Bram Abramson to the National Emergency Number Association ON

For the last few years, you've all been engaged in furious activity around what amounts to a forklift engine upgrade while you're driving down a very busy highway.

St. Catharines, Ontario
September 11, 2024

Bram Abramson, Commissioner, Ontario
Canadian Radio-television and Telecommunications Commission (CRTC)

Check against delivery

Good morning. As you may have just heard, I am a communications lawyer by trade and training-and, in the past, a very occasional ESWG participant-who began serving as the CRTC's Commissioner for Ontario about a year and a half ago, in February 2023.

In that capacity, it really is an honour for me be with you today, here on the traditional territory of the Haudenosaunee and Anishinaabe peoples. I thank them and pay respect to their elders.

Taking a step back

For the last few years, you've all been engaged in furious activity around what amounts to a forklift engine upgrade while you're driving down a very busy highway.

So I want to start by taking both a breath and a step back, so that I can acknowledge the privilege I have in addressing a room focused on the work of first responders on this particular day of the year, and at this particular time of day.

Exactly 23 years ago I was riding a public transit bus in Washington DC, on the way to the office. I had not yet gone back to law school. My job at the time was analyzing international telecom network infrastructure and traffic patterns. I had just been issued my first cell phone, an Ericsson flip phone on the VoiceStream network. I was sitting in the large back area of the bus, when I got a call from my father about what he'd seen unfolding in a news alert.

I had to repeat what he said to make sure I'd heard him correctly. In turn, the other people around me in the back of the bus started staring at me. Some of them started texting folks they knew to find out what was happening.

Even as someone whose job it was to think broadly and deeply about the place of telecommunications networks, it was that shocking moment that really became my introduction and template to how connectivity everywhere was changing the world. Mobile devices were important in the narrowest sense, for signalling danger or calling for help. But there was also a set of concentric circles emanating out from that core. We want to know that we can get help. We want to check that folks are okay. We want to reach out for reassurance. We want to verify information with a personally-trusted source. And so on.

The CRTC is responsible for checking on the health of the markets that make sure that all of those concentric circles function properly and well. We are required to intervene in those markets when, left alone, they wouldn't protect the interests of users or deliver the outcomes listed in the Canadian Telecommunications Policy and the directives we're issued by Cabinet from time to time.

But at the heart of those concentric circles is the ability to get help quickly-whether we're home, or whether we're out and about. And, increasingly, based not just on our own say-so, but also the say-so of devices that we deputize in our quest to stay safe. Whether it's a heart monitor embedded into our watch, a crash analysis algorithm connected to sensors in our phone, or a full-blown in-car system, NG9-1-1 is about improving the speed and efficiency and efficacy of emergency call receiving and dispatching, but it's also about keeping up with the technologies that are already knocking on your doors. About ensuring Canadians can reach 9-1-1 using smartphones and telematics, through voice, text, and eventually pictures and videos.

Which brings us full circle. Over the last 23 years, the way we do 9-1-1 has changed both outwardly, and under the hood.

Outwardly, we are driven by devices, we pinpoint locations, and call volumes are in a different world. In 2023, we estimated that 80 percent of 9-1-1 calls were being made on wireless devices. That's a sea of change from a generation ago.

At the same time, under the hood, you have become better at handling multi-agency and multi-jurisdiction situations. You have upgraded technology and training to support improved coordination and call management. There is a renewed focus on mental health, preventing burnout, and managing the emotional impact of your work. This conference is a great testimony to that.

So my first message this morning is a simple one. My colleagues at the CRTC and I recognize the importance of the work you do and the steady and continuous progress you have made. We appreciate your engagement in it. Thank you.

Current request

Let me next give you some context for what I mean when I talk about my colleagues at the CRTC. I work out of Toronto as one of nine CRTC commissioners.

Three of them, consisting of our Chair and two Vice-Chairs, are based at the CRTC headquarters in Gatineau. The other six, including myself, live and work in regions across the country. We are advised by an expert staff that administers our day-to-day processes and formulate detailed recommendations for us to consider. In fact, today I am accompanied by Mylène Germain, a senior analyst in our Telecommunications sector who has been working on Emergency Services files for many years, and who many of you know.

That structure might sound familiar to you. In some ways it's not too different than the municipalities with which many of you work every day. They likewise have a council whose members, or councillors, make formal decisions. They likewise have a staff that administer day-to-day processes and that advise them.

Of course, in other ways we're set up quite differently than a municipality. One of the most important differences is this: the CRTC is an administrative tribunal. Now, that's not the same thing as a court. We have the ability to be pro-active and initiate proceedings of our own motion. But, like a court, we have to consider applications before us fairly, carefully, and based strictly on the arguments and evidence that have been filed with us.

For that reason, there are some things that are off-limits to me. I cannot present thoughts or consider arguments on files that are currently or imminently before the Commission.

As you know, one of those files involves three applications to extend the March 4, 2025 deadline for completing the transition to Next Generation 9-1-1, and for decommissioning Enhanced 9-1-1 networks. I want to address that straight away.

I have no announcement for you today. I cannot discuss the proceeding, because the file is still before us. I cannot even talk about when you can expect to see the decision issued.

So thank you for your patience. I know how important this decision will be to all of you. We are working to deliver it.

Working across jurisdictions

Now, I know that some of you are ahead of the curve. And I know that we have several PSAPs here in Ontario that have already gone live with NG9-1-1. You have been working:

• to find the funding;
• to ensure your municipality has everything mapped;
• to upgrade equipment and software;
• to work with vendors to try to customize your platform to your needs;
• to roll out training;
• to figure out how it all fits together;
• to make sure no ball gets dropped.

Or maybe you're with a vendor, making sure you don't miss a major milestone opportunity, but also run off your feet to get the work done. Or with an ILEC that is pushing on every detail, onboarding everyone you can, and worrying about those who haven't yet showed up.

Of course, even those of you with processes that are well underway are still experiencing challenges. Like struggling to explain to decisionmakers why funding is needed, how broad some of the systemic changes are that are required, and generally, to get across what it's going to take to get it done.

I know that in some ways, I'm preaching to the choir. Those who are least equipped to transition to NG9-1-1 are not always among those engaged actively in the process and attending conferences like this one. But, to echo the theme of the conference, we are "transitioning together". Everyone has to be on board.

I've had the opportunity to visit PSAPs in Peel Region and in Hamilton. I look forward to getting to more PSAPs around the province. I'm likewise open to meeting with municipal officials to help explain the nature of the E9-1-1 turn-down deadline and the kind of changes required to ensure NG9-1-1 is up and running before that happens. I know that, sometimes, it takes the right municipal official or city councillor to hear the right presentation at the right time, to get everyone aligned, and to understand why even when it seems penny wise, waiting much longer might be pound foolish if their citizens are to continue to be served by 9-1-1. Our operators are standing by.

At the same time, I want to be clear about the CRTC's jurisdiction and role in the 9-1-1 ecosystem. We exercise regulatory oversight over the access that Telecommunications Service Providers facilitate to let Canadians contact a PSAP, wherever one has been established by the local government.

That means two things.

First, that we're a federal body. Our role is different than that of the provinces and of the municipalities they enable.

But, second, that even at the federal level, that our mandate is relatively circumscribed. Other federal agencies and departments have broad responsibility for public safety programs and initiatives. We're the telecom people.

For many of you that will be nothing new.

Ten years ago, we published our 9-1-1 action plan, in Telecom Regulatory Policy 2014-342. It followed up on a report put together by my predecessor, Commissioner Timothy Denton. It read in part:

"Given that its jurisdiction is limited to TSPs, the Commission considers that it would not be appropriate for it to take the initiative to create a governance or policy body that would oversee the 9-1-1 system as a whole, including provincial/territorial or municipal PSAP or first responder policies and standards. However, collaboration between stakeholders in the context of a common forum could be very helpful in dealing with complex, multi-stakeholder, and technical issues. For example, the ESWG will continue to bring together multiple stakeholders to develop solutions, standards, and processes related to the technical and operational implementation of 9-1-1 services in Canada."

The 9-1-1 system is a federated system. It only works if multiple independent entities - each with its own responsibilities, pressures, and contingencies - are both cooperating and coordinating. Here in Ontario, responsibilities are devolved to regional and local bodies. That means multiple jurisdictions, diverse services within each jurisdiction, and a patchwork of technologies, funding envelopes, and management.

And yet, across that patchwork, the 9-1-1 brand, to borrow a term from Commissioner Denton's report, tries to give a similar experience across the country.

And often succeeds. You have made progress in this area in key ways:

• The Canadian NG9-1-1 Coalition has been an active and important mechanism.
• Professional associations like NENA and APCO, and meetings like this one, are important opportunities for coordination.
• The province has begun to play a more significant role, for instance in setting up funding programs.
• It is noteworthy that the extension request was filed by a coalition of the Canadian Association of Chiefs of Police, the Canadian Association of Fire Chiefs, and the Paramedic Chiefs of Canada.
• Finally, your work through the Emergency Services Working Group whose chair, Ryan Antsey, you'll hear from next, has been invaluable. Those of you who participate in ESWG, including our own staff, are lending your expertise and ensuring that we proceed forward in a standards-based and coordinated manner.

Where have we been and where we're going

In fact, the ESWG's work has been instrumental to progress in many of the regulatory work streams that go into 9-1-1, including the system's framework and architecture; resilience and outage-handling; and how it leverages different platform types, including clarity of approach for multiline systems in offices and on campuses and, of course, location identification on mobile phones.

In the next few minutes, I will update you on four regulatory work streams, talk about some future challenges, and then leave some time for Q&A.

Framework and architecture

Overall, we have been guided by key framework reviews, particularly since we rolled out the 9-1-1 action plan in 2014, marking its tenth anniversary this past summer:

• In 2017, we put the big pieces into place with Telecom Regulatory Policy 2017-182, titled Modernizing 9-1-1 networks, which set June 30, 2023 as the deadline for decommissioning E9-1-1 in favour of NG9-1-1.
• Then, in 2021, owing to the pandemic, that date became March 4, 2025 through Telecom Decision 2021-199.

Along the way, we issued decisions:

• confirming use of NENA's i3 standard,
• applying 9-1-1 obligations directly to Originating Network Providers that aren't carriers,
• defining and redefining demarcation points and secondary PSAPs as components of the system, to make sure everyone knows where their part of the jigsaw puzzle begins and ends;
• identifying common data formats and common requirements for localized traffic, interconnection at two diverse paths, and the use of hosted solutions and a range of other big-picture, framework or systemic decisions.

Decisions on these framework items and systemic issue will continue to roll out. We have a couple currently before us that relate to pre-production testing rules and environments. Watch for those.

At the same time, these kinds of issues themselves fit into a larger context. Some of our other workstreams that don't bear directly on 9-1-1 will have an impact on you.

Our work providing for competitors to use the fibre networks and radio access networks of larger incumbents, while maintaining incentives for them to invest in high-quality networks, will mean there is a diversity of Originating Network Providers operating in the system that will have to participate in the federated 9-1-1 system.

Likewise, our work to support projects that improve access to mobile and broadband services in rural, remote and Indigenous communities through the industry-funded Broadband Fund is designed to bring to Canadians everywhere in the province, and across the country, access to key services-including devices and networks that have the persistent ability to call 9-1-1.

Resilience and outages

A second workstream under the heading of 9-1-1 regulatory activity has involved ensuring the system's resiliency in the face of both human and natural threats. Back in 2015, we endorsed a consensus report on recommendations to deal with telephone Denial of Service attacks against PSAPs. The following year we imposed on carriers a duty to take reasonable measures relating to the reliability and resiliency of 9-1-1 networks, and to inform PSAPs and what we now call Originating Network Providers about outages.

That work has continued, both at ESWG and directly before the Commission. Together, we adopted cybersecurity best practices for PSAPs, and technical measures relating to compatibility, reliability, resiliency, and security extending into the NG9-1-1 environment. At the same time we recognized situations where initiatives could be deferred, like the STIR/SHAKEN call authentication mechanism that is geared towards the interconnected Internet Protocol environments that the transition to NG9-1-1 will actually see happen-well ahead, by the way, of its implementation in the rest of the voice and telephone-numbered network.

Here, too, this work is at the centre of a set of concentric circles that extend well beyond the 9-1-1 environment. Extreme weather, cyberattacks, and accidents have increased in scale and frequency. But our operating environment has changed, too. Once we relied on a single telephone network. Today we sling multiple devices whose collective reliability depends on the intersection of a diverse set of mobile carriers and fixed Internet providers, each operating relatively autonomously. So the way we mitigate service outages has had to change.

So far, we have required all service providers to report major service outages to us within two hours, and to file a comprehensive report on the nature of the outage within 14 days. Understanding how and why these outages occur is critical to avoiding them in the future, and important to ensuring access to emergency services continues during an outage. We are currently still working on a decision to determine what these outage notifications to relevant authorities and post-outage reporting requirements should be.

But that decision will be just the first stage of how we address network resiliency in broader terms. For instance, telling authorities about outages is one thing. Making the information broadly available is another. Do we need to formalize and coordinate how consumers are told about outages? How would a standard approach to consumer reporting help with 9-1-1 outages? Likewise, what kind of network resiliency principles, public alerting and emergency services, consumer compensation, accessibility, technical measures, and monetary penalties will be required to ensure a comprehensive approach to resilient networks that underpin the devices Canadians use to do everything from request emergency services, to reach out to their friends and loved ones? We will continue to consult the public on these issues in the coming months and years. What you have learned and already know from your ongoing work will be invaluable in helping put in place a trustworthy framework.

Platforms

In terms of platforms, Canadians access 9-1-1 from fixed home phone lines, nomadic Voice-over-IP services, Multi-Line Telephony Systems, mobile phones, and increasingly from other endpoints, ranging from smartwatches to in-car systems.

We have issued decisions creating terms, setting standards, and addressing device-, platform- or endpoint-specific issues on most of these. On multiline systems, as you might find in an office environment or on a corporate campus, ESWG has done excellent work pulling together best practices, which we have endorsed. A decision on direct-dialing for 9-1-1 and for 9-8-8 suicide prevention and crisis support will be forthcoming.

And, of course, mobile devices are a unique endpoint ecosystem that has posed very fundamental questions and created significant opportunities for getting more help faster to Canadians. Here, ESWG's work has been instrumental. The dynamic has been one of interacting back and forth with the ESWG on issues like location accuracy requirements and thresholds and, most recently, on bringing Advanced Mobile Location, or AML, handset-based location tools to the 9-1-1 ecosystem.

AML, through its two flavours for Android and for Apple handsets, will bring significantly improved location accuracy, and with it the ability to get to many people who are in need faster than ever, to the 9-1-1 ecosystem. It could not have been achieved without substantial work put in across the industry, including by telecom carriers vetting and adopting these requirements, implementing these systems across organizations, testing them thoroughly, and putting them into production. This process has been orthogonal to the NG9-1-1 work. But it is a good illustration of just how much is accomplished by you, who work in this area, driven by a mission to serve the public.

Privacy

One of the forward-looking issues engaged by AML, and by location services generally, is privacy. The CRTC has a particular mandate in the area of privacy:

• The recent revisions to the Broadcasting Act that have had us looking at online streaming as part of the broadcasting system, also expressly require us for the first time to "protect the privacy of individuals who are members of the audience for programs broadcast by broadcasting undertakings".
• But the Telecommunications Act has for many years elevated the objective of "contribut[ing] to the privacy of persons" to one of the nine objectives of the Canadian Telecommunications Policy that drives our work.

As NG9-1-1 systems transform emergency communication, and as we move towards more software- and data-driven approaches to federated emergency communications systems more broadly, the stakes involved in contributing to the privacy of persons will only grow.

NG9-1-1 systems collect and store more data than older forms of emergency communications. This data may be shared and accessed across multiple agencies and jurisdictions, raising questions about who has access to the data and how it is used. So data protection, particularly in mixed-traffic and hosted environments, becomes more important as a way to safeguard not only integrity and availability, but also confidentiality: you have already seen end-to-end encryption requirements in some of the standards endorsed by ESWG and that we have adopted. And clear policies about data retention periods and the circumstances under which data can be shared become essential.

To that end, some of you who watch the regulatory process may have noted a Request for Information that related to the privacy and data sovereignty details wrapped up in the deployment of AML, which embeds Apple and Google location awareness into the process in a way that is relatively new to the system. This is an area whose prominence will continue to grow.

Fees

A final regulatory workstream that bears noting today has been around the fees that the telcos participating in the 9-1-1 process charge to the public, and to each other. This relates to the dollars and cents required to cover the costs of taking on different components, some of which are regulated by tariff and some of which are not. But it also relates to issues like the cost of keeping both E9-1-1 and NG9-1-1 running in parallel, to the regulatory classifications and real-world responsibilities assigned to different players in the system, and so on.

These issues aren't always ones that involve PSAPs as directly as some of the other workstreams I've talked about today. But they represent an important regulatory workstream. They also sometimes engage some of the big questions about the different moving parts and conceptual pieces that make up the architecture of the system.

Facing the future together

The transition to NG9-1-1 is overdue and sorely needed. It is not easy. Earlier I compared it to a forklift engine upgrade while you're driving down a very busy highway. At the same time as we watch the growth of NG and NG-enabled PSAPs, the existing system must continue to be fully supported to avoid anyone losing the ability to access 9-1-1 services.

We know the end result will be well worth the effort. The system-wide transition to NG will represent the end of a long process, and the start of something new.

We've been here before. For decades, voice telephone calls were telecom's killer application. But once telephony was encapsulated inside the Internet Protocol, turned into software, and brought into a converged environment where it can interoperate with other software, we got Facetime, and Teams, and Zoom, and sending each other voice memos, and working in email and text and group chat and all of the different and nimble ways in which we communicate today at a distance.

In the same way, the NG9-1-1 environment and its first generation of tools represent a base infrastructure layer for future innovation. Real-time text. Continued roll-out of the ability to transfer calls between cities and provinces, for 9-1-1 callers who have learned something remotely about the health and safety of loved ones in another location, and are in a position to feed that information into a life-saving situation.

How you use NG9-1-1 will transform gradually and under your control. But it will come. From identifying and tagging geographic clusters as they ring through to, down the road, the ability to pro-actively alert devices in a tight geographic cluster, or in-progress visual updates through the closest available consenting devices. Callers, PSAPs, responders, and their respective devices will be able to collaborate more closely and more usefully, with better call routing and situation management, while reducing false alarms or unneeded dispatch, making more efficient use of all resources. Innovations like on-device telehealth or satellite-to-mobile calling also mean new partners and new members of the 9-1-1 ecosystem.

Conclusion

To conclude, let me return to where I began: the strong appreciation we at the CRTC have for all of the hard work you and the members of your teams have put in over the past few years and, really, during the decade that we have been following our action plan. We appreciate and we try to reciprocate your efforts. But we also acknowledge that there is still much hard work ahead, and we're right in the middle of it.

And we know everyone in this room is doing what we can to make this transition a reality. There are many challenges and obstacles we will have to face to get there. But they are challenges well worth overcoming. Because the goals that we share are too important.

The CRTC is only one participant in this ecosystem, alongside other jurisdictional and sectoral authorities. At the same time, we continue to work and to be available to work with all parties on moving things forward. Where you see an opportunity for us to assist in ways that can do so and correspond to our role, our door is open. There is a lot of work before us. Every opportunity to work creatively is one to be seized.

We at the CRTC look forward to getting to our NG9-1-1 future together. I'd be pleased to respond to any questions you may have.

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