On October 17, 2022, the Commission released Telecom Decision CRTC 2022-284 | CRTC which sets out a number of determinations related to the permissibility of hosted call handling solutions (CHS) for public safety answering points (PSAPs) in the context of next-generation 9-1-1 (NG9-1-1).
In Canada, the Commission determined that incumbent local exchange carriers (ILECs) would be responsible for building, operating, and maintaining the NG9-1-1 networks, the costs of which would form the basis of the NG9-1-1 tariffs. Previously, the Commission had expressed the view that (i) the NG9-1-1 networks connect to a demarcation point at a site other than a PSAP was inconsistent with the NG9-1-1 framework as outlined in Telecom Regulatory Policy 2017-182, Telecom Decision 2018-188 and Telecom Decision 2019-353, and was therefore not permissible; and (ii) the NG9-1-1 framework did not contemplate hosted CHS and therefore does not currently support it.
However, in this decision, which was brought about because of an application by the New Brunswick 9-1-1 Bureau, the Commission determined that:
9-1-1 governing authorities can designate demarcation points at hosted CHS sites in the NG9-1-1 networks; such designations would be subject to certain conditions; and
demarcation points, regardless of whether they are located at a PSAP or a hosted CHS site, must be clearly designated within the NG9-1-1 service agreement between the 9-1-1 governing authorities and the NG9-1-1 network providers.
Who pays for the interconnection transport
Normally a PSAP is not required to cover the costs of interconnection facilities from the NG9-1-1 networks to the PSAP facility. With respect to new demarcation points to a data centre for a hosted call handling solution, the Commission determined that:
if NG9-1-1 network providers have established NG9-1-1 connections at demarcation points designated by 9-1-1 governing authorities per the direction contained in the original NG9-1-1 framework, any costs associated with relocating these connections for the purpose of accessing hosted CHS by PSAPs shall not be recoverable via NG9-1-1 tariffs and instead shall be borne by the 9-1-1 governing authority requesting the relocation;
if 9-1-1 governing authorities designate demarcation points solely at hosted CHS sites, only the costs associated with connections between the NG9-1-1 network and the hosted CHS sites shall be recoverable via the NG9-1-1 tariffs, with the costs associated with connections between the hosted CHS site and the PSAPs being borne by the 9-1-1 governing authorities; and
if 9-1-1 governing authorities designate demarcation points at both hosted CHS sites and PSAPs, the 9-1-1 governing authorities shall bear the cost of establishing the new connection between the demarcation point at the hosted CHS and the demarcation point at the PSAP. It is understood, however, that this new connection shall be part of the NG9-1-1 network and moving forward, costs associated with traffic transiting over this new connection are eligible to be recovered via the NG9-1-1 tariff.
Conditions applicable to a hosted CHS
9-1-1 governing authorities, as a condition of interconnecting with the NG9-1-1 network, shall ensure that all demarcation points and networks within the PSAP domain (including those of hosted CHS sites). These are generally not new conditions, simply restatements of existing conditions of interconnect as set out in the UNI and are subject to further review and recommendations from the Emergency Services Working Group (ESWG).
deploy Dual Stack as the preferred method for simultaneous use of IP version 4 and IP version 6 address space or to individually perform Network Address Translation – Protocol Translation (NAT-PT) for their network domain, as defined in the NG9-1-1 network provider’s UNI interconnection specifications;
support a set maximum transmission unit (MTU) value of 1,500 bytes for their network domain;
use the Border Gateway Protocol (BGP) for dynamic routing between peering networks, using registered autonomous system (AS) numbers when available;
use an i3-standard-compliant Border Control Function (BCF), as defined in the NG9-1-1 network provider’s UNI interconnection specifications, and deploy BCFs in a manner that prevents single points of failure;
use the quality of service (QoS) strategy defined in the NG9-1-1 network provider’s UNI interconnection specifications;
implement the mandatory list of audio CODECs (coder-decoders), which is (i) provided by the NG9-1-1 network providers as part of the production onboarding process, and (ii) updated through the proposed change management process managed by CISC;
use the top-level PSAP Credentialing Agency (PCA) service provided by the NG9-1-1 network provider, as defined in the UNI interconnection specifications; and
abide by any additional conditions that may, in the future, be adopted by the Commission.
Additionally, the demarcation points for hosted CHS must be located within the combined territory of the small ILECs and the adjacent large ILEC, and the relevant PSAPs are supported by a minimum of two geo-redundant hosted CHS sites.
The Commission also placed several limits on the types of CHS configurations permitted. First there is a prohibition on administrative or non-emergency traffic transiting over the NG9-1-1 networks. This likely includes a prohibition on CHS solutions embedded within the 9-1-1 Network with 9-1-1 Network connections to the PSAPS, as this would require transiting of traffic from the CHS to the PSAP via the 9-1-1 Network. Such traffic likely consists of proprietary messaging and is not considered normal NG9-1-1 traffic appropriate for transit of the ESInet. This prohibition will also require partition of administrative lines that seek to use the same IPBX forming part of the hosted CHS such that non-emergency related calls from the PSAP are not directed to the ESInet for termination to the PSTN.
Additionally, some hosted CHS options will see NG9-1-1 traffic transiting over commercial lines from the CHS data centre to PSAPs and that there are inherent reliability and resiliency concerns with such configurations (as they are not provided pursuant to the 9-1-1 network provider tariffs). The Commission is of the view that 9-1-1 governing authorities who opt for this option should thoroughly evaluate their options, as they will be responsible for the connections and any related outages.
Lastly, in addition the above noted restrictions on hosted CHS, the Commission directed NG9-1-1 network providers to:
incorporate into their NG9-1-1 outage reports all 9-1-1 service outages that are attributable to hosted CHS providers or the connections between the hosted CHS providers and the relevant PSAP(s); and
provide, for each of these service outages, the date, duration, and cause of the outage; the affected area(s); the remedial action(s) taken to address the outage; and the number of affected calls, if this information is available.
The Commission also adjusted the definitions of primary and secondary PSAPs as follows:
A primary PSAP is a PSAP to which 9-1-1 emergency requests and associated data are routed as the first point of contact with a 9-1-1 telecommunicator. In most cases, the primary PSAP then contacts the appropriate agency to dispatch emergency responders. However, in cases where local authorities determine that specialized expertise is required to handle the 9-1-1 call, such as emergency medical services, 9-1-1 calls are then transferred to a secondary PSAP; and
A secondary PSAP is a PSAP to which 9-1-1 emergency requests and associated data are transferred from a primary PSAP.