Telecoms companies debating immediate vs. phased-in deployment of crisis line

Canada’s telecom companies are debating before the CRTC whether it is best to deploy a national mental health and suicide prevention crisis hotline simultaneously throughout the country -- once a required transition to national 10-digit dialling in all areas is achieved -- or if it should be done in a phased-in approach. The latter would leave certain areas with seven-digit local dialling waiting for the service but can speed up deployment to other Canadians. In June, the CRTC opened consultations on the establishment of a national three-digit number for mental health crisis and suicide prevention services to quicken access to support. It gave a Sept. 1 deadline for interventions and an Oct. 1 deadline for replies -- the latter of which was published Tuesday. Many of the questions asked by the CRTC were non-contentious in the telecom companies' answers. However, BCE Inc. and Rogers Communications Inc. differed in their views on the deployment timelines. Bell said 988 should be implemented everywhere in Canada at the same time -- as did TekSavvy Solutions Inc. and Bragg Communications Inc.‘s Eastlink in the September interventions -- arguing it would avoid confusion for individuals trying to access the service from an unserved numbering plan area (NPA), it would allow for a well-coordinated national education campaign, and that it is consistent with the deployment strategy of the Federal Communications Commission in the United States. Bell recommended first implementing 10-digit dialing in the remaining four NPAs as a result. “This migration requires customers in those NPAs to adjust their own equipment, such as private branch exchange (PBX) systems, as well as become accustomed to the new dialing requirements. While this process typically happens in relation to the introduction of a new NPA and takes a substantial amount of time to complete, we believe that this can be streamlined in this instance,” Bell wrote in its reply. Bell said it believes the company can make the transition within nine months from the date the commission issues its determination on the matter and went on to state that it has already undergone preliminary work to facilitate the switch. Rogers, on the other hand, recommended a two-phased approach -- as did Telus Corp. in its original intervention -- with 988 being deployed within six months of the CRTC’s decision, arguing it was important to roll out the service to at least some Canadians as soon as possible. “The introduction of 988 can therefore begin in most of Canada, while 10-digit calling is rolled out in the rest of the country. There are no reasons to wait for all NPAs in Canada to have 10-digit dialing and then to deploy 988 simultaneously across the country, as some parties suggested,” it wrote in its reply. Rogers recommended that for Phase 2 of its proposed approach, telecommunications service providers (TSPs) should be provided with an additional six months to implement 988 within the four NPAs after the conversion to 10-digit dialling is completed. “During the transition period, residents in these four area codes will still have access to a stop-gap measure, namely the existing in-service toll-free crisis line (#1-833-456-4566) and its associated wireless SMS short code, #45645. Those in need will continue to have access to current levels of service while the necessary engineering takes place,” it wrote in its reply. The majority of telecommunications respondents in the interventions agreed with the CRTC’s preliminary view that 1-8XX translation should be the routing method used for a three-digit code. “This method would be the simplest and least cumbersome to TSPs as it would not require customized network or system modifications,” Bell wrote in its reply. However, in its September intervention, Regroupement des centres de prévention du suicide du Québec (RCPSQ) said it preferred to have three-digit calls routed directly to various suicide prevention or crisis counselling centres. “We understand that RCPSQ prefers this model as they want to preserve the network structure of call centres already in place in Quebec and believe that this method would ensure call centres that officially represent 1-866-APPELLE are not advantaged over call centres that are not part of this network structure,” Bell argued in its reply. It added that 1-8XX toll-free systems can route calls to different call centres or terminating numbers, allowing the crisis centres to work together “to ensure that services are always available and would enable routing rules to be centrally modified when new centres join the network, or when availabilities change.” Telus and the other incumbents agreed that TSPs should incur the costs associated with the move to 10-digit dialing and the associated network modifications to support a three-digit code. However, in its reply, Telus noted that costs and timeline estimates varied between the parties depending on the changes required in each provider’s network and resources. “The TSPs based their respective estimates on a number of assumptions about the service and the features and functionalities that would be required. These assumptions were necessary because there is insufficient information on the record of this proceeding about the business requirements for the three-digit code to provide responses that are more accurate. A review of the interventions has done little to clarify the business requirements,” it wrote to the CRTC in its reply. It recommended that the commission ask current providers of similar mental health crisis services for more information to establish exactly what features and functionality are required. “Once there is more clarity on the service requirements, the commission should then ask Telus and the other TSPs to provide further submissions so that they can update their positions and estimates for prospective costs, as well as positions on cost recovery.” Telus said The majority of the telecommunications companies agreed that the commission should refrain from directing that the three-digit code utilize 911/NG911 networks for call routing. In its reply, Rogers stated that the 911 networks are not designed to support long duration calls like 988 and that public-safety answering point (PSAP) operators would require extensive training to answer the calls. “Further, some interveners indicated that automatic dispatchable location determination is not needed for most 988 calls and, if it were implemented, it would violate privacy and confidentiality rights. This would simply discourage those in need from using the services,” Rogers wrote in its reply. The Canadian Association of the Deaf (CAD-ASC) reiterated its points to the CRTC, in its reply, that telecommunication companies and PSAPs must provide the Deaf, Deaf Blind, and Hard of Hearing (DDBHH) accessible services with voice relay services (VRS), IP Relay, and Real Time Text (RTT). “Regardless of the methodology determined to offer the 9-8-8 service, accessibility should be included from the start and members of the DDBHH should participate in the testing before launch,” it wrote to the CRTC. CAD-ASC took issue with Rogers’ original intervention in which the company suggested that “a sign language user would initiate a regular video relay session and would then ask the operator to contact 9-8-8.” CAD-ASC argued in its reply that a sign language user struggling with mental health issues will have difficulty taking action that way during a time of crisis. CAD-ASC also noted that Telus’ suggestions that DDBHH community can text the 988 number raised concern as “members who struggle with mental health concerns have also suffered language deprivation, causing a weaker literacy in English/French. Due to this, SRV Canada VRS as the way of communication is highly required to ensure all involved parties understand each other clearly.” CAD-ASC said that to translate 988 calls to a toll-free number would be the most effective solution as a toll-free number can be compatible with SRV Canada VRS, the organization responsible for implementing Canada's video relay service. “With respect of VRS calls, the advantage of using a 1-8XX toll-free routing model is there is no need to change the existing processes which are well understood by VRS users. As stated in our intervention, a VRS user makes a call by placing the number in the Canada VRS app. The call is then routed first to a VRS interpreter and then the system creates a three-way call (video between the user and the interpreter, audio between the interpreter and the called party). If 988 calls are routed to a single toll-free number, this system can work for VRS users,” Bell wrote in its reply. With respect to texting, Rogers told the CRTC in its reply that SMS is the most suitable protocol because of its universal use and is not handset or operating system dependent. “Neither RTT nor are suitable to support the provision of 988 due to unknown operational realities or handset limitations,” it said. -- Reporting by Jenna Cocullo at jcocullo@thewirereport.ca and editing by Michael Lee-Murphy at mleemurphy@thewirereport.ca.

Telecoms companies debating immediate vs. phased-in deployment of crisis line

News | October 5, 2021

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