 networks, which the Commission calls the "ILEC stewardship model".  That is no surprise. The CRTC will also retain a firm hand in standards development, because it envisages that standards will continue to be developed and adopted by a group within the Canadian Interconnection Steering Committee, and umbrella committee for various technical issues, which are addressed by specific sub-groups.

The sub-committee that deals with 9-1-1 matters is the emergency services steering group, known by its acronym, ESWG.

Since the Commission has opted for institutional arrangements that "enables unrestricted and direct Commission oversight" (para.68), it had better think about the adequacy of its supervision of the ESWG, and how the ESWG operates.

The ESWG is characterized by telco dominance of technical matters, and an uncertain status for anyone not already within the club. It should not be in doubt that anyone can join its deliberations. Participation should not be at the pleasure of its chairman or a majority of its members, but should be established as a matter of right.

Moreover, I think a strong case can be made that the Committee should be chaired by a member of the staff of the Commission.

In the ESWG the technical expertise lies preponderantly with the telcos, and the emergency responders and 9-1-1 people are by training and education not experts in communications technologies.Hence solutions are what the telcos agree upon.

Since the Commission has agreed to continue the profitable monopoly of existing 9-1-1 communications providers into the various aspects of IP-driven 9-1-1 emergency services, it behooves the Commission  closely to oversee the reasonableness of the tariffs, and the profits ensuing from them. It also is important for the Commission to take an active role by ensuring that  standards development makes no further entrenchment of existing monopolies than is absolutely necessary.

For instance, it is common practice in the Internet world to maintain registries of addresses that are under different management than the sellers of domain names. It is common practice for registries to be national in scope (such as dot ca) or global (such as dot com).

It is easy to envisage that the telco domination of the standards world through the ESWG  will ensure that Internet ideas will not disturb the tranquility of current arrangements, unless pressure comes from outside participation or from the Commission. For the time being, the ESWG is a club. As it grows in importance, ways will need to be found to make it less closed and more open to technical innovation and non-telco expertise.

It is also easy to see that major PSAPs (public safety answering points) have no particular need to be organized on a municipal basis, and that, moreover, a PSAP in Halifax could back up one in Calgary a various times of the day. Or that modern technologies allow for primary PSAPs to be limited to three or four across the country. This is a matter for the Department of Public Safety and the provinces to attend to.

My hope is that the CRTC, by asserting its jurisdiction so forcefully over the subject, will continue to pay close attention to standards development and deployment, and commercial arrangements within this newly re-confirmed big carrier monopoly.

The Commission seems ready to start asking questions about value for money in the 9-1-1 system, by asking for reports on reliability, resiliency, and security.

In addition, by asking that all traffic transiting their NG9-1-1 networks remain in Canada, (at para.125) the Commission may have begun something important for peering in Canada. Internet traffic related to 9-1-1 would have to peer within Canada, rather than be sent to the United States, as is the practice now, since neither Bell nor Telus will peer with other Canadian ISPs.

Much has been set right by this policy. Much remains to be done. In exchange for re-confirming the incumbent stewardship model, the Commission has obliged to take a more active interest in the subject, and a closer vigilance of what Canadians are getting for what they pay. I shall keep my fingers crossed.

 

 

 

 

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Timothy Denton is a lawyer by training who practices principally in telecommunications and Internet policy and domain name issues, with a strong concentration on explaining what the technology is and what it means.

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Guest Friday, 15 December 2017
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