Regulator also designates small ILECs as ONPs
By Ahmad Hathout
The CRTC on Friday extended by two years the deadline to decommission the legacy 911 system, after public safety groups said they wouldn’t be able to make the March 4, 2025 deadline to implement the new system.
The regulator said a majority of proceeding intervenors – including the Canadian Association of Chiefs of Police, the Canadian Association of Fire Chiefs, and the Paramedic Chiefs of Canada – said they would not be able to implement the system by this week.
The CRTC has now set March 31, 2027 as the deadline for the full decommissioning of the old system and the full implementation of the new one, which will provide distressed callers the ability to send photos and videos to emergency responders.
“Extending the NG9-1-1 deadline means that Canadians will have to wait longer for the enhancements that NG9-1-1 will bring,” the commission said Friday. “It will also require TSPs to incur additional ongoing expenses to operate existing 9-1-1 and NG9-1-1 networks until the new deadline.
“However, based on the public record of this proceeding, the Commission considers that additional time to complete the transition to NG9-1-1 is necessary and in the public interest,” it added. “In extending the deadline, the Commission is helping to ensure that Canadians do not lose access to 9-1-1 services, while also maintaining incentives for other key 9-1-1 stakeholders to continue their rapid transition efforts, and minimizing financial impact on TSPs.”
The CRTC said because the two networks will continue to exist, it will maintain its dual-rate model, meaning providers using the system – called originating network providers (ONPs) – will have to pay two separate rates to use the ILECs’ two networks. Quebecor challenged this system as unfair.
The regulator said it factored in the fact that the costs on ONPs to use the old system have decreased significantly since 2017, and there is an expectation, at least from Bell, that this cost will continue to decline.
The decision comes after the CRTC’s Emergency Services Working Group (ESWG) filed a status report in late January alerting the commission that the “vast majority of the approximately 242 primary and secondary [public safety answering points, or PSAPs] in Canada will not have completed their transition to NG9-1-1 until the end of 2026.”
The problem lies in the lack of technical expertise and limited vendor availability for testing, “which have created a bottleneck and slowed down the transition to NG9-1-1,” the CRTC said, citing the ESWG report.
Only three PSAPs, according to the report, have launched such services of April 2024.
CRTC categorizes small ILECs as ONPs for NG911
In a simultaneous but separate decision Friday, the CRTC also decided that small ILECs (SILECs) will be categorized as ONPs instead of NG911 network providers, meaning they are not expected to be the ones routing call traffic directly to PSAPs for the purpose of delivering NG911 services.
As ONPs, the SILECs will simply have to – as already required – connect to the large ILECs’ points of interconnection (POIs), which connect to the PSAPs. They then pay the requisite wholesale fee to the large ILECs, which are Bell, Telus, or SaskTel.
“The Commission considers that the technical elements are already in place for SILECs to be reclassified as ONPs, because SILECs are onboarded and interconnected with the NG9-1-1 networks and deliver their retail customers calls to the large ILEC POIs in the same manner as ONPs,” the decision read. “Reclassifying SILECs as ONPs would not affect ONPs’ interconnection with NG9-1-1 networks or Canadians’ access to 9-1-1 services.”
Besides ONPs being most of the way there, the commission ruled this way in part because SILECs have “limited visibility” into which competitors operate in their territory, creating difficulty when it comes to recovering those wholesale costs if they are tasked with directly delivering NG911 service in the area. It also said the reclassification would lower costs for them and their customers because it would strip out all the extra logistical requirements already done for them.
The commission was ruling on an application made by Telus, which encouraged the reclassification, and the responding submission by the Independent Telecommunications Providers Association (ITPA), which said its SILEC members should maintain status as NG911 network providers.
The ITPA said it was concerned that categorizing SILECs as ONPs would create gaps in service where ILECs don’t traditionally operate.
The CRTC took note of that and determined that large ILECs will take the reins to close those gaps in part because those ILECs, like Bell, already have outsourcing agreements to operate in those territories. “This means that Bell Canada is already technically providing NG9-1-1 services in SILEC territory, which include the provision of technical functions, as well as functions related to contracts with SILEC wholesale customers.
“Because SILECs (and other ONPs that serve SILEC territories) are already interconnected with ILEC NG9-1-1 network provider POIs, ILECs are already in a position to assume the responsibility of providing wholesale 9-1-1 access in SILEC territories,” the decision said. “The Commission is therefore of the view that mandating ILECs to provide 9-1-1 wholesale service in SILEC territory would prevent service gaps arising from SILECs being reclassified as ONPs.
“SILECs would still be responsible for providing 9-1-1 access to their own retail customers but would no longer need to provide wholesale 9-1-1 services,” the commission added. “SILECs would retain all other SILEC responsibilities and privileges not associated with those related to being NG9-1-1 network providers.”
As a result, and to ensure no gaps in service, the CRTC has ordered the ILECs to interconnect their NG911 networks to all PSAPs, including those outside of their own territories and inside SILEC territory. This would, in effect, make SILECs non-incumbent just for the purposes of 911 services.
Ontario Commissioner Bram Abramson dissented on the basis that the CRTC has chosen a “path of least resistance” instead of seeking alternatives that would allow dynamic competition to flourish.
“Rather than preserve a notional role for telecommunications companies of varying sizes—some merely represented by others’ delegates—easier to eliminate this complexity,” Abramson writes. “Easier to downgrade SILECs, who have outsourced to the ILECs anyway, to the category of simple originating network providers among many. Easier not to bend over backwards to preserve a seat for SILECs should they wish to insource or, more likely, change outsourcers for, these functions in the future.
“By continuing to outsource to the very ILECs who, wearing a variety of hats, may also be seen to be usurping SILECs’ functions, SILECs are, no doubt, partly authors of their own misfortunes,” Abramson continues. “But their situation is also a precarious one and their choices limited given all of the transitional challenges currently before them. Given our policy obligations, and our broader concern with preserving the competitive process, we should have ensured SILECs could still steward these changes—outsourced or not—rather than replace them altogether.”
Photo via Wikimedia
