Speech by Timothy Denton, National Commissioner, Canadian Radio-television and Telecommunications Commission
To the Interoperability Technology Interest Group (CITIG), NG9-1-1 National Governance and Coordination Workshop
June 10, 2013
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Thank you very much. It's a pleasure for me to speak to an audience that combines professional expertise with a deep commitment to the safety, security and well-being of all Canadians. I can't think of any work in this country that is more important than yours.
Role of the CRTC
The provision of 911 services is a collaborative effort between the CRTC, provincial and municipal governments, telecommunications companies, first responders and public safety answering points (PSAPs). For the system to function, each one of us has a part to play.
The CRTC supports your work by ensuring that Canadians have access to reliable communications services during emergency situations. This is achieved through the regulation of the telecommunications companies that operate the wireline and wireless networks Canadians use to connect to 911 call centres. Service providers must provide access to 911 services wherever a public PSAP has been established.
As a result, 98% of Canadian telephone subscribers have access to basic 911 services and 95% are served by enhanced 911 services.
In the last few years, the CRTC has been working in a collaborative fashion with stakeholders through the Emergency Services Working Group to make significant improvements to the 911 system. This resulted in wireless service providers upgrading their networks to enable 911 operators to locate callers using a cellphone with a higher degree of accuracy.
Earlier this year, following a successful trial, we announced that telecommunications companies’ networks would have to support new features making it possible for Canadians with hearing or speech impairments to communicate with 911 call centres via text messaging. In addition, 911 operators can now request location updates for people calling 911 from a cellphone.
In 2014-2015, the CRTC will be reviewing the regulatory framework governing next-generation 911 services (NG911). To prepare for that formal review, the Commission invited experts, stakeholders and all Canadians to make their views known in three broad areas:
- How well is the current 911 technology performing? For example, how good is it in locating a caller who's using a cellphone?
- What are the issues involved in moving to NG911, including institutional arrangements and the design of systems?
- And what are the policy considerations on 911 matters?
I was appointed Inquiry Officer, and I asked for public comments on a number of more specific questions.
I held one-on-one and small-group meetings with over 125 stakeholders in Canada and with regulatory and industry experts in the United States and Europe.
I then reviewed the comments we received from individuals, groups, telecom service providers and government organizations. Of course, those replies included a very well-informed and useful brief from CITIG.
The general view is that while the system is adequate for the telephone era, technological change in the devices used by Canadians signals a massive change throughout the system – and there is no coherent approach to consider how the transition will be managed or who will pay for it. It is axiomatic that the 911 system has to keep up with the devices in people’s hands. The message I heard during my inquiry is that we must ensure the 911 system continues to evolve to meet the needs of Canadians.
I would like to highlight some of the challenges that will require innovative solutions in the coming years.
Expectations of Canadians
First of all, Canadians expectations regarding 911 services are changing, and this is resulting in certain misconceptions.
A survey in 2010 found that 76% of the respondents believed that the PSAP would know where they are calling from, and 73% believed that the technology could find them even if they couldn't speak.
In a 2012 survey, 64% said that emergency responders should be prepared to answer calls for help posted on social media. And 55% thought that emergency responders are currently monitoring social media sites.
Thirty-five percent thought that a call for help on social media would result in assistance from emergency services; 74% of those believed that help would arrive within an hour.
Many Canadians told me they had doubts about the adequacy of 911 services for people with disabilities. The system does not always accommodate the modes of communication which the person may have at their disposal. There may also be problems about the maintenance of up-to-date information about the user.
There are also people with inadequate access to 911 services because of where they live. Access is not yet universal across Canada. While 98% of Canadian telephone subscribers have access to some form of 911, 2% do not benefit from this access. This is not always a technological problem. Sometimes it is due to organizational or political factors.
Issues for PSAPs
PSAPs and first responders gave me great insight into the challenges that they face every day. More and more people are giving up their landlines for wireless or VoIP (Voice over Internet Protocol). This increases the difficulty of automatically locating a 911 caller when full information is not available by voice. Location of a wireless handset can be determined by triangulation with cellular base stations, or by GPS. But triangulation may offer only limited accuracy, and GPS may not be available.
Even when longitude and latitude may be determined, there is no automatic technique to find the altitude coordinate which will pinpoint which floor in a building is the source of the call. The problems are even greater with VoIP, because IP addresses are independent of geographic location. Many see location-finding techniques in an increasingly IP-oriented environment as a matter of urgent concern. They also report that unintentional calls to 911 through pocket dials and misdials waste time and delay response to genuine emergencies. Test calls from wireless devices can have the same effect.
All these factors place greater demands on the PSAPs. They are concerned that their funding based on provincial levies applied to wireless customers is inadequate to support their workload.
They also point out that the lack of a common funding model across provinces and regions has led to regional differences in the level of 911 service provided. Should there be accountability for the efficiency with which the public’s money reaches PSAPs? Should there be a system in place to measure to what extent service levels for PSAPs are attained? Should there be a place where service level agreements are established?
There are also limited capabilities for data collection, making it more difficult to assess 911 services. Most PSAPs gather data and prepare reports based on their own information and that provided by the phone companies. But this misses out on details like the type of incident, the type of device, location information and the proportion of false calls.
How many 911 calls are made in Canada each year? No one seems to know since the data collected by different PSAPs is not collated to give us a picture of the calls that come in across the country.
It is obvious that 911 has a measurement problem in Canada. Money is going into the system, in significant quantities. Should there be a coherent view of, or reporting on, how it is being spent, by whom and with what results?
And that is strictly on the basis of the system’s immediate metrics. No measurements, no measurers, no accountability. If we get this problem sorted, and I think it will not be long before that happens, there is another problem: Not gathering data from PSAPs in common formats that allow for national aggregations and comparisons is a tremendous lost opportunity.
The question of data is of huge importance for public policy. Imagine a map of the country showing incidents by type, time of day, or any other criterion. How much would it be worth to assemble nation-wide data gathering by collating all 911 data in a comprehensive system, at appropriate levels of aggregation for the various levels of government? 911 is a rich field for what is now being called “Big Data.” Unfortunately, for want of common data formats, and for want of someone tasked with measurements, a rich source of social information goes to waste.
Issues for incumbent telephone companies
The submissions we received from the incumbent phone companies maintained that the current system provides robust and secure access to 911 features and systems for both PSAPs and interconnecting carriers.
The incumbents reported a high level of accuracy for location information provided with wireless 911 calls—an assertion that varies considerably from what PSAPs and other participants in the system have observed. For example, during our visit at a Toronto PSAP, a cellphone call placed to 911 from inside the building was consistently thought to be coming from the same address across a canyon 800 metres away.
Incumbents also noted that the format and accuracy levels were at least equal to, and in most cases superior to the currently mandated standards. Yet in Canada, there exists no standard of accuracy measured in metres of radius. Does the problem of location accuracy need remedial attention?
They did raise their concerns over the challenges presented by calls received via VoIP. If fully communicative voice contact is not obtained, locating the caller requires third-party involvement, which is time-consuming and depends on stored information on the last known address. That information may or may not have been updated by the customer. The system may also be vulnerable to spoofing and the malevolent practice of swatting.
The incumbents also noted that there are parts of the country where no 911 service of any kind is provided, and local numbers must be called to get help in emergencies.
Outlook for NG911
Most people acknowledge that NG911 will help solve many of these problems. It’s true that IP technologies will offer new capabilities to 911 systems, such as instant messaging, social media, images and video. It will offer new efficiencies with the potential for savings.
However, PSAP people have told me that they are concerned the expectations of Canadians will increase faster than the system's ability to meet them. CITIG noted that the new developments mean higher costs initially, including investment in equipment, procedures and training. For PSAP dispatchers and the provinces that pay for PSAPs, the speed and magnitude of change looks like a gigantic unfunded liability.
And so far there is no high-level forum to discuss the problems and consider what policies should be implemented.
There is a lot of support in Canada for the i3 standards and architecture roadmap developed by NENA (National Emergency Number Association). However, this is substantially U.S.-oriented. Some members of our industry prefer a simplified NG911 solution specifically tailored to Canadian needs. Others warn against isolating our system, which could increase costs and limit equipment choice.
Questions about NG911
The participants in the inquiry raised a number of questions with me about the transition to NG911. Here are just a few of them:
- Can enhancements be introduced incrementally without reducing the current quality of service?
- Are open industry standards required?
- Do providers of NG911 services require increased liability protection?
- How can the public's expectations be managed?
- Given increased data flow under the new systems, there will be more data collected and shared. What about privacy protections? How are PSAP operators to deal with the flood of information to be sorted, collected, acted upon and stored as evidence?
- Should there be a national multi-stakeholder coordinating or consultative body for 911 policy development?
There are many questions, and not all can be answered within the jurisdiction of the CRTC. But all stakeholders will have to work together to meet the new challenges in doing the best we can for the Canadian public that relies on the 911 system for help in all sorts of emergency situations.
I look forward to continuing this important discussion with you during this conference.
Thank you very much.
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