UPDATED: Several stakeholders tell CRTC about MLTS systems for 911/988

The CRTC received a raft of responses on its notice of consultation on 911 and 988 calls from multiline telephone systems (MLTS). The systems, found in such institutions as hotels and universities, require the use of a prefix to be dialed before an outside line is established. During 911 emergencies the public service answering point (PSAP) often does not have the precise location or phone number of the person calling. “We share the commission’s goal of ensuring that members of the public can successfully dial 911 to call for help and that PSAPs can quickly and accurately locate the caller,” BCE Inc. wrote in its submission. “We caution, however, against the implementation of obligations that may have an overly simplistic view of what constitutes an MLTS and the technical, commercial and practical challenges associated with implementing such obligations.” “MLTSs are frequently implemented with no involvement from the TSP at all,” Bell states later in the same filing. “In fact, many MLTS owner/operators pursue MLTS solutions specifically so that they can self-manage their own solution for reasons of cost and control while minimizing TSP involvement.” Bell queries whether the commission has the jurisdiction to impose conditions on hotels, businesses and other MLTS users. In the United States, the Federal Communications Commission does have such power. Assuming the regulator does, Bell continues, there should be a transitory period of two years before imposing rules on MLTS users. There should be no indirect regulation on TSPs, the telecom added. If it does not have the power, the CRTC should ask Parliament to grant it such ability. Rogers Communications Inc. maintains the commission does not have such power and that TSPs can only inform their MLTS customers of best practices. The company also pointed out that 911 calls through a MLTS often get routed to an internal number before being sent to an emergency responder. That could lead to privacy concerns when the 988 number is implemented later this year. There should be no on-site notification when 988 is called, the telecom said. Rogers also proposed a two-year implementation regime. Saskatchewan Telecommunications Holding Corp. also worried about the commission’s jurisdiction. TSPs would have no recourse to hold MLTS operators to account if they were not following CRTC mandates, SaskTel argued. Like the other telecoms, the prairie phone company believes standards should only be imposed on MLTS systems going forward, as retrofitting legacy systems would be cumbersome. Telus Corp. asserted that the regulator is well within its rights to rule over MLTS providers. "The commission still retains authority to regulate all telecommunications apparatus, whether exempt or not," the western telecom wrote . But it questioned whether the CRTC needs to. Telus contends 911 problems are far less pronounced than popularly believed. The commission should check to see how many emergency calls are made from wireline and wireless devices before going into regulation, the company said. Cogeco Communications Inc. was similar to Telus in its wariness about overreach by the commission. "Cogeco submits that the hasty adoption of new regulatory obligations on telecommunications service providers is not in the public interest and that, at the very least, a better understanding of the challenges--whether technical, operational or commercial--related to the implementation of any new solution (or solutions) that would address the commission's concerns is warranted prior to taking regulatory action," the firm wrote. Indirect regulation was cited as a concern by the Canadian Telecommunications Association. The trade group recommended the CRTC Interconnection Steering Committee’s (CISC) Emergency Services Working Group (ESWG) look at the implications of next generation 911 (NG911) and 988 services going forward. It also suggested a two-year transition period. Bragg Communications Inc., operator of Eastlink, filed an intervention endorsing the CTA paper. Equipment manufacturers Mitel Networks Corp. and Avaya Holdings Corp. believe the CRTC does not have jurisdiction over MLTS operators and should work to get powers similar to those of the FCC in the United States. The government of New Brunswick asserted that every 911 call should have a dispatchable location and a legitimate call back number associated with it. Many times, when people have misdialed 911 through a MLTS, they hang up immediately. That leads to call centre employees trying to track them down to see if there is a true emergency. The city of Calgary also said that calls should go directly to the PSAP and not an on-site location. It stated that NG911 will permit the inclusion of greater relevant detail, such as floor, room number and seat. It believes obligations should be placed on both the TSPs and the carriers. Legacy systems should have up to five years to retrofit their equipment, the municipality maintained. Several police departments also weighed in on the topic. The Royal Canadian Mounted Police endorsed the commission’s moves. “The RCMP is supportive of efforts by the CRTC which will improve Canadians’ access to 911 services when calling from a multi-line telephone system,” the Mounties wrote. “The removal of barriers to calling 911, in combination with the provision of specific caller location and call back information to PSAPs, will be a significant benefit to public safety and will increase Canadians’ confidence in the 911 system.” The Ontario Provincial Police said a campaign to promote the new system will increase public awareness of the limitations of MLTS. The Police Service of London Ont. asserted that MLTS operators should be responsible for ensuring that calls go through no matter if they are dialled from 911 or 9-911. If buyers of MLTS service do not comply with the new rules, they should be denied service by carriers and resellers, London police opined. “To ensure that providers, carriers and resellers are abiding by the guidelines it might be beneficial to impose fines or the possibility of having their licence suspended or terminated if unwilling to comply,” the force said. The Canadian Next Generation 911 Coalition suggested that institutions employing MLTS should have an employee meet first responders at a designated site, to direct them to the emergency. Esri Canada proposed that providers of nomadic VoIP service should be required to provide direct access to 911. Updated to add Telus and Cogeco interventions. –Reporting by Paul Park at ppark@thewirerreport.ca and editing by Jenna Cocullo at jcocullo@thewirereport.ca.

UPDATED: Several stakeholders tell CRTC about MLTS systems for 911/988

News | June 23, 2023

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UPDATED: Several stakeholders tell CRTC about MLTS systems for 911/988

News | June 23, 2023

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