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Telecom - Commission Letter addressed to the Distribution list

Ottawa, 7 February 2022

Our reference: 1011-NOC2021-0191

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Distribution list

RE: Introduction of a three-digit abbreviated dialing code for mental health crisis and suicide prevention services, Telecom Notice of Consultation CRTC 2021-191 – Request for information

With the issuance of Telecom Notice of Consultation CRTC 2021-191, Footnote1 the Commission initiated a proceeding to establish the need for the implementation of a national three-digit code for mental health crisis and suicide prevention services (three-digit code), to identify the existing barriers to the establishment of such a code and, if necessary, to determine how these barriers can be overcome.

For the purposes of developing the record of this proceeding, the parties identified in the distribution list are to file responses to the questions set out in the attachment by 7 March 2022. Parties may file comments on the information provided in response to these questions by 17 March 2022. These submissions must be received, not merely sent, by the above dates.

As set out in section 39 of the Telecommunications Act and in Broadcasting and Telecom Information Bulletin CRTC 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, persons may designate certain information as confidential. A person designating information as confidential must provide a detailed explanation on why the designated information is confidential and why its disclosure would not be in the public interest, including why the specific direct harm that would be likely to result from the disclosure would outweigh the public interest in disclosure. Furthermore, a person designating information as confidential must either file an abridged version of the document omitting only the information designated as confidential or provide reasons why an abridged version cannot be filed.

Yours sincerely,

Original signed by

Lisanne Legros
Director
Telecommunications Networks Policy

c. c.:    Matthew Tosaj, CRTC, 819-878-6887, matthew.tosaj@crtc.gc.ca
Sylvie Labbé, CRTC, 819-953-4945, sylvie.labbe@crtc.gc.ca

Attach. (1)

Distribution List

Bell Canada et al., Footnote2 bell.regulatory@bell.ca
Association canadienne des télécommunications sans fil (ACTS), communications@cwta.ca, ugrant@cwta.ca;
Service de prévention du suicide du Canada (SPSC), jenny.hardy@camh.ca;
Administrateur canadien du SRV, ExecDirector@cav-acs.ca;
Distributel Communications Limited (Distributel), regulatory@distributel.ca, christopher.hickey@distributel.ca;
Bragg Communications Inc. (Eastlink), regulatory.matters@corp.eastlink.ca;
Iristel Inc. (Iristel), regulatory@iristel.com;
Québecor Media Inc. (Vidéotron), regaffairs@quebecor.com;
Regroupement des centres de prévention du suicide du Québec (RCPSQ), info@rcpsq.org;
Rogers Communications Canada Inc. (Rogers), regulatory@rci.rogers.com;
Saskatchewan Telecommunications (SaskTel), document.control@sasktel.com;
Tbaytel, laura.foulds@tbaytel.com;
TekSavvy Solutions Inc. (TekSavvy), regulatory@teksavvy.ca;
TELUS Communications Inc. (TELUS), regulatory.affairs@telus.com.

Requests for information

Questions for Bell Canada et al., the CWTA, Distributel, Eastlink, Iristel, Quebecor, Rogers, SaskTel, TekSavvy, and TELUS

  1. On 16 July 2020, the Federal Communications Commission (FCC) required United States telecommunications carriers and voice over Internet Protocol providers to make necessary modifications to implement a three-digit code (i.e. 9-8-8) for a national mental health crisis and suicide prevention hotline by 16 July 2022. On 19 November 2021, the FCC also required covered text providers Footnote3 to implement text-to-9-8-8 by the same date.
    • In light of the fact that Canadians, particularly those residing near the United States border, may be made aware of the implementation of such a code in the United States by 16 July 2022, what measures could be taken in Canada by telecommunications service providers to attenuate the risk that Canadians calling or texting 9-8-8 from that date will not be able to reach the help they need? Also elaborate on your view on the appropriateness of implementing such measures, including the advantages and challenges associated with their implementation.
  2. In paragraph 28 of its intervention, Bell Canada et al. indicated that transition from seven- to ten-digit local dialing is typically done as part of an NPA Relief Project, which follows the Canadian NPA Relief Planning Guideline. It however submitted that, as the move to ten-digit local dialing will not involve the introduction of a new NPA, the timelines associated with certain activities in the Guideline could likely be eliminated (i.e. steps 1 to 16), and that an abbreviated timeline could be achieved if the industry runs a clear and concise customer awareness campaign in parallel with transitioning to ten-digit local dialing.
    1. Provide your views on what activities would be required for the transition to ten-digit local dialing, including associated timelines.
    2. Provide your views on the appropriateness of conducting an abbreviated customer awareness campaign for the transition to ten-digit local dialing to implement a three-digit code for mental health crisis and suicide prevention services. Also provide your views on the timing of that campaign, as well as on the content and associated timelines for the campaign, including customer notification and network announcements.
  3. Explain whether it would be possible to prevent mobile wireless calls and/or texts to the Canadian three-digit code from being inappropriately routed to the United States (or vice-versa). Also provide your views on whether it would be appropriate to implement measures to reroute calls to the tree-digit code to the appropriate mental health crisis and suicide prevention service, and if so, what these measures could be.
  4. The RCPSQ indicated that the province of Quebec has 31 suicide prevention centres located in 13 different regions. It submitted that it would favour a scenario where calls to the three-digit code in Quebec would be routed directly to the province’s suicide prevention centres, as not all of the centres are agents of 1-866-APPELLE, the provincial toll-free suicide prevention hotline.
    • Explain the advantages and challenges in applying this routing scenario in the province of Quebec, including the anticipated impacts on the timelines and costs associated with the implementation of the three-digit code.
  5. Would routing calls to the three-digit code using 1-8XX translation allow calls to be routed based on the caller’s general location for the purpose of routing the call to the nearest available mental health crisis and suicide prevention service? If so, comment on any potential challenges, and whether the caller’s exact location could be kept confidential.

Question for Bell Canada et al., Eastlink, Iristel, Québécor, Rogers, SaskTel, Tbaytel, and TELUS

  1. The CWTA, supported by several parties in this proceeding, proposed that texting to the three-digit code should be deployed using a Common Short Code (CSC).
    • Should a new CSC be deployed for the three-digit code, comment on the feasibility of using such a code, and on whether this service should be provided at no charge for the end-user.

Question for Tbaytel

  1. In paragraph 11 of its intervention, Tbaytel submitted that ten-digit local dialing in all areas should be mandated no earlier than 18 months from the date of the decision in this proceeding, and that it would be appropriate to provide no less than an additional six months to deploy the three-digit code after ten-digit local dialing is implemented in all remaining areas.
    • Other telecommunications service providers provided shorter timelines for transitioning to ten-digit local dialing and deploying the three-digit code. For instance:
      • Bell Canada et al. submitted that it could transition its networks to ten-digit local dialing within nine months of a Commission determination, and that the subsequent reprogramming of the switches to support the three-digit code could be done simultaneously; Footnote4
      • Rogers submitted that seven-digit local dialing numbering plan areas (NPAs)  that are not undergoing NPA relief activities should transition to ten-digit local dialing within six months after the Commission’s decision and then have another six months to actually implement the three-digit code; Footnote5
      • TELUS submitted that transitioning to ten-digit local dialing in its exchanges where seven-digit local dialing is still the norm could be completed within 4-6 weeks, and that the three-digit code could be implemented within 26 weeks. Footnote6
      1. Provide a list of the activities (e.g. equipment changes, switch replacements, reprogramming of switches) Tbaytel would need to undertake to (i) transition its network to ten-digit local dialing, and (ii) implement the three-digit code. Assume that the three-digit code would be routed to a single 1-8XX number using conventional call routing protocols.
      2. Taking into account the activities listed in response to question a) above, indicate, with supporting rationale, whether Tbaytel anticipates that it would need 18 months to transition its network to ten-digit local dialing and/or an additional six months to deploy the three-digit code. If not, indicate, with supporting rationale, how long the company anticipates it would take to transition its network to ten-digit local dialing and to implement the three-digit code.

Question for CSPS partners Footnote7 RCPSQ and the RCPSQ

  1. Explain whether it would be appropriate to implement measures to transfer mobile wireless calls and/or texts to the Canadian three-digit code inappropriately routed in the United States (or vice-versa), and if so, explain whether your organization could implement such measures.

Question for CSPS partners

  1. The CWTA, supported by several parties in this proceeding, proposed that texting to the three-digit code should be deployed using a Common Short Code (CSC), which is similar to the approach currently used by the CSPS to receive text communications (i.e. through CSC #45645).
    1. Provide your views on the solution proposed by the CWTA to implement texting capabilities for the three-digit code. Explain what would be the advantages and challenges associated with this solution, including the impact that such an approach would have on the CSPS and its partners (e.g. modifications or upgrade to their messaging platforms).
    2. Provide your views on the feasibility of transferring texts received through the three-digit CSC to organizations outside of the CSPS network, such as the RCPSQ.
    3. Should the CSPS consider the solution proposed by the CWTA is not appropriate, provide your views on other options that could be used to deploy texting capabilities, including on the advantages and challenges associated with these options.

Question for the RCPSQ

  1. The RCPSQ indicated that the province of Quebec has 31 suicide prevention centres located in 13 different regions, some of which being agents of 1-866-APPELLE, the provincial toll-free suicide prevention hotline.
    1. Explain how the services offered by the suicide prevention centres in Quebec are managed and coordinated between them, including how the 1-866-APPELLE hotline is managed (also indicate which entity is ultimately managing 1-866-APPELLE).
    2. Explain how calls to the CSPS from callers with Quebec area codes, which are then routed to 1-866-APPELLE, are managed by 1-866-APPELLE.
    3. Explain whether it would be possible for the entity managing 1-866-APPELLE to internally route the calls received from the three-digit code to the different suicide prevention centres in the province of Quebec.

Questions for the Canadian Administrator of VRS

  1. Explain how your organization currently handles VRS calls made to three digit codes other than 9-1-1. What limitations, if any, do you currently have with respect to VRS calls made to three digit codes or X-1-1 numbers?
  2. Assuming that calls to the three-digit code would be routed to a single 1-8XX number using conventional call routing protocols without a requirement to provide location information, explain what impact the introduction of the three-digit code would have on your organization, including on your serving and operational arrangements. Also explain whether these calls should be prioritized over other non-9-1-1 calls made to VRS.
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