Public Safety Telecommunications in Canada: Regulatory

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Canadian Journal of Communication, Vol 30 (2004) 65-88©2004 Canadian Journal of Communication Corporation

Public Safety Telecommunications in Canada: Regulatory Intervention in the Development of

Wireless E9-1-1

Gordon A. GowLondon School of Economics and Political Science

Abstract: Wireless E9-1-1 is an interesting case in the capacity of industry volun-tary efforts to meet public interest obligations, in part because the CRTC haslargely forborne from regulating the wireless sector under current competitionpolicy. Results to date are mixed: despite successful technical trials in the earlystages, deployment of the service was slow and uneven, and proceedings came tobe plagued by uncertainty and fractious debate between stakeholder groups. Evi-dence suggests that selective regulatory intervention in the wireless sector maybe necessary in certain cases to ensure that public interest obligations areachieved in a timely manner. This paper examines wireless E9-1-1 as a keystonestandardization initiative, drawing upon a layered policy model and the conceptof interconnection space to structure its analysis of the evidence.

Résumé : Le service 9-1-1 évolué (E9-1-1 sans fil) est un cas intéressant car ilnous permet d’évaluer la volonté de l’industrie de rencontrer ses obligations deservice public, en partie parce que le CRTC, suivant sa politique actuelle qui con-siste à encourager la concurrence, s’est généralement abstenu de réglementer lacommunication sans fil. Les résultats à ce jour sont mitigés : malgré des essaistechniques réussis lors des premières étapes, la diffusion du service s’est avéréelente et inégale, et des incertitudes et débats houleux entre les groupes impliquésont marqué les démarches initiales. Il y a lieu de penser qu’une réglementationlimitée du secteur sans fil pourrait s’avérer nécessaire dans certains cas pour quel’industrie puisse rencontrer ses obligations de servir l’intérêt public sans prendretrop de retard. Cet article examine donc le service E9-1-1 sans fil, l’envisageantcomme une initiative clé pour la standardisation, et se fonde sur un modèle depolitiques superposées et sur un concept d’« espace d’interconnexions » pourstructurer son analyse de données.

Keywords: Telecommunications policy; Mobile phone; Public safety; Location-based services; CRTC; Technical standards; Layer model

Gordon A. Gow is on the faculty of the Department of Media and Communications, London School ofEconomics and Political Science, Houghton Street, WC2A 2AE London, United Kingdom. E-mail:[email protected].

66 Canadian Journal of Communication, Vol. 30 (1)

IntroductionThe widespread dissemination of mobile telephones has placed an unexpectedburden on public safety agencies, where mobile phones now represent close to50% of total calls to 9-1-1 operations centres (BC 9-1-1 Service Providers Asso-ciation, 2001a). A serious concern for emergency services operators when dealingwith calls placed from mobile phones is the ability to identify the location of acaller in distress, as these callers may not be able to report their specific location,creating potential delays for emergency dispatch and response. Wireless-enhanced emergency service (“wireless E9-1-1”) is a new service being intro-duced into the public telephone network across North America that provides thegeographic location and caller-identification (“caller-ID”) information of amobile-phone caller when in contact with a 9-1-1 operator. It promises to assistemergency services and to dramatically enhance public safety through improvedresponse times. Its development in Canada also raises questions about the currentpolicy framework for wireless service providers with respect to their public safetyobligations.

This paper is based on a recently concluded and more comprehensive empir-ical study into the development of wireless E9-1-1 in Canada (Gow, 2003). Thestudy examined numerous aspects of the regulatory and industry processesinvolved in creating this new enhancement to public safety telecommunications,and it was informed by published studies on a variety of issues, including tech-nical standards, interconnection, and stakeholder participation in the developmentof large technical systems. Its findings were supported by extensive analysis ofsource documents filed with the Canadian Radio-television and Telecommunica-tions Commission (CRTC) and the Canadian Wireless Telecommunications Asso-ciation (CWTA). This paper will focus on one aspect of the larger study; namely,it will address the issue of technical standards and regulatory intervention.

The genesis of wireless E9-1-1 in CanadaThe story of wireless E9-1-1 in Canada actually originates in the United States,with the Federal Communications Commission’s (FCC) Notice of Proposed Rule-Making under Docket 94-102, issued in October of 1994. The primary intent ofthis notice was to launch a series of related initiatives to improve public safety inlight of growing concern over the impact of mobile phones at public safetyanswering points (PSAPs).

Over the course of some 35 years, public safety groups across the U.S. haddeveloped a rather advanced system for providing the public with the capability torequest emergency services by dialling the digits “9-1-1” (National EmergencyNumber Association, 2002a). The original 9-1-1 system was designed as a simplevoice connection to an operator designated to handle emergency calls and dis-patch appropriate agencies as required. With the subsequent development of moresophisticated telecommunications services, an enhanced “E9-1-1” system hasbeen implemented, whereby the voice connection is now augmented with data ele-ments that provide caller ID and the street address associated with the telephonenumber (National Emergency Number Association, 2002b). With these two

Gow / Public Safety Telecommunications in Canada 67

pieces of information, an emergency operator now has more information availableto improve dispatch operations. This enhanced functionality enables emergencycalls to be more easily re-directed to appropriate jurisdictions for dispatch, and inthe event that a caller is unable to provide their location verbally to the operator,emergency personnel can be directed to the exact spot from which the call origi-nated. This combination of Automatic Number Identification and AutomaticLocation Identification—or ANI/ALI (pronounced “Annie-Alley”)—function-ality has since become the benchmark feature of E9-1-1 across North America.

With the rapid adoption of mobile phones that began in the mid-1990s, thewell-established E9-1-1 system quickly became fragmented between wirelinecalls with ANI/ALI capability and calls from mobile phones that provided noenhanced functionality whatsoever. This was because the original E9-1-1 servicehad been conceived within a wireline environment, in which each telephonenumber was more or less permanently associated with a single street address.Mobile phones undermine this design, as a mobile phone number is not neces-sarily associated with a fixed physical location. Moreover, the typical trunk-siderouting arrangements between wireless carriers, incumbent carriers, and thepublic safety answering points have until recently made it technically impossibleto provide enhanced 9-1-1 functionality for mobile phones. The growth of mobiletelephone usage led to the need to develop new standards for the provision ofE9-1-1 service.

The FCC was determined to solve the problem of wireless E9-1-1 by estab-lishing a two phase process by which wireless carriers would be required toprovide ANI/ALI information to local public safety answering points (seeTable 1). In the first phase of the process, U.S. wireless carriers were required toprovide a system that would supply a local PSAP with the telephone number of themobile caller, plus low resolution location information in the form of a cell-site orcell-sector address from which the call to 9-1-1 had been placed. The secondphase requirements are more rigorous and demand that the wireless carriersimplement a system that provides ANI and high-resolution location informationin the form of the near-real-time latitude and longitude co-ordinates of the mobilephone (United States. Federal Communications Commission, 2001, 2003).1

Table 1: FCC Wireless E9-1-1 Requirements

The development of wireless E9-1-1 in Canada has not been prompted by adirect regulatory mandate as in the United States, but public safety agencies nev-ertheless face similar challenges from this emerging technology. With more than10 million (and still growing) wireless subscribers now in Canada (CanadianWireless Telecommunications Association, 2003b), the PSAPs that are respon-

FCC Phase Requirement

0 Transmit all 9-1-1 calls to a PSAP

1 Transmit ANI and cell-site/sector

2 Transmit ANI and latitude/longitude location


sible for handling 9-1-1 dialled calls have reported that up to half of all calls nowcome from mobile telephones, causing similar problems to those faced by Amer-ican emergency dispatch operators. Despite the lack of a specific regulatory man-date, however, the policy framework in Canada nevertheless has had a powerfulinfluence in shaping the development of a Canadian version of wireless E9-1-1. Inparticular, a number of major policy developments and regulatory decisions havecome to influence emergency services (9-1-1) deployment for mobile telephones.

Mobile phones and the CRTCUnder the Telecommunications Act of 1993, telecommunications in Canada fallwithin the portfolio of Industry Canada, and the CRTC regulates many of theactivities in this area. A central aim of the Act is, inter alia, to support the transi-tion to a liberalized and competition oriented telecom sector in Canada, with aspecific mandate “to foster increased reliance on market forces for the provisionof telecommunications services” (Canada. Department of Justice, 2001, sec. 7(f)). While this mandate has set the general tone for the regulation of the wirelesssector in Canada, section 34 of the Act has directly influenced the CRTC’s deci-sions regarding wireless service providers (WSPs) in Canada. Section 34(2) isoften a touchstone for Commission decisions regarding wireless service becauseit establishes the terms and conditions of regulatory forbearance:

Where the Commission finds as a question of fact that a telecommunicationsservice or class of services provided by a Canadian carrier is or will be subjectto competition sufficient to protect the interests of users, the Commission shallmake a determination to refrain, to the extent that it considers appropriate,conditionally or unconditionally, from the exercise of any power or the perfor-mance of any duty under sections 24, 25, 27, 29, and 31 in relation to theservice or class of services. [emphasis added]

In other words, the CRTC is required to forebear from applying certain sec-tions of the Act to carriers offering telecommunications services deemed to bewithin competitive markets. These specific sections fall under Part III of the Act,which deals with rates, facilities, and services, and thus include conditions of ser-vice, rates and tariffs, and working agreements between carriers.

Section 34 of the Act would prove to be a centrepiece for the future of thewireless sector through Telecom Decision 96-14: Regulation of Mobile WirelessTelecommunications Services, which has established what we might call thesecond generation of regulatory framework for commercial mobile telephony inCanada; this has now largely superseded the first-generation regulatory frame-work pertaining to analog mobile telephone services established in the 1980s(Canada. Canadian Radio-television and Telecommunications Commission,1996). The Telecom Decision followed on the heels of the appearance of digitalcellular (or PCS) into the Canadian market in 1995 and a public consultation(Public Notice 96-2) to determine the appropriate regulatory classification andtreatment of mobile wireless telecommunications services. The CRTC issued itsfinal determination in December 1996, citing section 34 of the Telecommunica-tions Act and stating that it would forebear from regulating most wireless service


providers with respect to conditions of service, tariff approval, rates and calcula-tion methods, and intercarrier working agreements. This decision established thatsecond-generation digital mobile-phone service in Canada would be largelyunregulated by the CRTC, as it was (or would likely be, in future) “subject to com-petition sufficient to protect the interests of users.”

It is important to note, however, that at the time Telecom Decision 96-14 wasissued, local exchange telephone service in Canada was a regulated monopolyheld by the incumbent landline carriers, so the Decision in effect created a situa-tion of regulatory asymmetry whereby wireless service providers, while providinglocal-exchange telephone service, were not required to meet many of the obliga-tions established for the incumbent wireline local-exchange carriers (ILECs). Atthe time of the Decision, mobile phones remained a relatively marginal service,but today they are increasingly competing directly against traditional telephoneservice as a form of wireless local loop, and yet wireless service providers are stillnot required to meet many of the public interest obligations set by the CRTC forlocal telephone service. Therefore, until some years later, the choice by mostWSPs to provide customer access to emergency services (9-1-1) was not based ona regulatory requirement, but was instead a voluntary offering that varied widelyin consistency and reliability across the country.

9-1-1 and the CRTC’s local competition frameworkFrom a regulatory standpoint, emergency (9-1-1) service received what to manymust seem a counterintuitive treatment in the Local Competition Framework(Telecom Decision 97-8) issued in May 1997, which opened local telephoneservice in Canada to the prospect of competition at the local loop (Canada. Cana-dian Radio-television and Telecommunications Commission, 1997). In paragraph113 of this decision, the Commission determined that 9-1-1 is not an “essentialfacility,” but it then established in paragraph 286 “that it is [nevertheless] in thepublic interest to require CLECs [competitive local exchange carriers] to provide9-1-1 service.” According to paragraph 74 of the Decision, to be “essential,” afacility, function, or service must fulfill all three of the following criteria: it ismonopoly controlled; competing local-exchange carriers require it as an input toprovide services; and competing local-exchange carriers cannot duplicate it eco-nomically or technically. At the proceedings leading up to Decision 97-8, severalparties argued that 9-1-1 should be treated as an essential facility, but the Com-mission did not accept these arguments in its final determination.

With regard to regulated local-exchange carriers, however, the Local Compe-tition Framework does specify a quality-of-service requirement for 9-1-1 servicethat includes “enhanced” functionality in some cases:

…With regard to 9-1-1 service, all [regulated] service providers must ensure,to the extent technically feasible, that the appropriate end-user information isprovided to the Automatic Location Identification database to the same extentas that provided by the ILEC [incumbent local exchange carrier]. (TelecomDecision 97-8, p. 286)


In most basic terms, paragraph 286 of Decision 97-8 simply means that newentrants into the regulated local-exchange market—known in the industry ascompetitive local-exchange carriers (CLECs)—must conform to standards forproviding emergency (9-1-1) service based on those set by the incumbent local-exchange carrier in the respective operating territory. Yet until 2003, theserequirements did not have any bearing upon most wireless service providers,because they do not qualify as regulated carriers, or CLECs, under the terms ofDecision 97-8. However, if a wireless service provider chooses to apply for CLECstatus, then among the obligations set forth by the framework for local competi-tion is a requirement to provide 9-1-1 service comparable to the ILEC-establishedstandard. While this obligation may seem reasonable in exchange for certainadvantages provided by CLEC status,2 a literal implementation of paragraph 286is problematic when considered from the point of view of a CLEC seeking to offermobile wireless service, because the ILEC standard is based on a fixed addressthat is associated with a telephone number. The ALI function is thus generatedbased on subscriber residence or business address in the database. This is clearlynot as helpful when dealing with a mobile phone, where there is no necessaryassociation between the address on a billing record and a subscriber’s physicallocation at the time a call is placed to 9-1-1. Paragraph 286 embodies what Lessig(1999) has termed “latent ambiguity,” and this was to surface in September 2000,when the CRTC granted interim approval to two new entrants—Clearnet PCS Inc.(later acquired by TELUS Mobility) and Microcell Connexions Inc. (using thebrand name Fido)—to become wireless competitive local-exchange carriers (W-CLECs). Telecom Orders 2000-830 and 2000-831 required these new entrants tointroduce wireless E9-1-1 where available, despite the fact that technical trialswere still under way at the time the Orders were issued and the service enhance-ment was neither available in Canada, nor was it likely to become available anytime soon in many areas outside of Vancouver, Toronto, and Calgary.

During the interim period, however, the Orders directed the W-CLECs toconform to the ILEC-established standard and to populate the ALI databases withtheir subscriber records—despite the evidence that had been given to the Com-mission regarding the questionable value (and cost) of such an undertaking for amobile service. In effect, the Orders sought to resolve the latent ambiguity ofparagraph 286 by imposing an ad hoc interim solution that sparked more regula-tory proceedings and dragged out a fractious debate over technical standards,which led to uncertainty and delays in the deployment of wireless E9-1-1 inCanada.

The interim solution revealed, among other things, the difficulty in deter-mining appropriate and effective regulatory intervention when public interest is atstake in otherwise unregulated areas of competitive activity. To understand moreclearly the various dimensions of this problem, it is helpful to consider the spe-cifics of wireless E9-1-1 in Canada as having characteristics attributable to a“keystone standardization initiative.”


Wireless E9-1-1: A keystone standardization initiative“Keystone standardization initiative” is a term coined by Richard Hawkins todescribe an undertaking that will “have implications for those broad areas of tech-nological development that relate directly to specific policy goals for the nationaltelecom system” (Hawkins, 1997, p. 206). The significance of the term is to drawattention to certain kinds of undertakings for which regulators need to be espe-cially vigilant in monitoring developments and making interventions. WirelessE9-1-1 can be viewed as a keystone standardization initiative insofar as it buildsupon and establishes a set of technical and operational standards with significantimplications for the future of public safety telecommunications and in this manneris related directly to the public interest objectives of the Canadian Telecommuni-cations Act.

In their most fundamental role, technical standards provide the foundation ofinteroperability for telecommunications systems; they are therefore an importantprerequisite in the early development and deployment of many new services. Thisis certainly the case for wireless E9-1-1 in the United States, where a major seriesof standards initiatives have been launched in the wake of the FCC mandate.Organizations such as the National Emergency Numbering Association (NENA),the Telecommunications Industry Association (TIA), and the American NationalStandards Institute (ANSI) have published volumes of recommendations andtechnical standards intended to enable functional requirements of wireless E9-1-1and to provide interoperability with existing systems.

Standards are not merely technical concerns, however, as they increasinglyhave become regarded as one of many strategic inflection points within a compet-itive supply market through which key players will seek to influence the design oftelecommunications networks to their advantage (Mansell, 1993, 1999). Attemptsat influencing network architecture often begin with the standardization process,as Hawkins discovered with his work on European digital wireless telephony,where he observed a close link “between standards and the development of partic-ular services and product lines,” showing how standards are often introduced atthe initial design stage of a product or service to influence its position in the mar-ketplace (Hawkins, 1995, p. 33). Furthermore, Hawkins observed that in this stra-tegic positioning role, standards-making often serves as “the institutionalmechanism through which factions in the telecoms industry mediate between theiradversarial commercial relationships and their common technical needs” (p. 33).These two observations represent what we might call strategic tendencies in thedevelopment of technical standards for new telecom services, and both are borneout in the development of wireless E9-1-1 in Canada.

The challenge for regulatory intervention within a competition orientedpolicy framework is to establish a fine balance between standards directives andvoluntary efforts to ensure “standards are produced and implemented in a way thatis compatible with regulatory objectives as set out in national policy” (Hawkins,1997, p. 200). Yet Hawkins claims that while telecom reform initiatives have ledto an increase in the range and complexity of standardization efforts, the direct


involvement of national regulatory agencies in standards development is nowmore limited in scope than ever before.

Despite a fading role for regulators in the standards-making process,Hawkins identifies three principles to guide regulatory intervention in keystonestandardization initiatives. The first principle speaks to the public interest at themost basic operational level, where regulators are responsible for ensuring theprovision of public network services by issuing broad directives in the form ofregulations. These services are the type intended to be available to all potentialusers on a “reasonably equitable” basis, and public safety services such as 9-1-1have been deemed to be in the “public interest” as stated in Canada’s Local Com-petition Framework under Telecom Decision 97-8. In order to meet this responsi-bility within an environment of rapid technological change, however, Hawkinspoints out that regulators must engage with standardization processes to “main-tain contact with the evolving technical parameters of different kinds of networkservices at the operational level” (1997, p. 205) in order to fulfill their role inoverseeing public network facilities.

A challenge to this oversight role comes from the expanded range of consid-erations by which firms are motivated to participate in standardization followingliberalization in the telecom sector. Hawkins identifies five “key types of stan-dardization rationale” (1997, p. 201) that are active within a competitive telecomsector today: variety reduction, harmonization, intelligence, design, and marketpositioning. Whereas variety reduction and harmonization are largely seen asmatters of cost reduction through technical interoperability, the latter three ration-ales are more closely aligned with strategic business activities intended to betterposition equipment and service suppliers in a highly dynamic marketplace.Industry players may seek to participate in standards development to gain valuableintelligence on trends and issues, influence “pre-competitive” technologies in theearly stage of development, or directly link their marketing and research anddevelopment activities with standards development to improve market positioningwith respect to new technologies and services.

The second principle of regulatory intervention in standardization speaks tofair play aspects of competition policy, as regulators must ensure that standardsdeveloped for and applied at key network bottlenecks “do not act to erect barriersto market entry, or to create technological path dependencies that favour certainforms of service development over others” (Hawkins, 1997, p. 205). Regulatorsmust find a way to engage with standards making processes to ensure a balancebetween shifting technical exigencies and regulatory symmetry. In the case ofwireless E9-1-1, this suggests that the CRTC has a role in ensuring that incumbentcarriers do not use technical standards to abuse their inherited and exclusivecontrol over the established 9-1-1 platforms, which serve as intermediary networkinterfaces between the wireless service providers and the public safety answeringpoints (this despite being classified as “non-essential” by the CRTC).

A number of instruments for the technical regulation of standards are avail-able to prevent abuse of essential facilities, but these must be appropriate to the


context in which they are applied. Technical regulation in the contemporarytelecom context can be classified into three primary methods: voluntary stan-dards, “virtually mandatory” standards that are de facto employed in a market, andmandatory standards set by a regulatory agency (Hawkins, 1997, p. 205). Whenconsidering these three instruments, however, Hawkins points out that regulatoryagencies must balance their need to influence certain aspects of network evolu-tion, especially those regarding broad general policy objectives, without imposingundue constraints on standards development that might counteract efficiencygains and incentives to innovate.

At the heart of this matter is a long standing tension between voluntary andmandatory instruments. Typically, voluntary instruments are preferred in thetelecom industry, under the rationale that industry knows its business best and ismotivated to work toward optimization of results. Hawkins points out that underthese conditions, optimal results are not guaranteed, and that this scenario couldvery well lead to problematic path dependencies as the dominant stakeholdersseek to preserve competitive advantage in the market through proprietary designs.In addition, without regulatory incentive, uncertainty in the standardizationprocess can result in delays in standards development and pose subsequent bar-riers to investment and innovation in network infrastructure. For regulatory agen-cies, this tension amounts to a need to balance between direct involvement andarms length oversight in standards development. Hawkins notes, however, thatwith the emerging complexity in telecom technology, any form of broad scaleinfluence is likely confined to a few international equipment manufacturers, ven-dors, and service providers. From a Canadian perspective, this suggests thatdomestic influence over standards development may be seriously constrained bytrends in the international setting, and especially those initiatives led by Americaninterests. This is clearly evident in the wireless E9-1-1 case, as we shall see, whereAmerican organizations have set the research agenda and have created “virtuallymandatory” standards available for application in Canada.

The third principle of regulatory intervention speaks to the broad social andeconomic policy objectives of national governments, and the concomitant needfor regulators “to support this policy structure and…to contribute to its develop-ment” by selective engagement with standardization processes (Hawkins, 1997,p. 205). As for the CRTC’s role with regard to public safety and mobile phones,the Telecommunications Act in Canada clearly states in subsection 7(a) that aprimary national policy objective is to “facilitate the orderly development…of atelecommunications system that serves to safeguard, enrich and strengthen thesocial and economic fabric of Canada” and, as stated in subsection 7(i), “torespond to the economic and social requirements of users of telecommunicationsservices” (Canada. Department of Justice, 2001). To the extent that the CRTC inDecision 97-8 recognized 9-1-1 as a matter of public interest, it is reasonable toargue that the “social requirements” of mobile phone users should include accessto emergency dispatch services.


A keystone standardization initiative represents a window of opportunity toco-ordinate the public interest objectives established in section 7 with the compe-tition directive in section 34 of the Act:

Standardization is becoming a crucial node through which the technical designof network services will be self-regulated with the industry…the standardiza-tion phase is the only open point of access at which users can inject their col-lective needs and perspectives into the process of network and service designsuch that they might actually influence its outcome. (Hawkins 1995, p. 34)

Despite this opportunity, there are numerous conceptual difficulties in sortingout the multifaceted commercial relationships that may exist between users andsuppliers as a result of network unbundling, which provides access at variouspoints of interconnection to new entrants and third-party service providers. Thissituation results in a potentially complex supply chain of services, creating prob-lems for making clear distinctions between suppliers and users in a competitivetelecom market. Hawkins attempts to address this problem by making a distinc-tion between end-users and intermediate users, based on the claim that intermedi-aries extend the functionality of the basic public network facilities, while end-users are typically a point of termination that adopts one or more service profilesprovided by a carrier.

Drawing on this distinction among user groups, Hawkins (1995) thendescribes some of the major practical obstacles to participation in standards-making. Among these he has observed that the community of various user groupstends to be fragmented in the users’ views depending on their position in thesupply chain (whether as end-users or intermediates). According to his findings,intermediate users tend toward a focus on upstream standards at the network core,while end-users concern themselves with downstream standardization efforts,such as the terms and conditions of network access. This fragmentation splitsresources and creates impediments for coherent participation in a keystone stan-dardization initiative. Furthermore, as a result of these obstacles, standardizationhas a tendency to remain an upstream, supplier led process “without much activereference to service requirements as perceived by the users” (Hawkins, 1995,p. 33).

In response to these considerations, Hawkins (1995) offers two alternatives tofacilitate closer involvement of the user community in standards making. First hesuggests the notion of an “honest broker,” or a third party external to both supplierand user communities. The second alternative is that of “the filter,” which is abody set up by a standards institution to allow the user community to participate instandards projects at various stages of development. Selective intervention is thekey to these alternatives, and some kind of “coercive mechanism” should be con-sidered to ensure the establishment of “user-administered requirements studies asconstituent parts of the standardization process” (p. 36). Hawkins suggests thatoversight in this regard is appropriate to the public regulatory function and may beespecially important in the case of a keystone standardization initiative, such as


wireless E9-1-1, where the downstream implications may have long-term or oth-erwise far-reaching implications for the public interest.

In the case of wireless E9-1-1 in Canada, an interesting question looms large:how is it that technical trials could be a success story in industry voluntary effortsand yet stall at the deployment stage? Is it possible to understand this in terms ofthe tensions and obstacles described by Hawkins? When and how could the regu-lator have become involved to ensure deployment in a timely manner, and whatwas at stake in the regulator’s reluctance to do so?

Interconnection space and technical standardsCommon technical standards are the foundation for interoperability and for theproduction of the network effects that are an important feature of telecommunica-tions systems. The idea of network effects is that “[as] the number of users of aproduct or network increases, the value of the product or network to other userschanges” (Cave, Majumdar, & Vogelsang, 2002, p. 76). These effects are createdby establishing symmetrical access to other users of the system through interoper-ability. Some network economists use the term “complementarity” to describe thecombined technical and social conditions required to achieve network effects(Economides, 1996), but a more common term in telecom policy literature is“interconnection.” Telecommunications analysts regard interconnection as a fun-damental enabler of all telecom regimes, and William Melody has gone so far asto call it the “cornerstone of competition”:

Interconnection is fundamentally important because the telecom system mustfunction as a single system. Users desire end-to-end services within an appar-ently ‘seamless’ communication network. They want connectedness and con-nectability. They do not usually care who own what facilities in the overallsystem, or how the communication links are established. As traditionaltelecom networks have grown from national to global dimensions and havebeen expanded to include competitive suppliers and new services, interconnec-tion has become the key to defining the limits of telecom service networks andthe structure of competition that can prevail in supplying them. (1997, p. 53)

Interconnection has thus served historically as a regulatory instrumentdirectly linked to telecom policy objectives, as both Melody and Noam haveargued. Noam (2001), for instance, has classified the recent history of telecomdevelopment into three distinct regimes of interconnection policy, which evolvefrom a “pro-incumbent” stance to “pro-competition” unbundling, then to “marketcontrol” strategies.

The historical shift in policy regimes has implications for keystone standard-ization initiatives. Within the pro-incumbent regime, networks were tightly inte-grated into closed vertical structures with limited points of interconnection amongsimilarly positioned full-service carriers. Technical standards were developed by asmall group of participants benefiting from a proprietary and vertically integratedarrangement. Recent developments in telecom reform and a shift to the pro-com-petition regime have permitted a gradual dissolution of closed vertical structuresand resulted in a more complex arrangement of network elements as new entrants


are permitted to compete against the incumbent in the provision of a growingrange of services at multiple points of interconnection.

The unbundling of network and service elements to support competitiveaccess requirements leads to potentially complicated arrangements of existingsystems and emerging technologies. In effect, this means that a keystone standard-ization initiative may embody a diverse range of legacy systems and new stan-dards under development by different organizations, which is indeed the case withwireless E9-1-1. Having some means of sorting out the complexity of such a situ-ation is important for enabling regulators to assess industry self-regulation and fordetermining selective intervention strategies when such efforts are seen to befailing to achieve policy objectives in a timely manner.

One such means for sorting out the complexity of emerging electronic com-munications infrastructures has appeared recently in the telecom policy literature,variously referred to as “the layer model” (Fransman, 2002) or “functionalsystems model” (Arnbak, 1997). These models are loosely based on the OpenSystems Interconnection (OSI) reference model originally created for the designof integrated communication systems.3 All layer models share the same basicfeature of classifying electronic services into a set of distinct but interconnectedfunctional strata. In some cases, the layer model is put forward as a replacement tothe traditional “silo” model used in communications policy, where regulatorymatters are more or less divided into separate vertical stovepipes such as voicetelephony, radiocommunications, and broadcasting (Sicker, 2002). Within thelayer model, these vertical silos are replaced by a series of horizontal, functionallydistinct, but interacting, subsystems. Arnbak’s functional systems model, forinstance, consists of four layers arranged from bottom to top (following the OSIconvention), from physical systems based on hardware elements to more logicalsystems based on software elements (see Table 2).

Table 2: The Layer Model

The primary functional system is that which provides physical transportbetween source and receiver(s); it includes wireline and wireless forms of trans-mission, as well as basic physical interfaces. The second system is that of “net-work services,” which includes the provision of switching, routing, and gatewayservices. The third system is “value-added services” that provide client-serveraccess to information content. Finally, the fourth functional system is “informa-tion services,” where content is created and supplied, often as a market good. Witha voice-telephony service, this fourth layer may not be readily apparent, but in thecase of wireless E9-1-1, the automatic generation of location information (ALI)forms part of this information services layer (as I illustrate).

Layer 4 Information services

Layer 3 Value-added services

Layer 2 Network services

Layer 1 Physical transport


Arnbak’s functional systems model helps to illustrate the complexity of sup-plier/user relationships and provides the basis for a more nuanced set of observa-tions with regard to the strategic tendencies Hawkins has observed instandardization initiatives. By mapping wireless E9-1-1 with the layer model, arange of supplier/user relationships and potentially varying degrees of regulatoryoversight at each layer come to light. For example, a combination of wireline andwireless infrastructure (Layer One) must enable end-to-end connectivity betweena customer’s mobile phone and the operator’s desktop telephone at a PSAP;network services (Layer Two) must enable the correct routing of a 9-1-1 dialledcall from the wireless service provider to the 9-1-1 platform, and from there on tothe PSAP. Network routing in Layers One and Two of the wireless E9-1-1 systemis divided into two main points of interconnection. The first of these is at the inter-face between the wireless service provider’s outgoing trunk lines and the 9-1-1platform, which in Canada is likely to be operated by the ILEC—although thisneed not be the case inasmuch as the CRTC has deemed 9-1-1 to be a potentiallycompetitive service. The second point of interconnection occurs at the interfacebetween the 9-1-1 platform and the PSAP telephone system.

The provision of caller-ID and location information (ANI/ALI) between thewireless service provider and the public safety answering point can be classifiedinto valued-added services (Layer Three) and information services (Layer Four).The value-added service component refers to the interconnection of signallingsystems and databases that must occur in order to populate the 9-1-1 platformwith ANI/ALI data and for the display of this data on the PSAP telephone system.(This is a distinct function from the network routing of the basic voice connectionthat takes place in Layer Two.) Finally, information services (Layer Four) refer tothe process and procedures by which location information is generated by thewireless service provider, associated with municipal addressing schemes, andeventually formatted for entry into the ALI database at the 9-1-1 switch and, ulti-mately, for display at the 9-1-1 operator’s computer terminal.

As this mapping suggests, and for all its seamless functionality, wirelessE9-1-1 requires a complex arrangement of organizations and technical standardsto enable and support this service. At Layer One, a physical infrastructure oper-ator is required to provide end-to-end connectivity. In some cases where large dis-tances or organizational boundaries are crossed, several Layer One operators maybe involved in the physical delivery of the voice call through switches and signal-ling systems (Layer Two). The wireless carrier, or perhaps a third-party serviceprovider, must operate an ALI database or 9-1-1 platform (Layer Three) thatoffers ANI/ALI data service to a PSAP. Finally, an information services providermust supply the location data, either in a raw or customized form, to the ANI/ALIdatabase located at the 9-1-1 platform or directly to the PSAP telephone system(Layer Four). All the functional subsystems must be interconnected in order tohave a working wireless E9-1-1 service, which is a primary objective of the key-stone standardization initiative in this case.


As one might imagine, the job of policy and regulatory analysis under theseconditions can be extremely complicated, as numerous stakeholders may beinvolved at one or more layers of the functional model, and strategic alignmentsamong players may vary according to the layer under consideration. Moreover,some of these functions may be regulated (e.g., physical transport) while othersremain unregulated (e.g., information services provision). In the case of mobiletelephones, the CRTC has largely refrained from involvement in the upper layers,while maintaining an active oversight role in the lower two layers of physical trans-port and network services through its Interconnection Steering Committee (Canada.Canadian Radio-television and Telecommunications Commission, 2001a).

Arnbak draws these four layers together into a multidimensional concept heterms “interconnection space” for analyzing unbundled telecommunications-network architectures. He claims it is a useful framework for assessing the needfor regulatory intervention under conditions of competitive supply:

The policy issues facing a regulator are to decide to what extent the costs andbenefits of a particular path through the interconnection space can bediscovered—and allocated—by a free market, or if regulations are required toenforce desirable interconnection paths. (1997, p. 79)

In the study that forms the basis of this paper, Arnbak’s interconnection spacewas applied to the case of wireless E9-1-1 to disintegrate the standardizationprocess into functional undertakings as they might correspond to the layeredmodel. The results of the analysis help to explain some of the problems faced inthe deployment of wireless E9-1-1 in Canada, as well as to suggest important con-siderations for regulatory intervention possibly relevant to future instancesinvolving keystone standards and the public interest. The remainder of the paperwill present this analysis and findings.

Technical standards and regulatory interventionOverall, the development of wireless E9-1-1 in Canada has been characterized bymixed and often contradictory results that correspond with Hawkins’ observationson strategic tendencies. On the one hand, the telecom sector and the PSAPsworked together through the Canadian Wireless Telecommunications Association(CWTA) to adopt a set of voluntary technical standards that were to define a par-ticular service enhancement (Canadian Wireless Telecommunications Associa-tion, 2003a). This was undertaken in a relatively proactive manner, open to mostmajor stakeholder groups, and it proved to be effective insofar as it ultimatelyresulted in a commercial tariff in British Columbia and Alberta that enabled theservice to be made available for the first time (Canada. Canadian Radio-televisionand Telecommunications Commission, 2001b). Throughout various proceedingswith the CRTC, the industry advocated this voluntary process as the best course ofaction, citing problems with the FCC mandatory approach to wireless E9-1-1 tosupport their case.

On the other hand, and despite the successful technical trials, progress on theactual deployment of wireless E9-1-1 in Canada has been slow in Canada’s major


cities and is virtually non-existent in other parts of Canada. Hawkins’ observationthat under certain conditions “the standardization process can result in delays…and pose subsequent barriers to investment and innovation in network infrastruc-ture” (Hawkins, 1997, p. 204) is supported by this case, as wireless E9-1-1 hashinged on the willingness of incumbent carriers to provide underlying intercon-nection services to which they have been reluctant to commit in certain instances.However, by considering wireless E9-1-1 as a standardization initiative within themultidimensional concept of interconnection space, a number of significant pat-terns come to light.

Wireless E9-1-1 in Canada involves all dimensions of interconnection space,where each layer tends to circumscribe a specific set of considerations and relatedissues for other layers. Table 3 provides a summary.

Table 3: Wireless E9-1-1 and interconnection space

At the physical infrastructure layer, the wireless local loop has challenged keyassumptions in the standard design of the ALI database, creating problems inlocating callers who are using mobile phones. Trunking arrangements betweenwireless service providers and the ILECs were also a central concern at this lowerlayer. At the network services layer, there was a requirement to develop documen-tation and intercarrier working agreements to specify interconnection arrange-ments and signalling between wireless service providers and the incumbent-controlled 9-1-1 system, as well as additional contracts specifying network ser-vices and administrative details between wireless service providers, incumbents,and public safety answering points. The 9-1-1 platform and ANI/ALI functionrepresents a value-added data service operated by the incumbents to the publicsafety answering points. At the fourth layer of information services, issues ofobtaining and verifying customer records for the ALI database, methods for cell-site mapping, and requirements for standardizing municipal addresses (the“Master Street Address Guide” or “MSAG”) featured prominently in the proceedings.

Functional Layer Considerations Issues

Information Services Subscriber records; cell-site mapping (ESRD); street address standards (MSAG)

Disruption of business models; control over critical information; customer privacy rights

Value-added Services ALI database Terms and conditions of access; database design and alternatives

Network Services Network-access services (Strawman; E9-1-1 tariff); ILEC/PSAP contracts

Terms and conditions of interconnection, including liability; requirements for new equipment; stranded investments

Physical Infrastructure Wireless local loop; trunking options

Problem equipment; legacy platforms; regional differences in network equipment and design


From an overall perspective, it is apparent in this case that industry voluntaryefforts were most successful at the lower layers of interconnection space, in thephysical and network services layers, where previously established technical stan-dards could provide a relatively uncontested choice of signalling options andnetwork-interface arrangements. Evidence from technical trials and minutes fromthe CRTC Interconnection Steering Committee (CISC) indicate that most partiesto the technical trials agreed to adopt these standards with little difficulty, perhapsmeaning that variety-reduction and harmonization rationales are more easilyaddressed in industry-directed forums than those matters considered to haveimportant consequences for strategic business operations.

Yet the matter is not quite that simple. Standardization at the lower layers ofinterconnection space also appeared in one instance to have an influence on thebusiness intentions of Microcell Connexions Inc. (Fido) to become a W-CLEC.Following a series of delays and a questionable ruling by the CRTC regarding itsE9-1-1 obligations, Microcell filed a Part VII application with the CRTC andrequested that the regulator force the ILECs across Canada to commit to certaintechnical standards either immediately or in their upgrade paths, to gain someassurances that the capability for deploying wireless E9-1-1 across the countrywould be put in place within a specified time frame (Microcell Telecommunica-tions Inc., 2001b). This request appeared at the time to be a strategic call for tech-nical standardization in the lower layers of interconnection space, insofar asMicrocell, in its W-CLEC bid, may have been looking to approach the CRTC withsome guarantee that it would be able to deploy wireless E9-1-1 on a national basiswithin a reasonable period if standard upgrades for the ILECs were to be man-dated. Such an assurance may have been seen by Microcell as a potential bar-gaining chip to avoid certain interim obligations in Orders 2000-830/831, whichwere widely regarded by the wireless industry as wasteful and of dubious merit.

In the upper layers of interconnection space—value-added services andinformation services—the issue of standards has not been resolved easily. Anextensive debate over what data should be used to populate the ALI databaseinvolved references to software design standards, municipal addressing schemes,and even the customer-activation process used by mobile-phone retailers. Detailsof this debate are documented elsewhere (Gow, 2003), but for the purpose of thispaper, the matter illustrates several considerations raised by Hawkins, especiallythe influence of large equipment manufacturers and international bodies, theproblem sorting suppliers from users in the telecom sector, and the challenge offragmented user communities. More generally, it suggests that while standardiza-tion does indeed seem to serve as a mechanism to mediate between factions in thetelecom industry, such adversarial commercial relationships are not necessarilythe same at each layer of interconnection space. In other words, strategic alliancesat one layer could disintegrate when faced with issues that reside in a differentfunctional layer.

This became evident in the debate that took place over a design for the ALIdatabase, illustrating the problem of external influences on domestic standardiza-


tion initiatives and the fragmentation these influences may create among usergroups. For instance, during the latter stages of the wireless E9-1-1 proceedings,following the successful technical trials, the PSAPs became increasingly vehe-ment about wanting the ALI database populated with two types of addresses: onefor the real-time location of the mobile-phone customer and another for the cus-tomer’s home or business address. For their part, the wireless service providerscountered with the argument that a home or business address is irrelevant to a callplaced from a mobile phone and, moreover, that the current ALI database in use atthe 9-1-1 platform is designed to accommodate only one address field per record.On this matter, the PSAP representatives, with one exception, were clearly alignedin their position as users of the ANI/ALI system. The wireless service providersand ILECs, as suppliers of the ANI/ALI service, were aligned in opposition to thePSAPs. This set of alliances, essentially confined to Layer Two concerns, becameincreasingly hardened as wireless E9-1-1 development proceeded from trials todeployment.

When one wireless service provider challenged the Alberta PSAP representa-tive to produce documentation on standardization that would support his counter-claims about the ALI database capabilities, the representative eventually cited adocument produced by the Telecommunications Industry Association (TIA), anAmerican-based standards organization (Alberta E9-1-1 Advisory Association,2002). To promote its claim for including two address fields in the ALI database,the Ontario 9-1-1 Advisory Board cited a “Future Models” document publishedby the U.S. National Emergency Numbering Association (NENA) (Ontario 9-1-1Advisory Board & Alberta 9-1-1 Advisory Association, 2001). Microcell and theother WSPs simply rejected the evidence on the grounds that it ignored the realityof the ALI system in current use, dismissing much of it as “blue sky” visions(Microcell Telecommunications Inc., 2001a). Later in the proceedings, the ALIdatabase debate fragmented the PSAP community itself when the BC 9-1-1Service Providers Association, having now had operational experience with wire-less E9-1-1, withdrew its call for populating the ALI database with a secondaddress field and joined the WSPs and ILECs in their views on the matter (BC9-1-1 Service Providers Association, 2001b).

Wireless E9-1-1 as a keystone standardization initiative has been heavilyinfluenced by American organizations such as NENA and the TIA, which arewell-resourced and influential participants that have published extensive stan-dards documents for suppliers and users of E9-1-1 services. While these stan-dards-making organizations have provided important resources for Canadiancarriers and PSAPs, they may also have created false expectations among theseparties, in part drawing out the debate over the ALI database design. Americantechnical standards are forged in working relationships found in the United Statesand may not be transplanted easily into Canada where PSAPs, WSPs, and ILECshave very different histories and relationships with one another (see Table 4).

The fact that a wireless E9-1-1 system is designed around two major points ofinterconnection is an important consideration in this debate, because it was at the


heart of numerous problems between the PSAPs and the WSPs, especially Micro-cell. In the overall process of providing wireless E9-1-1 service, the supplier/userrelationship is complicated by the two-point design in which the 9-1-1 serviceprovider (usually the ILEC) serves as an intermediary actor between the WSPsand the PSAPs. Constraints imposed by the intermediary create additional com-plexity in the design of the value-added services at Layer Two. Despite the factthat the Local Competition Framework in Canada does not consider 9-1-1 aservice that meets the mandatory conditions for designation as an “essentialfacility,” the 9-1-1 intermediary platform remains a monopoly controlled networkelement ultimately under the discretionary control of the ILEC in all regions ofCanada. In fact in 1999, before it was purchased by TELUS Mobility, ClearnetPCS did put forward a proposal that would have introduced a third-party providerof ANI/ALI, citing the provisions in the Local Competition Framework for sup-port, but this appears to have been largely ignored as a means of providing analternative to the ILEC-controlled E9-1-1 facilities (Alberta 9-1-1 AdvisoryAssociation, 1999; Ontario E9-1-1 Wireless Trial Committee, 2000).

Table 4: Shifting alignments in wireless E9-1-1

Another matter related to the Layer Two concerns over the ALI database thatwas not yet fully resolved involved the collection and standardization of customerrecords, which reside in the Layer One dimension. The representative for Micro-cell went to great lengths in his submission to the CRTC under Public Notice2001-110 to detail the requirements of obtaining and verifying subscriber recordsduring customer activation. At the heart of this process is the Master StreetAddress Guide, which pre-validates civic addresses before they are accepted by anALI database. Microcell’s position was that providing verifiable subscriberrecords would require real-time access to the MSAG and that such a propositionwas fraught with problems due to the inconsistent nature of MSAG coverage andthe potential range of civic addresses that a mobile subscriber might provide whenseeking service. In fact, in the CRTC Industry Steering Committee, Microcell hadasked Bell Canada to modify certain intercarrier working agreements to includeprovince-wide access to the MSAG in Ontario or, alternatively, for the CRTC toremove the requirement to validate subscriber records in Order 2000-831. BellCanada, which responded with a specific contribution to the CISC on this matter,argued against Microcell’s request on the basis that unrestricted access to MSAGs

Interconnection Space Alignments Conflict

Information services ILECs versus WSPs and PSAPs

Access to Master Street Address Guide (MSAG)

Value-added services ILECs and WSPs versus PSAPs

ALI database design

Network services ILECs versus WSPs and PSAPs

Upgrade paths and timelines in certain provinces

Physical transport Parties largely in agreement Choice of trunking and signalling (minor disputes)


“could assist outside suppliers in producing revenue reducing competitive prod-ucts” (Bell Canada, 2001).

This matter illustrates another shift in strategic alliances between interestedparties, because it involves ILEC control over municipal street address data (seeCRTC Interconnection Steering Committee. Emergency Services (9-1-1), 2001).When implementing an E9-1-1 service, local municipalities are often required toundertake a costly process of standardizing civic addresses to contribute to anMSAG system. In some areas this system has been under the exclusive control ofthe ILEC operating the E9-1-1 platform. Microcell’s request for wide area accessto the MSAG was perhaps the first challenge to the exclusive control of this poten-tially valuable resource. Following Bell Canada’s refusal to provide MSAG accessto other WSPs, the Ontario 9-1-1 Advisory Board complained bitterly that

It is the view of the OAB and [others] that municipal SAG information is pro-vided to Bell Canada for their input into the 9-1-1 database to meet the needsof all municipalities with whom they have agreements for [E9-1-1 service].Municipalities entrust Bell Canada with this information solely for the purposeof timely and effective emergency response. The intent is not to give them theright to claim sole ownership and distribution rights. We do not believe it iswithin their purview to unilaterally decide the extent to which this addressingdata should or should not be made available to Wireless CLECs. (Ontario 9-1-1Advisory Board & Communaute urbaine de Montréal, 2001.)

In this instance the strategic alliance of interested parties again changed, thistime at Layer Four (information services), as the ILECs found themselves inopposition to the PSAPs and wireless service providers. Furthermore, the Ontario9-1-1 Advisory Board’s comments on this issue may foreshadow future debates asmore advanced mobile tracking capabilities are deployed in Canada. The MSAGis a highly accurate and up-to-date means of validating municipal street addressinformation that could be used in turn to support commercial location-based ser-vices. It is also costly to maintain, and municipalities may seek to recover some ofthese costs by licensing access to third parties, perhaps leading to further re-align-ments between wireless service providers, ILECs, and other commercial interests.

ConclusionsMuch of the uncertainty surrounding wireless E9-1-1 in Canada has now beenresolved to some extent with the CRTC’s Decision 2003-53, which now requiresthat all wireless service providers offer E9-1-1 where the ILEC has made it avail-able (Canada. Canadian Radio-television and Telecommunications Commission,2003). If we begin counting with the initial wireless CLEC Orders in 2000, it tookthree years to arrive at this decision, which suggests that the CRTC’s Decision 96-14 to forebear from this sector may have created a problematic grey area withrespect to the regulation of emerging services in wireless telecommunications. Iwould argue that this is evident in the uncertainty on the part of the Commissionas to its role in the wireless E9-1-1 initiative and in its reluctance to intervenewhen the process bogged down in misguided debate, contributing to unacceptabledelays in the implementation of an important enhancement to public safety tele-


communications. The evidence also suggests that despite the CRTC’s previouslystated position on the matter, the ILEC-owned and -operated 9-1-1 platform isvery likely a de facto bottleneck in the provision of network access to the publicsafety answering points and should thus be reconsidered for “essential facility”status under the terms of the Local Competition Framework in Decision 97-8.

The layer model helps to reveal how strategic considerations among stake-holder groups may shift according to the various dimensions of interconnectionspace. With wireless E9-1-1, the unified effort between ILECs, wireless serviceproviders, and PSAPs that initially produced successful technical trials at thelower layers of interconnection space dissolved when dealing with matters in theupper layers. This may be partly a case of dominant players seeking to control theintroduction of new services by delaying or otherwise refusing to provide accessto certain network elements or information sources. In other cases it may be due toconflicting expectations among interested parties, as seemed to be the case withthe PSAPs and the ALI database.

Under these circumstances, or the threat of such circumstances developing,some measure of guaranteed and timely regulatory intervention must take place toensure that public interest obligations are taken into account, especially in mattersof public safety. However, the layer model also suggests that the most problematicstandardization efforts may be located in the domain of value-added or informa-tion services, where the terms and conditions for regulatory intervention are lesscertain.

The limited success of industry voluntary efforts in the case of wirelessE9-1-1 suggests that it may be possible to establish lower-level interconnectionarrangements without significant regulatory intervention. However, many ILECsoutside of BC, Alberta, and Ontario have been slow, and in some cases unwilling,to commit publicly to upgrading switch platforms to provide the network accessservices necessary to enable WSPs such as Microcell to provide wireless E9-1-1service in these other provinces.

With upper-layer issues, specifically the ALI database design, some of themisunderstandings and enmity between parties may have been avoided had theCRTC’s Interconnection Steering Committee—or perhaps more appropriately,Industry Canada—assumed an active role as third-party broker to liaise betweenCanadian stakeholder groups and E9-1-1 standardization activities taking place inthe United States with organizations such as the TIA and NENA. Acting asbroker, the representative could have vetted detailed technical information andmore closely assessed technical arguments within the proceedings, therebyoffering an intermediary perspective on disputed issues and providing reliableinformation to all parties, including the CRTC. An intermediary position, underthese circumstances, might also have assumed an overarching responsibility foridentifying verifiable best practices and encouraging all parties to adopt them inconjunction with critical path dependency issues related to network-upgrade deci-sions and transitioning to Phase 2 deployment of wireless E9-1-1 in Canada.


With the advent of wireless broadband services and third-generation mobilephones, the standardization of value-added and information services will grow inimportance beyond public safety concerns into commercial location based ser-vices, mobile commerce, and the delivery of multimedia content to mobile hand-sets. As such, selective regulatory intervention will likely need to extend across alllayers of interconnection space in order to ensure that public interest obligationsinform future keystone standardization initiatives and contribute to the orderlydevelopment of Canada’s telecom infrastructure overall.

Notes1. High resolution is defined according to the type of system that a carrier chooses to implement. For

handset-based solutions, the FCC has set an accuracy/reliability requirement of 50 metres for 67%of calls and 150 metres for 95% of calls. For network-based solutions, the FCC requires an accu-racy of 100 metres in 67% of calls and 300 metres for 95% of calls. A typical handset-based solu-tion uses GPS (Global Positioning System), which involves placing a small receiver in the mobilephone to enable it to report its physical location using satellite-based radio signals. Network-basedsolutions, by contrast, use triangulation techniques calculated at cellular base stations or controlpoints in the wireless network. An advantage of the network-based solution is that mobile phonesneed not be modified with GPS in order to be located in geographical space. The website of theAlabama chapter of the National Emergency Number Association (NENA) offers a good explana-tion of these solutions: http://www.al911.org/wireless_home.htm.

2. CLEC status offers carriers certain benefits unavailable to WSPs, such as local number portability(LNP) and access to contribution funds intended to offset service delivery in high-cost servingareas.

3. The OSI reference model was presented in 1984 by the International Standards Organization andcontinues to serve as an archetypal model for the design of electronic communications systemsand networks.

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Public Safety Telecommunications in Canada: Regulatory