By Ahmad Hathout
The large telecommunications companies are urging the CRTC to turn away applications asking it to require a pre-production test environment for next generation 911 calls, saying it is unnecessary and too costly.
Some public safety answering points (PSAPs) and the government of British Columbia filed separate Part 1 applications with the regulator asking for it to mandate the ability of these emergency entities to hook up to a pre-production test environment for NG911 so that real 911 calls are not at risk when testing software updates and new features. The NG911 networks are expected to carry multimedia, such as images and video, to emergency responders.
But the legacy telecoms said in submissions last month that they don’t think such a test bed is necessary and, if such an environment is required by the commission, it could present a costly addition that could delay the decommissioning of the legacy 911 network – slated by March 2025.
For N911 service provider Bell, which has a test lab to test software and new features, there is no test environment that can completely replicate the production environment, and requiring one would be “extremely costly and resource intensive for all stakeholders.”
PSAPs can interconnect with the lab at their own expense, but doing so would “not only defeat the purpose of this lab, but also be of little benefit as they could only test features which are not yet deemed ready for PSAPs by NG9-1-1 Providers or vendors,” Bell said.
“Once a software load is ready, the best means of testing it with a PSAP is over the live network towards the PSAPs own testing environment or through a test call,” Bell said, adding it is entirely possible for PSAPs to conduct test calls, texts, videos without putting the public at risk.
The other major NG911 service provider Telus said in its submission that its current lab is not designed to be able to accommodate the testing the PSAPs are asking for.
But according to Telus, it isn’t needed because the providers follow the highest industry standards and already do thorough testing between themselves and the call handling solution vendors.
Telus further argues that the United States Federal Communications Commission does not require such a pre-production testing environment, an argument echoed by Rogers.
Beside arguing that pre-production testing environments in the U.S. are offered on a commercial basis only, Rogers adds that not all PSAPs will benefit from pre-production environments and that NG911 rates are already too high.
As such, while Rogers said it isn’t against the provision of such a test bed, this should be an optional service offered by NG911 service providers on a commercial basis to stakeholders – and, like Telus, the cost should not be found in the existing 911 tariffs.
Similarly, Quebecor argues that the requested testing environment is unnecessary because the NG911 providers already have integration activities and well-established protocols to ensure network compatibility.
The telecom says such an additional test bed will only add redundancy and prolong the retirement of the current 911 services.
“Pre-production testing risks increasing the already extremely high NG911 implementation costs, which will have the consequence of increasing the 911 fees of telecommunications service providers,” Quebecor said.
If required, Quebecor added that such associated costs should be placed on the applicants and should not find their way to 911 rates charged by the network providers or to current 911 network components.
