October 7, 1998

TO:Toronto Emergency & Protective Services Committee

FROM:Norman Gardner, Chairman

Toronto Police Services Board

SUBJECT:IMPACT OF LOCAL TELEPHONE SERVICE DE-

REGULATION ON THE TORONTO POLICE SERVICE

Recommendations:

It is recommended that:

the Emergency & Protective Services Committee endorse recommendations with regard to the impact of local telephone service de-regulation on the Toronto Police Service and request City Council to send a letter to the Federal Minister of Industry indicating such endorsement, the specific recommendations are outlined as follows:

1.That a mandate be developed for the Number Portability Administration Centre (NPAC) that includes the registration of all wireline and wireless telephone numbers; and

2.That the Toronto Police Service have unobstructed automated access to a database of all wireline and wireless telephones in order to extract information, as necessary, for 9-1-1 calls, and 24 hour a day, 7 day a week access to a contact point for search warrants and telephone interception access.

Council Reference/Background History:

At its meeting on September 24, 1998, the Toronto Police Services Board was in receipt of the following report JULY 27, 1998 from David J. Boothby, Chief of Police:

SubjectImpact of local telephone service de-regulation on the Toronto Police Service

RECOMMENDATIONS:THAT the Board request the Federal Minister of Industry develop a mandate for the Number Portability Administration Centre (NPAC) that includes the registration of all wireline and wireless telephone numbers.

BACKGROUND:

The use of telephone services by the public has a significant impact upon the police service in two predominant areas; those being incoming emergency 9-1-1 calls, and investigations regarding the origin or content of a telephone call for investigative purposes.

Historically, the Service has dealt with one local telephone service provider, now known as the Incumbent Local Exchange Carrier (ILEC), which has been Bell Canada. Bell has a lengthy history of working with the police service and has maintained the expertise to manage the provincial Enhanced 9-1-1 network, and the security personnel to manage search warrants.

Local telephone service de-regulation as discussed in Board Minute 301/97 has resulted in the evolution of two new Certified Local Exchange Carriers (CLEC's) with another four providers anticipated in the Toronto market place by the end of 1999.

Today's telephone service also extends beyond the traditional "wireline" telephone, to include "wireless" telephone service as provided by cellular, Personal Communications Systems (PCS) and Low Earth Orbit Satellites (LEOS). An ever increasing number of emergency 9-1-1 calls, (approximately 20% to date in 1998) and telephone conversations that are part of a police investigation, are taking place over these "wireless" telephone systems. To date there are 4 major wireless telephone networks, with two additional LEOS networks entering the market place before the end of 1999.

To add to this ever expanding industry are a large group of companies that "re-sell" local telephone service they have purchased from a CLEC. These re-seller companies number in the hundreds across Canada. Re-sellers continue to represent a significant challenge for this Services response to emergencies. The Automatic Location Identification data at the 9-1-1 call centre often displays the name and address of the registered reseller, and not the location where the telephone is located. As a result, emergency crews have been dispatched to the administrative offices of a reselling company for heart attacks, robberies, and assaults without anyone knowing where the real event was occurring.

The Police Service, namely both the 9-1-1 Emergency Call Centre, and Intelligence Services on behalf of the investigative community, are primarily interested in three essential pieces of information:

1.) Where is the telephone physically located

2.) Who owns the telephone, or is subscribing to the service

3.) Which company is providing the service

This information is not standardized across carriers. Local resellers and Wireless Service Providers are not obligated to maintain this information, others do not provide access to it 24 hours a day. Further, there is currently no single point of contact for determining the ownership of all telephone numbers.

In order to look after the interests of the 9-1-1 Emergency Call Centre and the investigative community, significant time and effort has been expended by members of this Service to address issues created by telephone de-regulation.

The Communications E9-1-1 Co-ordinator Chair's the regional 9-1-1 Committee for Toronto (police, ambulance & fire departments) and sits as Vice-Chair of the Ontario 9-1-1 Advisory Board (information and press releases from whom are contained in Appendix A). She also sits as a participant of the 9-1-1 Sub-Working Group of the Canadian Radio-Television and Telecommunications Committee (CRTC) representing Ontario, and Co-Chairs the Canadian Wireless Telecommunications Association E9-1-1 Committee representing Public Safety Answering Points (PSAP's) nationally. Participation on these committees is undertaken to safeguard the interests of the Service, and to protect against the off-loading of costs to the municipality.

The CLEC Municipal Service Agreement constructed by the Ontario Board members of the E9-1-1 sub-working group, and developed in consultation with Toronto Legal Services, has resulted in the entrenching of quality and service commitments by CLEC's that will result in savings for Municipalities across the province for administrative and legal expenses while maintaining an superior level of service.

The Electronic Surveillance Co-ordinator for Intelligence Services also sits as a member of the Network Security Sub-Working Group of the CRTC on issues relating to privacy protection and telecommunications interception, and on the Telecommunications Committee of the Criminal Intelligence Service for Ontario. These efforts are undertaken to ensure the police services' access to information and investigative tools, while also protecting the municipality against the off-loading of costs.

The inconsistency in standards for some wireline and wireless providers, the separation of regulatory controls within Industry Canada, and the CRTC, along with the large number of Federal Acts and Regulations, makes the police services work in this field both difficult and time consuming.

The offices of the Communications E9-1-1 Co-ordinator and the Electronic Surveillance office and Records Unit of Intelligence Services are tasked with this additional work required to operate in this new and evolving telephone environment. This additional work is putting an added strain on the human and financial resources in these units and continued efforts will have to take place to ensure that the negative impact to our Service created by this de-regulation is limited as much as possible.

Although the direct costs associated with CLEC's was addressed in Board Minute 301/97, and at the Metropolitan Council meeting of 1998.10.8 (Appendix B), the growing human resource expenses associated with this issue are a direct result of actions on the part of the CRTC and the Federal government.

The previous efforts of the Board to prevent a "hard dollar" impact on the Service and the Municipality as a result of new CLEC's requesting direct connection to the 9-1-1 Network as opposed to the 9-1-1 Centres telephone equipment were successful. As a result of the Boards support of the Provincial 9-1-1 Advisory Boards' intervention, the resulting procedures for new CLEC's require their connection to Bell Canada's 9-1-1 network, which already provides our incoming 9-1-1 calls. This CRTC requirement ensures that the Municipality will not be saddled with the hardware upgrade costs and associated annual operating costs that would ensue, had the Board not been successful. Regardless, we have come to realize that there will continue to be additional human resource required to the meet the demands of dealing with this evolving multiple carrier environment.

In order to alleviate future human resource demands in the records tracking and telephone information management area, the Service is seeking a single point of contact for telephone number information. The CRTC has engaged a trusted third party company to act as the Number Portability Administration Centre (NPAC). This role is being fulfilled by Lockheed-Martin in Canada as well as the United States. The Service foresees the role of the NPAC as being "the keeper of the data" in relation to all wireline and wireless telephones. We are seeking unobstructed automated access to such a database to extract as necessary this information for 9-1-1 calls, and 24 hour a day, 7 day a week access to a contact point for search warrants and telephone interception access.

Failing this, the Service will be forced to take on the responsibility of tracking down subscriber information, addresses, and company information. This will impact upon our ability to provide timely 9-1-1 response, and escalate our human resource costs to secure and manage this information.

While the private sector companies that provide this service have shown their opposition to such a request for a broad number of self-serving reasons, they continue to be content to download the costs for these issues to local municipalities.

Therefore I recommend that the Board request the Federal Minister of Industry develop a mandate for the Number Portability Administration Centre (NPAC) that includes the registration of all wireline and wireless telephone numbers.

Superintendent William Holdridge of Communications Services (local 87709), Communications 9-1-1 Co-ordinator Judy Broomfield of Duty Operations (local 88899) Staff Sergeant James Brown (8-8851) of Duty Operations and Detective Sergeant Doug MacCheyne of Intelligence Services (local 83638) will be present to answer any questions on this issue.

Conclusions:

The following persons were in attendance and discussed this issue with the Board:

S/Sgt. James Brown, Duty Operations

Judy Broomfield, Communications 911 Coordinator

D/Sgt. Doug MacCheyne, Intelligence Services

Rick Galway, District Chief, Etobicoke Branch of the City of Toronto Fire Service & Member of the Canadian Executive, National Emergency Number Assoc.

The Board approved the following Motions:

1.THAT the Board approve the foregoing report; and

2.THAT, in order to broaden the awareness of the concerns created by telephone de-regulation, the Board:

a)provide a copy of the foregoing report to the Emergency & Protective Services Committee with a request that it ask City Council to endorse the Service's recommendation and send a letter of support to the Federal Minister of Industry; and

b)place this issue on the agenda of the next meeting of the "Big 12" Ontario Police Services Boards.

Contact Name and Telephone Number:

Staff Sergeant James Brown, Communications Services, Toronto Police Service, telephone no. (416) 808-8851.

Respectfully submitted,

Norman Gardner

Chairman

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