Questions RE: Emergency Public Notifications

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AN ANALYSIS OF EMERGENCY COMMUNICATION SYSTEMS, INITIATIVES, LEGISLATION, AND
PROTOCOLS IN CANADA
AUGUST 14, 2006
Giles Gysel
City of Kamloops
Information Technology Division
TABLE OF CONTENTS
EXECUTIVE SUMMARY………………………………………………………………………………………………3
EMERGENCY COMMUNICATIONS TECHNOLOGIES – OVERVIEW………………………………………….5
COMMUNITY NOTIFICATION SYSTEMS…………………………………………………………………………..5
ACQUIRING PERSONAL INFORMATION FOR EMERGENCY PUBLIC NOTIFICATIONS PURPOSES….5
BC PROVINCIAL LEGISLATION…………………………………………………………………………………….6
CANADIAN CITIES USING EMERGENCY NOTIFICATION SYSTEMS WITH VOLUNTARY
SUBSCRIPTION LISTS………………………………………………………………………………………………..7
CNS AND ACCESS TO EMERGENCY 9-1-1 DATABASES……………………………………………………...7
EMERGENCY 9-1-1 INTEGRATED CNS – SYSTEMS ARCHITECTURE……………………………………….8
CNS, ILECs and the CRTC…………………………………………………………………………………………….9
CNS AND WIRELESS TECHNOLOGIES……………………………………………………………………………11
THE ALBERTA EMERGENCY PUBLIC WARNING SYSTEM AND CANALERT………………………………11
PRIORITY ACCESS DIALING…………………………………………………………………………………………12
SUMMARY AND RECOMMENDATIONS…………………………………………………………………………….12
ANNOTATED SOURCE LISTING……………………………………………………………………………………..15
2
AN ANALYSIS OF EMERGENCY COMMUNICATION SYSTEMS, INITIATIVES, LEGISLATION, AND
PROTOCOLS IN CANADA
EXECUTIVE SUMMARY
The increased prevalence of national emergencies in Canada since the 1990’s has led to public demands for
emergency notification systems, services, and protocols. Warning systems fall into three broad categories:
emergency broadcast systems providing blanket notifications over television, radio, internet, and cellular
telephone network channels; priority access dialing and message notification for emergency staff; and
automated telephony call-out warning systems (Community Notification Systems or CNS) that access
Incumbent Local Exchange Carrier (ILEC) subscriber or other databases and Geographic Information System
(GIS) technologies to send messages to citizens in a defined geographic area.
Currently, emergency notification technologies are widely used in the United States and elsewhere, and there
are several vendors providing products and services to emergency authority and government clients. In
addition, the Canadian federal government, through Industry Canada, has spearheaded development of these
through initiatives involving ILECs, local government authorities, technology firms, and other stakeholders.
However, Canadian telecommunications companies are highly regulated under the Telecommunications Act,
and must conform to the Terms of Service assigned by their governing body, the Canadian Radio-Television
and Telecommunications Commission (CRTC). Therefore, roadblocks to blanket implementation of emergency
notification systems in Canada are more regulatory than technological at this time.
Under the federal Telecommunications Act, the Personal Information Protection and Electronic Documents Act
(PIPEDA) and the BC Freedom of Information and Protection of Privacy Act (FOIPPA), “white page” directorylisted telephone subscriber names, addresses, and telephone numbers are not confidential and are accessible
in emergency situations. However, white pages directories do not contain unlisted subscriber information,
which is confidential and cannot be disclosed except under limited circumstances defined in the ILEC’s Terms
of Service. Furthermore, white pages databases are only updated once a year. As such, the accuracy of white
pages listings is estimated at less than 60%, an unacceptable figure to local government authorities
implementing CNS.
Much more current and accurate is the ILEC’s Emergency 9-1-1 directory database which is updated daily, and
contains listed and unlisted numbers as well as subscriber information from Competitive Local Exchange
Carriers (CLECs) using ILEC infrastructure. The accuracy of an Emergency 9-1-1 directory is estimated at
95% or higher. However, access is severely restricted except in cases when subscribers waive their right to
privacy by contacting 9-1-1, or at the ILEC’s discretion when a threat to an individual’s life, health, or property is
imminent.
White pages listings could be enhanced by local government initiatives encouraging voluntary submission of
contact information, as is done with the County of Essex, Ontario Emergency Management Department and the
Alberta Northeast Region Community Awareness and Emergency Response (NR CAER) programs. These
communities already use CNS technologies operated by their regional ILECs (Bell Canada and Telus,
respectively) without having Emergency 9-1-1 database access.
Information collected by the City for emergency contact purposes would be subject to FOIPPA. Therefore, it
can only be used for the purpose it was collected, and must be maintained according to FOIPPA dictates.
Although BC Emergency Program Act Part 4 Section 26 has conditions to override all other provincial Acts,
including FOIPPA, the pre-requisite declaration of an official local state of emergency assumes such overrides
would only be implemented post-event, and FOIPPA legislation would still hold precedence for pre-event
emergency notifications.
Under FOIPPA, personal information collected for other purposes (i.e. property taxes, program registration)
cannot be used by the City for emergency contacts unless informed consent is given by that individual. It might
be possible to get consent at time of collection to build a voluntary emergency contact database, although
potential costs to the City in terms of maintenance, administration, and potential liability should information no
longer be current, or if an in-house system fails to operate, would likely outweigh the benefits of collection 1.
1
The prohibitive costs for municipalities to maintain and keep contact information current became evident during testing of CNS services in
Canada, as outlined in paragraph 16 of the CRTC Part VII application. See “Part VII Application Requesting Access to Incumbent Local
3
Rather than managing an emergency notification system in-house, a more cost-effective and efficient solution
is to use a hosted CNS solution provided by the ILEC whereby, using a secure web-based interface, a local
government authority records an emergency broadcast message and accesses the ILEC’s GIS system to
define coordinates for the emergency area. The GIS extracts information from the ILEC subscriber database to
automatically contact area residents and deliver the message using an Interactive Voice Recognition (IVR)
system. Using ILEC infrastructure means City implementation of parallel and redundant systems is not
required, while the web interface ensures access is available anywhere with an internet connection.
Undoubtedly, a CNS accessing an ILEC Emergency 9-1-1 database provides the greatest accuracy. However,
despite the involvement of Canadian ILECs in developing these technologies, requests by municipal and
emergency authorities to access ILEC Emergency 9-1-1 databases for CNS have been denied. ILECs cite
privacy concerns, the fact that access for CNS notification is not covered under their CRTC Terms of Service,
that CNS does not cover wireless or Voiceover Internet Protocol (VoIP) telephony technologies, and the overall
lack of federal emergency notification standards, protocols, and regulations currently in place. This is presently
at issue with the CRTC, under Telecom Public Notice 2005-7 (dated June 22, 2005). Given the fact that CRTC
Public Notices generally take 1-2 years to complete, it is not unreasonable to expect a decision and
corresponding Telecommunications Order to be issued in the next 3-6 months.
Although an Integrated Emergency 9-1-1 CNS is the most effective solution available for landline telephones, it
is not effective for wireless technologies, as contacting wireless subscribers individually using Short Messaging
Services (SMS) text messaging imposes a significant load on the cellular network and raises privacy issues.
Instead, Cell Broadcasting, a function of cellular wireless networks where text messages are sent
instantaneously within a defined broadcast area for the equivalent network load of a single SMS message, is a
much more efficient method of emergency notification. Technologically, Cell Broadcasting notifications using
an internet-based technology similar to CNS are possible, and currently the CRTC has a call for applications
(CRTC 2005-38, April 22, 2005) to provide an All Channel Alert (ACA) service pending.
A Canadian All Channel Alert is the goal of CANALERT, a national standard emergency public alerting protocol
initiative currently in development that will allow emergency management organizations to issue brief messages
over media such as radio, TV, cellular telephones, and the internet. Telephony-based CNS protocols will likely
be integrated under CANALERT once these are established.
The City should adopt a “wait-and-see” approach on implementing telephony-based emergency notification
systems until the CRTC makes its decision on Public Notice 2005-7. It is not unreasonable to assume ILEC
Terms of Service will be adjusted to allow Emergency 9-1-1 database access for CNS notification, given the
fact that all stakeholders – including the ILECs, who stand to gain marketing opportunities for new products
based on infrastructure they are already obligated to maintain – are not adverse to the principle of CNS
implementation to enhance public safety. Once the CRTC decision is made and corresponding
Telecommunications Order issued, the City can better evaluate its own position regarding CNS implementation
and the costs involved, as the CRTC Order will likely assign regulated service tariffs as well. Regardless of the
CRTC decision’s outcome, the most efficient solution is to use an ILEC-hosted solution rather than collect and
manage emergency contact data in-house, unless an ILEC-hosted CNS is extremely cost-prohibitive. Any
decision to implement an in-house CNS and/or a program of voluntary contact information collection should be
based on these factors.
A wait-and-see approach on emergency broadcasting to wireless devices should also be taken until the
outcome of CRTC ruling 2005-38 and the CANALERT national emergency broadcast protocol initiatives are
known. Ideally, any emergency notification solution would integrate functionality for landline, wireless, and
other communication technologies.
The City should take advantage of the federal Priority Access Dialing and Wireless Priority Services currently
offered by the Industry Canada Emergency Telecommunications Data System (ETDS) to ensure critical staff is
given priority access to landline and wireless networks during emergency situations.
A source listing of various initiatives, products and services is provided at the end of this document.
Exchange Carriers (ILECs) Emergency 9-1-1 Databases for the Purpose of Providing a Community Notification Service”, CRTC website, June
14, 2004 http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
4
EMERGENCY COMMUNICATION TECHNOLOGIES – OVERVIEW
The increased prevalence of national emergencies in Canada since the 1990’s has led to public demands for
emergency notification systems, services, and protocols. Warning systems fall into three broad categories:
1) Automated telephony call-out warning systems (Community Notification Systems or CNS) that access
Incumbent Local Exchange Carrier (ILEC) subscriber and other databases and Geographic Information
Systems (GIS) technologies to send messages via telephone to citizens in a defined geographic area.
2) Emergency broadcast systems providing blanket notifications over television, radio, internet, and cellular
telephone network channels
3)
Priority access dialing and message notification over telephone and wireless networks for authorized
emergency staff
COMMUNITY NOTIFICATION SYSTEMS
Telephone Emergency Notification Systems (also referred to as Community Notification Systems or CNS)
operate by accessing Incumbent Local Exchange Carrier (ILEC) or other database subscriber information in
areas defined by geographic coordinates using Geographic Information System (GIS) technology. The GIS
interfaces with the subscriber database to automatically dispatch multiple calls (minimum 1,500 calls per hour) 2
over Public Switched Telephone Network (PSTN) landlines in the defined emergency area.
Calls are pre-recorded messages sent by the emergency authority via an Interactive Voice Recognition (IVR)
system, providing instructions and asking the call recipient to confirm receipt of the message by pressing a
telephone key. Reports can be generated by the emergency authority as to the number of calls confirmed as
answered/not answered to consider further action.
Emergency 9-1-1 Integrated CNS systems (also referred to as “Reverse 9-1-1” systems)3 are already prevalent
in the United States and elsewhere and there are several vendors offering these products. However, the U.S.,
under the Patriot Act, does not guarantee the same level of landline telephone subscriber privacy as Canada
does. Furthermore, U.S. telecommunication companies are not regulated as strictly or thoroughly as Canadian
ILECs, which fall under the jurisdiction of the Canadian Radio-television and Telecommunications Commission
(CRTC) under the terms of the Telecommunications Act.
Therefore, in Canada the issue surrounding CNS implementation is more a regulatory/legal one than a
technical one at this time.
ACQUIRING PERSONAL INFORMATION FOR EMERGENCY PUBLIC NOTIFICATIONS PURPOSES
In Canada, any disclosure of/access to information on ILEC databases are considered services provided by
telecommunications companies. As such, these services fall under the jurisdiction of the Telecommunications
Act, and therefore under the authority of the CRTC regulating body, which regulates telecommunication carrier
tariffs and Terms of Service conditions. Under the Telecommunications Act, CRTC authority takes precedence
over federal Personal Information Protection and Electronic Documents Act (PIPEDA) and BC provincial
Freedom of Information and Protection of Privacy Act (FOIPPA) regulations, and in some instances these Acts
are not completely harmonized 4.
2
TELUS Geomatics system capacity for communities of Fort Saskatchewan, Lamont, Sturgeon, and Strathcona, AB, as quoted in Article
“Community Notification System Launched”, April 1, 2003, from Telus website http://www.telusgeomatics.com/tgmain/aboutus/articles/nrcaerfr.htm (24 July 2006).
3 “Reverse 9-1-1” is a registered trademark for a CNS product owned by Microsoft. In this document the technology will be referred to under the
more generic terms of Community Notification Systems, CNS or 9-1-1-Integrated CNS.
4
The CRTC asserts its authority over PIPEDA in Paragraph 23, CRTC Telecom Decision 2002-21, April 12, 2002 and Paragraph 23, CRTC
Telecom Decision 2003, May 20, 2003. Overall, respondents have urged that the CRTC harmonize its right to access provisions with PIPEDA in
5
Under the Telecommunications Act, PIPEDA, and FOIPPA, Names, Addresses, and Telephone Numbers of
listed subscribers are not considered confidential, and can be obtained by accessing the ILEC “white pages”
directory or other commercially available databases. However, white pages directories do not contain unlisted
numbers, are only updated once a year, and often do not cover rural areas lacking addressing systems. In
addition, subscribers to the Canadian Marketing Association’s “Do Not Solicit” list are not available. As such,
the accuracy of white pages information is estimated at less than 60%5. There is also the danger of incorrectly
notifying people who have changed addresses but maintained the same telephone number, potentially causing
undue panic and confusion during emergency situations.
Personal information can be obtained through voluntary submission to a local government agency, which would
then enter/store it in a database to contact subscribers during an emergency. However, collecting information
in this manner does not guarantee full citizen participation and/or currency of the information once submitted.
The agency has to incur the expense of purchasing, managing, operating, and maintaining the database.
Voluntary submission may also create legal issues as the onus would be on the local government agency to
ensure subscribers are contacted as promised and the in-house system functions properly during an
emergency.
Some level of voluntary participation could be encouraged in conjunction with other City business when
personal information is collected such as paying property taxes, renewing business licenses, or program
registration, although it is unlikely the currency, accuracy, and blanket coverage required for an emergency
notification system to operate effectively would be sufficient using voluntary collection methods.
BC PROVINCIAL LEGISLATION
Under normal circumstances, as a BC public body the City is subject to FOIPPA regulations for all personal
information it collects, stores, and discloses. As a result, it must disclose information only for the purpose it is
collected, or under the specific provisions defined in FOIPPA Part 3 Sections 26-36.
Local municipal emergency authorities in British Columbia are subject to the conditions of the provincial
“Emergency Program Act” for their jurisdiction. Section 26 of the Emergency Program Act states:
“Unless otherwise provided for in a declaration of a state of emergency made under section 9 (1) [of this Act] or
in an extension of the duration of a declaration under section 9 (4), if there is any conflict between this Act or
the regulations made under this Act and any other Act or regulations, this Act and the regulations made under
this Act prevail during the time that the declaration of a state of emergency is made under section 9 (1) and any
extension of that declaration is in effect” 6.
As such, in British Columbia, the protection of privacy dictates under FOIPPA can be overridden should an
official local state of emergency be declared according to the Emergency Program Act. Therefore, the local
emergency authority could access City-controlled personal information without being constrained by FOIPPA.
However, the pre-requisite declaration of an official state of local emergency assumes Emergency Program Act
overrides to FOIPPA would only occur post-event, and FOIPPA legislation would still hold precedence for any
pre-event emergency notifications unless a local state of emergency has already been declared.
Under FOIPPA, any personal information collected, stored, and disclosed by the City is subject to the Canadian
storage and access provisions under Section 30.1. As such, the City must take steps to ensure whatever
emergency notification system solution (either hosted or in-house) it implements does not allow access,
storage, transport, or disclosure of data outside Canada unless an individual’s informed consent is given, or
under the conditions specified by FOIPPA.
regard to protection of subscriber privacy. Cited from CRTC Part VII Application Requesting Access to ILECs Emergency 9-1-1 Databases
Paragraph 70, 14 June, 2004, accessed from CRTC website http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
5
Part VII Application Requesting Access to ILEC’s Emergency 9-1-1 Databases, Attachment 3: Proposed Community Notification Service
Guidelines, Section 6. Accessed from CRTC site http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
6
Emergency Program Act, Part 4, Section 26. Queen’s Printer, Province of British Columbia, 2005
http://www.qp.gov.bc.ca/statreg/stat/E/96111_01.htm#section26 (24 July 2006).
6
CANADIAN CITIES USING EMERGENCY NOTIFICATION SYSTEMS WITH VOLUNTARY SUBSCRIPTION
LISTS
Currently, the County of Essex, Ontario Emergency Management Department, and the communities of Fort
Saskatchewan Lamont, Sturgeon, and Strathcona, AB (via the Northeast Region Community Awareness and
Emergency Response or NR CAER) offer voluntary emergency response subscriber service lists.
The County of Essex’s volunteer registration form is available at:
http://www.townoflakeshore.on.ca/emer.htm
The NR CAER volunteer registration form is available at:
http://www.nrcaer.com/pages/contactinfo.htm
The NR CAER also provides a 24-hour call update line whereby NR CAER-member companies and authorities
in the region can report unusual situations. The public can also access information/updates via a toll-free
number. The update line is associated with the NR CAER emergency call-out system, which automatically
contacts residents by telephone in an emergency area, as per information provided from the link below:
http://www.nrcaer.com/pages/ul_faq.htm
The NR CAER CNS is a hosted system operated by Telus Geomatics, which recently tested its emergency
notification system in Coquitlam, BC. 7
Information provided for the County of Essex and NR CAER CNS is a combination of commercially available
“white pages” information and volunteer submissions. Both the Essex and the NR CAER forms require
applicants to submit information via fax directly to the agency.
If the City proceeds with a voluntary submission approach, a similar form could be posted to the City’s website,
although there are potential negative staffing, data administration, legal, and FOIPPA impacts for keeping such
a list. Furthermore, initial testing in Canada 8 has shown that an ILEC-hosted CNS solution using ILEC
subscriber information is much more cost-effective than a City-operated and maintained system.
CNS AND ACCESS TO EMERGENCY 9-1-1 DATABASES
Contrasting the less than 60% accuracy of white pages information are ILEC Emergency 9-1-1 databases,
which are maintained according to CRTC regulations. Emergency 9-1-1 databases contain listed and unlisted
numbers for both ILEC and Competitive Local Exchange Carrier (CLEC) 9 subscribers, are updated daily to
ensure currency and accuracy, and are geographically mapped and displayed using the ILEC’s Automatic
Number Identification/Automatic Location Identification (ANI/ALI) system. Because of these attributes,
information on Emergency 9-1-1 databases is estimated to be over 95% accurate 10.
As a result, local government authorities are seeking to gain access to ILEC 9-1-1 databases for CNS usage.
However, Canadian telecommunications companies are bound by their CRTC-defined Terms of Service to
keep data stored in 9-1-1 databases strictly confidential except under limited conditions. For example, a
“Coquitlam Test Site for New Public Alert System”, November 18, 2004, accessed via Telus Geomatics website
http://www.telusgeomatics.com/tgmain/aboutus/articles/04Coquitlam.htm (24 July 2006).
7
8
The prohibitive costs for municipalities to maintain and keep contact information current became evident during testing of CNS services in
Canada, as outlined in paragraph 16 of the CRTC Part VII application. See “Part VII Application Requesting Access to Incumbent Local
Exchange Carriers (ILECs) Emergency 9-1-1 Databases for the Purpose of Providing a Community Notification Service”, June 14, 2004.
http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
9
CLECs, or Competitive Local Exchange Carriers, are Telecommunications companies offering service using pre-existing ILEC infrastructure.
“Part VII Application Requesting Access to ILEC’s Emergency 9-1-1 Databases Attachment 3: Proposed Community Notification Service
Guidelines, Section 6”, June 14, 2004. http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
10
7
caller’s right to privacy is waived when an emergency authority is contacted via 9-1-1, or when an emergency
authority is allowed to access the 9-1-1 database to contact endangered residents in a specific location (i.e, if a
neighbour calls 9-1-1 to report a fire in the house next door, 9-1-1 database access is given for emergency
authorities attempting to contact residents in that house).
There are other limited circumstances when subscriber privacy is waived, most notably, if the subscriber is
notified in writing and gives written consent; or, “to a public authority or agent of a public authority if in the
reasonable judgment of the [ILEC] it appears there is imminent danger to life or property which could be
avoided or minimized by disclosure of the information”11, but the onus is on the ILEC and not the emergency
authority to make this decision.
EMERGENCY 9-1-1 INTEGRATED CNS – SYSTEMS ARCHITECTURE
A national public alerting initiative was launched by Industry Canada in 2002 12 in response to the 2003 Senate
Committee report recommending implementation of Community Notification Systems that access ILEC
Emergency 9-1-1 databases in all Canadian municipalities13. Under the Industry Canada initiative, CNS
prototypes that access Emergency 9-1-1 databases have been developed by local and provincial government
authorities in conjunction with regional ILECs and computer software companies.
Below is a high-level diagram of the systems architecture for a Community Notification System based on ILEC
Emergency 9-1-1 database information:
Systems Architecture of Proposed Community Notification System
14
C omm u n i ty Notifi cati on S ys te m
Aut horized
Administ rat or
Cent ral Office
P ST N
T elephone
Int ernet
Cent ral Office
ILEC IVR Syst em
Firewall
ILEC GIS
Server
ILEC CNS
911
Dat abase
ILEC
E911
Dat abase
Cent ral Office
11
Telus General Terms of Service, Item 119.5 as approved by Telecom Order CRTC 2003-323. Similar conditions are laid out for Bell Canada
under Telecom Order CRTC 2003-319 ITEM 10 Article 11.1. Cited from “CRTC Part VII Application Requesting Access to ILECs Emergency 91-1 Databases”, Paragraphs 48 and 49, June 14, 2004 http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
12
“Industry Canada Emergency Telecommunications – Update of Public Alerting Demonstration and Evaluation Projects” March 20, 2006
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00052e.html (24 July 2006).
13
“National Emergencies: Canada’s Fragile Front Lines – An Upgrade Strategy”, Standing Senate Committee on National Security and
Defense, Volume 1, March 2004, p. 67 http://www.parl.gc.ca/37/3/parlbus/commbus/senate/com-e/defe-e/rep-e/rep03mar04vol1-e.pdf (24 July
2006).
“CRTC Part VII Application Requesting Access to ILECs Emergency 9-1-1 Databases” Paragraph 37, June 14, 2004
http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm (24 July 2006).
14
8
With this architecture, the CNS makes use of an ILEC’s web-based Geographic Information System (GIS)
coupled with an automated Interactive Voice Response (IVR) system. Authorized emergency personnel log
into the ILEC GIS via the internet using a secured account and password and enter map coordinates of the
emergency areas to be contacted. The GIS then queries the ILEC’s Community Notification System database
(which is automatically updated from the Emergency 9-1-1 database) for addresses and telephone numbers
within the specified emergency areas. After contact information is gathered, the emergency authority
configures the IVR with a broadcast message to be delivered via telephone. The broadcast message gives
instructions and requests recipients to confirm receipt of the message by pressing a specified telephone key.
Once a call-out has been performed, a report is generated indicating the number of phones in the affected
area, the number of calls answered/not answered, and busy signals or calls sent to answering machines.
Confidential customer information, names, addresses, and telephone numbers are not included in the call-out
report, no confidential customer information aside from phone numbers and addresses are collected when
querying the 9-1-1 database, and as the emergency authority is viewing a “mirror image” of the database rather
than accessing it directly, the data cannot be altered or corrupted 15.
Test trials determined it is too expensive and difficult for municipalities to collect, maintain, and update contact
information and keep it “real time” accurate, while ILEC white pages/directory assistance listings are neither
current nor comprehensive enough to operate an Emergency CNS 16. Furthermore, as the most up-to-date
and accurate contact information is stored in ILEC Emergency 9-1-1 databases, which must already be
maintained as per CRTC regulations and are accessible under emergency conditions according to the ILEC’s
discretion, an ILEC-hosted, an Integrated Emergency 9-1-1 CNS solution is the best option.
CNS, ILECs and the CRTC
Despite their role in developing an Integrated Emergency 9-1-1 CNS, requests by local government authorities
to access Emergency 9-1-1 databases for CNS use were refused by regional ILECs (Telus, Bell Canada,
Aliant), who argued that allowing access to confidential unlisted numbers and records belonging to Competitive
Local Exchange Carriers (CLECs) using ILEC infrastructure represent a breach of their CRTC Terms of
Service. Local government authorities counter-argued that, since CNS is intended as an extension of 9-1-1
emergency service to further enhance public safety and would only be activated during emergency situations,
ILECs do have the authority to grant access.
As a result, on June 14, 2004 the County of Strathcona, AB; the City of Fort Saskatchewan, AB; the
Association of Municipalities of Ontario; the City of Brandon, MB; the New Brunswick Department of Safety;
Emergency Management Alberta; Emergency Management Ontario; the County of Essex; and the City of
Niagara Falls, ON (collectively, “The Applicants”) filed a Part VII application with the CRTC requiring ILECs to
provide access, and establishing terms and conditions of access, to their Emergency 9-1-1 databases in order
to allow municipal, regional district, or other local government authorities to use this information for CNS
purposes.
The Applicants submitted that ILEC 9-1-1 databases are the most accurate and current sources of telephone
numbers for citizens and that ILECs presently have authority to grant access during emergency situations
under their CRTC Terms of Service, requesting a decision be expedited to rapidly establish CNS on a universal
basis throughout Canada.
As an attachment, the Applicants proposed guidelines for CNS operation including a policy statement and
rationale for 9-1-1 Integrated CNS usage; steps to protect information in the database; terms for authorized
users and emergency situations protocols to activate CNS; training requirements; and recommended public
complaint handling and document review processes 17. Under the Applicant’s proposed guidelines:
15
Ibid, paragraph 30.
16
Ibid, paragraph 16.
17
“CRTC Part VII Application Requesting Access to ILECs Emergency 9-1-1 Databases – Attachment 3: Proposed Community Notification
Service Guidelines”, June 14, 2004, page 7. Accessed from Industry Canada website page “Industry Canada Emergency Telecommunications
– Public Alerting In Canada” http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00019e.html (24 July 2006).
9

Only appointed public safety officials responsible for emergency management in their communities
would have access to CNS.

CNS users would not have direct access to 9-1-1 databases or be able to manipulate data.

No personal information other than critical data required for the CNS alert (i.e. address and telephone
number) would be accessed.

Downloadable call status reports would contain no personal information

Sufficient firewalls and encryptions would be in place to ensure 9-1-1 database information could not
be intercepted or made useful outside of the original context.

Emergency events and appropriate jurisdictional authorities for activating CNS are defined (i.e. a local
CNS activation would not be used for severe weather warnings, which are the responsibility of
Environment Canada),

Standardized protocols for CNS emergency message content and training/certification pre-requisites
for authorized users receiving CNS access are specified.
Responses were filed by Telus, Bell Canada (and its affiliates) and Aliant Telecom; the Office of the Privacy
Commissioner of Canada (OPCC); and the Public Interest Advocacy Centre (PIAC) (collectively, “The
Respondents”).
Although the Respondents were supportive of the need for public emergency notification systems, they felt
conditions to access confidential information for CNS purposes could not be authorized under the ILEC’s
current CRTC Emergency 9-1-1 tariffs and Terms of Service. In addition to privacy concerns, there were
issues with the fact that CNS Emergency 9-1-1 database access makes no provisions for wireless, VoIP, and
other technologies; that CNS has not been sufficiently tested to ensure overload on ILEC 9-1-1 infrastructure
would not occur during emergencies; and that provisions of access, “emergency” conditions, authorized user
requirements, and systems interface access between ILECs and local government authorities are not specified,
codified, mandated, and regulated on a federal level.
Despite counter-arguments from the Applicants addressing these concerns, on June 22, 2005 the CRTC set
aside the Part VII application to initiate a public proceeding (CRTC Public Notice 2005-7) with the following
scope:
1) Does the public value of a CNS accessing ILEC’s 9-1-1 database information sufficiently outweigh
subscriber privacy concerns for the CRTC to permit its usage?
2) If the CRTC does permit this usage:
a. Who should be authorized and what other entities should be involved with the request?
b. In what situations and circumstances should the information be made available for CNS purposes?
What is an appropriate definition of “emergency” situations?
c.
What information should be made available?
d. What additional safeguards, including relevant terms and conditions, should be established to
ensure there is no compromise to personal privacy by CNS operation?
e. How should CNS using information contained in the in 9-1-1 databases operate? (i.e. should
entities be given access to 9-1-1 databases or should they only be authorized to request use of the
information? Who/how/by what system should disseminate CNS messages? How and when
should potential entities interact with each other to provide a CNS? What requirements should be
imposed on ILECs and CLECs on the operation of CNS?) 18
18
Telecom Public Notice CRTC 2005-7, Paragraph 19, June 22, 2005 http://www.crtc.gc.ca/archive/ENG/Notices/2005/pt2005-7.htm
10
Currently, CRTC Public Notice 2005-7 is still pending. However, given that deadlines for submission have long
passed, the fact that Public Notice hearings take 1-2 years to complete, and the importance of expediting this
decision, it is not unreasonable to expect a ruling and corresponding CRTC Telecommunications Order within
the next few months.
CNS AND WIRELESS TECHNOLOGIES
It is significant that the scope of CRTC Public Notice 2005-7 does not cover emergency notification systems for
wireless technologies. The Respondent’s arguments point this out, also citing regulatory and security issues
with accessing ILEC 9-1-1 database information to contact wireless technology subscribers.
Although an effective means of contacting landline PSTN subscribers, using telephony-based CNS technology
to notify wireless subscribers is inefficient, as contacting wireless subscribers individually using Short
Messaging Services (SMS) text messaging is time consuming and imposes a significant load on the cellular
network. During emergency situations, this may interfere with normal operations when maintaining
communications is essential19. In addition, using CNS for wireless technologies raises privacy issues as SMS
text messaging requires the recipient’s identity and current physical location to be known, accessing personal
information from the Wireless Service Provider’s (WSP) database without consent of the subscriber.
A much more efficient and effective method of emergency communication for wireless devices is to use a Cell
Broadcasting technology. Cell Broadcasting is a function of cellular wireless networks whereby text messages
can be sent instantaneously to all emergency message-enabled wireless devices in the broadcast area for the
equivalent network load of a single SMS text message, and without requiring access to subscriber information.
Similar to CNS, an authorized administrator can define specific areas where emergency messages are sent
using an internet-based technology.
CellAlert Canada is a for-profit organization formed by the international non-profit organization Cellular
Emergency Advisory Service Organization (CEASA) to implement technology to provide a Cell Broadcast
system over wireless networks. Links to the CellAlert Canada and CEASA websites are listed below:
http://www.cellalert.com/
http://www.ceasa-int.org/
Currently the CRTC has a call for applications to provide an All Channel Alert (ACA) service (CRTC
Broadcasting Public Notice CRTC 2005-38, April 22, 2005) pending.20
THE ALBERTA EMERGENCY PUBLIC WARNING SYSTEM AND CANALERT
The Alberta Emergency Public Warning System (EPWS) is a system developed by the Alberta Ministry of
Municipal Affairs and the CKUA Radio Network that instantaneously broadcasts warnings of imminent and lifethreatening danger through radio, television, and cable systems when activated by the appropriate emergency
authority. All on-air broadcasters in Alberta now receive an EPWS signal either locally or through a network.
The link to the EPWS webpage is listed below:
http://www.municipalaffairs.gov.ab.ca/ema_epws.htm
Ultimately, a Canada-wide All Channel Alert the goal of CANALERT 21, a national emergency public alerting
protocol initiative currently in development by Industry Canada. CANALERT will allow emergency management
(24 July 2006).
19
“FAQs”, CellAlert Canada website, http://www.cellalert.com/faq.html (24 July 2006).
20
CRTC Broadcasting Public Notice CRTC 2005-38, April 22, 2005 http://www.crtc.gc.ca/archive/ENG/Notices/2005/pb2005-38.htm (24 July
2006).
11
organizations to issue brief public alert messages over media such as radio, TV, cellular telephones, and the
internet across Canada. Any local landline CNS would also be integrated under the CANALERT public alerting
protocols 22.
The need for national standards and protocols is reiterated in comments submitted by the Canadian Cable
Telecommunication Association (CCTA) as part of CRTC Public Notice 2005-7. CCTA points out that “there is
a risk that [CNS as proposed by the applicants] may not concord with Industry Canada’s CANALERT
Initiative…[resulting] in the establishment of duplicative or potentially conflicting information” among different
emergency notification systems 23.
PRIORITY ACCESS DIALING
Unlike public CNS, wireless, or broadcast emergency notification systems, Priority Access Dialing technology
ensures critical personnel get preferential access to landline and wireless networks during emergency
situations. Priority Access Dialing numbers are assigned to the database by the emergency authority. A list of
Canadian Priority Access Dialing initiatives is provided below.
Priority Access Dialing for emergency personnel with Canadian Emergency Telecommunications Service
Emergency Telecommunications Data System (ETDS) has been developed by Industry Canada to ensure
numbers in the ETDS get priority dial tone access when telecommunications systems are overloaded in times
of emergency:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00018e.html
Wireless Priority Service (WPS) is also available through the ETDS to ensure Public Safety and Emergency
Preparedness (PSEP) calls queue the next available wireless service channel for authorized authorities. Once
approval is given by the federal or provincial WPS approval authority and obtained through the ETDS, a
wireless service provider that supports WPS can be approached to obtain this service:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00016e.html
The Emergency Notification System (ENS) is an automated telephone contact callout system established by
the Alberta Ministry of Municipal Affairs Emergency Management Alberta that can automatically dial 1800
numbers an hour for emergency personnel on the ENS database:
http://www.municipalaffairs.gov.ab.ca/ema_ENS.htm
Local authorities should ensure critical emergency contact numbers are ETDS and WPS enabled to receive
priority dialing access during emergency situations.
SUMMARY AND RECOMMENDATIONS
Currently, there are several products available that apply CNS reverse dialing functionality using GIS and IVR
technologies, including ILEC-hosted solutions allowing Canadian municipalities to dispatch emergency
notifications using pre-existing ILEC infrastructure and databases. However, the issue is more of a regulatory
one than a technological one at this time, as Canadian national emergency broadcast and public notification
protocols have not yet been defined, and CRTC regulations do not allow access to ILEC Emergency 9-1-1 data
21
“Industry Canada Emergency Telecommunications – Public Alerting in Canada”, July 6, 2006, Accessed from Industry Canada website
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00019e.html (24 July 2006).
22
“Response to Interrogatory Strathcona on behalf of the Applicants, CRTC, September 9, 2005” as quoted in argument presented by Canadian
Cable Telecommunications Association (CCTA) submission to the CRTC dated December 14, 2005
http://www.crtc.gc.ca/public/partvii/2005/8665/ccta/051214.pdf (24 July 2006).
23
Comments presented by Canadian Cable Telecommunications Association (CCTA) submission to the CRTC dated July 29, 2005
http://www.crtc.gc.ca/public/partvii/2005/8665/ccta/050729.pdf (24 July 2006).
12
that is essential for an effective CNS. Similarly, no national protocols or standards are defined for wireless or
IP-based technologies.
Overall, Alberta is slightly ahead of the national curve in terms of emergency notification system
implementation, although Canada-wide implementation of CNS and other notification systems at the municipal
level will likely become commonplace over the next 1-2 years once national standards, protocols, and
regulations are altered, defined, codified, and established.
Therefore, before implementing any public emergency notification system or program the City should:

Await and monitor the outcome of CRTC Public Notice hearing 2005-7 RE: ILEC Emergency 9-1-1
database access for landline CNS operation before taking action. The CRTC decision and
telecommunications order, due in the next 6-12 months, will likely allow Emergency 9-1-1 database
access for a CNS, and provide Terms of Service and appropriate tariffs/rates for ILECs.

Understand an ILEC-hosted CNS solution would be likely much more cost-effective to implement and
maintain than a City-managed one.

Implement an alternate solution (either hosted or in-house) using a combination of ILEC white pages
data and volunteered data only if the decision resulting from CRTC 2005-7 does not allow Emergency
9-1-1 database access for CNS

Understand the weaknesses/drawbacks in terms of coverage, currency, etc. of an emergency
notification system based on white pages and/or volunteer information

Be aware that telephony-based CNS solutions only apply to Public Switched Telephone Network
(PSTN) landlines and not to wireless network, Voiceover Internet Protocol (VoIP) telephony, and other
IP network-based technologies

Understand that broadcast notification to wireless cellular and other IP-based network subscribers is
much more efficient and effective than CNS

Be aware that Cell Broadcast notification is a much more effective method of notifying wireless cellular
and other IP-based network subscribers than Short Messaging Services (SMS) text messaging, which
is time-consuming, raises privacy concerns, and imposes a significant load on the cellular network.

Await and monitor the outcome of CRTC Public Notice 2005-38 to see what technologies emerge for a
wireless and IP-based network All Channel Alert (ACA) broadcast service

Assess if/what type of integrated functionality an ILEC-hosted landline CNS solution offers for wireless
technologies

Be aware that all personal information held in City databases are subject to FOIPPA legislation, and
therefore cannot be used or disclosed for any purpose other than what it was originally collected

Be aware that BC Emergency Program Act Section 26 of the Emergency Program Act does provide for
overrides to other provincial Acts, including FOIPPA, once a local state of emergency has been
declared

Consider that the pre-requisite declaration of an official state of local emergency assumes the
Emergency Program Act’s overrides to FOIPPA would only be relevant post-event and not for preevent emergency notification warnings

Understand that any technological emergency notification solution (either hosted or in-house)
accessing City data would be subject to FOIPPA’s Canadian storage and access provisions

Be aware that, if the City decides in favour of an in-house emergency notification solution as the best
approach, or embarks on a program of volunteer information collection for the purpose of emergency
notification, there could be significant administrative, technological, financial, and legal impacts
13

Understand and be aware of other emergency agency jurisdictions (such as Environment Canada for
severe weather warnings) before emergency notification is made as part of any local emergency plan

Monitor progress on the Industry Canada CANALERT initiative, which will allow emergency
management organizations across Canada to issue brief public alert messages over radio, TV, cellular
telephones, and the Internet

Consider that CNS or other emergency notification systems will likely fall under CANALERT’s purview
and that pre-existing emergency protocols will likely have to conform to CANALERT standards once
established

Embark on an aggressive marketing and citizen awareness campaign in conjunction with implementing
any local emergency notification system

Assign critical emergency personnel contact numbers to the Emergency Telecommunications Data
System (ETDS) and Wireless Priority System (WPS) to ensure landline telephone and wireless priority
access dialing during emergency situations

Read and understand CRTC Part VII Application Attachment 3, which outlines proposed guidelines for
Emergency 9-1-1 database CNS operation by emergency authorities

Implement Emergency 9-1-1 database CNS operation protocols and procedures with local emergency
plans if and when these become federal standards
14
ANNOTATED SOURCE LISTING
EMERGENCY NOTIFICATION SYSTEMS – CURRENT INITIATIVES (FEDERAL)
A national public alerting initiative was launched by Industry Canada in 2002 in response to Senate Committee
on National Security and Defense recommendations.
The Senate Committee’s final report, entitled “National Emergencies: Canada’s Fragile Front Lines – An
Upgrade Strategy”, was issued in March 2004. It is accessible from the link below:
http://www.parl.gc.ca/37/3/parlbus/commbus/senate/com-e/defe-e/rep-e/rep03mar04vol1-e.pdf
INDUSTRY CANADA

The Industry Canada Emergency Telecommunications Branch has the lead role for emergency
telecommunications in Canada. The branch homepage can be accessed at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/Home
INDUSTRY CANADA – PUBLIC ALERTING SYSTEM INITIATIVES

The Industry Canada page “Industry Canada Emergency Telecommunications – Public Alerting in
Canada” offers an historical overview of various public alerting initiatives, projects, protocols, forums,
and workshops. It is accessible at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00019e.html

Updates on various Canadian emergency notification projects are available from the “Industry
Canada Emergency Telecommunications – Update of Public Alerting Demonstration and
Evaluation Projects” section of the Industry Canada website, accessible from the link below:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00052e.html

The summary report for the Geographic Public Alerting System project developed by the New
Brunswick Department of Public Safety, Aliant Incorporated, Caris Limited, and Xwave Software
for Industry Canada is accessible at:
http://strategis.ic.gc.ca/epic/internet/inettdu.nsf/vwapj/SummaryReportMay14.pdf/$FILE/SummaryReportMay14.pdf

The summary report done by the City of Sarnia, Ontario for Industry Canada, comparing
Emergency Notification System device effectiveness using outdoor sirens, interruption of local
radio and TV broadcasts, and telephony call-outs using a Public Alerting System developed by Bell
Canada, is at:
http://strategis.ic.gc.ca/epic/internet/inettdu.nsf/vwapj/SummarySarniaEmergencyPublicNotificationStudy1.pdf/$FILE/SummarySarniaEmergencyPublic
NotificationStudy1.pdf

The Industry Canada page “Industry Canada Emergency Telecommunications - Proposed
Authorized Users Guidelines for 9-1-1 Database Integrated Community Notification Systems
(CNS)”, provides an overview and background of proposed Integrated Emergency 9-1-1 CNS systems
in Canada. It is available at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00057e.html
15
This page also contains links to the CRTC Part VII Application to Access Emergency 9-1-1
databases for CNS purposes.

Attachment 3 of the CRTC Part VII application, entitled “Proposed Community Notification
Service Guidelines” outlines system activation protocols, emergency message contents, examples of
when CNS would be activated, and public complaint and document review procedures, and is
accessible at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/vwapj/Attachment_3_911_Guidelines.pdf/$FILE/Attachment_3_-911_Guidelines.pdf

Links to external websites listing public alerting initiatives in Canada and other countries, as
well as public alert solution providers and vendors, have been collected at the following Industry
Canada “Links” page:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00088e.html

In addition, other external reference documents concerning 9-1-1; Disaster Communications,
Legal Agreements, Documents, and Conventions affecting Emergency Telecommunications;
Priority Access; Public Alerting; and Telecommunications Critical Infrastructure Protection can
be referenced from the “Reference Documents” page at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00011e.html
INDUSTRY CANADA - PRIORITY ACCESS DIALING

Priority Access Dialing for emergency personnel with Canadian Emergency
Telecommunications Service Emergency Telecommunications Data System (ETDS), developed
by Industry Canada to ensure numbers in the ETDS get priority dial tone access when
telecommunications systems are overloaded in times of emergency:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00018e.html

The Canadian Emergency Telecommunications Service ETDS User Guide is accessible at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/print-en/wj00035e.html
INDUSTRY CANADA - WIRELESS PRIORITY SERVICE

Wireless Priority Service (WPS) is also available through the ETDS to ensure Public Safety and
Emergency Preparedness (PSEP) calls queue authorized emergency personnel for the next available
wireless service channel. Once approval is given by the federal or provincial WPS approval authority
and obtained through the ETDS, a wireless service provider that supports WPS can be approached to
obtain this service. The Industry Canada WPS page is accessible at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/h_wj00016e.html
INDUSTRY CANADA – EMERGENCY BROADCAST PROTOCOLS

CANALERT is a national standard emergency alerting protocol initiative currently in development. Led
by Industry Canada, CANALERT will allow emergency management organizations to issue brief public
alert messages over media such as radio, TV, cellular telephones, and the Internet across Canada.
More information on the CANALERT initiative can be accessed at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00096e.html
16
EMERGENCY NOTIFICATION SYSTEMS – CURRENT INITIATIVES (PROVINCIAL)
ALBERTA
PRIORITY ACCESS DIALING

Emergency Notification System (ENS), an automated telephone contact callout system established
by the Emergency Management Alberta (Alberta Ministry of Municipal Affairs Public Safety Division)
that can automatically dial 1800 numbers an hour for emergency personnel:
http://www.municipalaffairs.gov.ab.ca/ema_ENS.htm
BROADCAST SYSTEMS

Alberta Emergency Public Warning System (EPWS) is a system developed by Emergency
Management Alberta (Alberta Ministry of Municipal Affairs Public Safety Division), and the CKUA Radio
Network that instantaneously broadcasts warnings of imminent and life-threatening danger through
radio, television, and cable systems when activated by the appropriate authorized authority. All on-air
broadcasters in Alberta can now receive an EPWS signal either locally or through a network.
EPWS goals, activations, geographic coverage regions, and the authorized user handbook are accessible from
the EPWS homepage at:
http://www.municipalaffairs.gov.ab.ca/ema_epws.htm
EMERGENCY NOTIFICATION SYSTEMS – CURRENT INITIATIVES (MUNICIPAL AND REGIONAL)
COMMUNITY NOTIFICATION SYSTEMS

The County of Essex, Ontario Emergency Management Department offers a “Reverse 911
County emergency notification system” whereby voluntary subscribers are contacted via telephone
during emergency situations. Program information and the registration form are accessible at:
http://www.townoflakeshore.on.ca/emer.htm

The Northeast Region Community Awareness and Emergency Response (NR CAER) provides a
telephone-based CNS call-out service to volunteer subscribers in the communities of Fort
Saskatchewan Lamont, Sturgeon, and Strathcona, Alberta. The NR CAER also provides a 24-hour
call update line whereby NR CAER-member companies and authorities in the region can report
unusual situations which the public can access for information/updates via a toll-free number. More
information on NR CAER is accessible at:
http://www.nrcaer.com/pages/ul_faq.htm

The NR CAER volunteer registration form is available at:
http://www.nrcaer.com/pages/contactinfo.htm
17
EMERGENCY NOTIFICATION SYSTEMS – CURRENT INITIATIVES (OTHER)
WIRELESS BROADCAST SYSTEMS

CellAlert Canada is a for-profit organization formed by the international non-profit organization
Cellular Emergency Advisory Service Organization (CEASA) to implement technology to provide a
Cell Broadcast system over wireless networks. Links to the CellAlert and CEASA site home pages are
accessible from the links below:
http://www.cellalert.com/
http://www.ceasa-int.org/
CANADIAN TELECOMMUNICATIONS POLICY – CURRENT INITIATIVES
CANADIAN RADIO-TELEVISION AND TELECOMMUNICATIONS COMMISSION (CRTC)

Telecom Public Notice CRTC 2005-7 is the CRTC proceeding where the decision on whether
municipalities can access ILEC Emergency 9-1-1 databases for Community Notification Service is
currently pending.
An overview of Public Notice 2005-7 is accessible at:
http://www.crtc.gc.ca/archive/ENG/Notices/2005/pt2005-7.htm
The full correspondence of Public Notice 2005-7, including links to relevant documentation by the
Applicants and Respondents, is accessible at:
http://www.crtc.gc.ca/PartVII/eng/2005/8665/c12_200507212.htm

The full correspondence of CRTC Part VII application (File #: 8665-S62-20045888) whereby the
municipal and regional “Applicants” requested access to ILEC Emergency 9-1-1 databases for
Community Notification Service, including links to relevant documentation by the Applicants and
Respondents, is accessible at:
http://www.crtc.gc.ca/PartVII/eng/2004/8665/s62_200405888.htm:

Broadcasting Public Notice CRTC 2005-38 is a call for applications to provide an All Channel
Alert (ACA) Service to broadcast local warnings of imminent threats to life or property on behalf of
authorized government agencies. The decision is still pending.
An overview of Public Notice CRTC 2005-38 is accessible at:
http://www.crtc.gc.ca/archive/ENG/Notices/2005/pb2005-38.htm
RELEVANT ACTS AND LEGISLATION (FEDERAL)

Telecommunications Act legislation states that all Canadian telecommunications companies must
comply with regulations defined by the Canadian Radio-Television and Telecommunications
Commission in order to provide service in Canada.
The Telecommunications Act is accessible from the Department of Justice Canada website at:
http://laws.justice.gc.ca/en/T-3.4/index.html
18

Canadian telecommunication companies must protect all personal information under their control
according to Personal Information Protection and Electronic Documents Act (PIPEDA) legislation,
except under limited circumstances outlined by the CRTC as authorized by the Telecommunications
Act.
The Personal Information Protection and Electronic Documents Act is accessible from the Department
of Justice Canada website at:
http://laws.justice.gc.ca/en/P-8.6/index.html
RELEVANT ACTS AND LEGISLATION (PROVINCIAL)

The Freedom of Information and Protection of Privacy Act (FOIPPA) dictates conditions by which
personal information can be collected, stored, and disclosed by BC public bodies.
FOIPPA is accessible from the BC Queen’s Printer at:
http://www.qp.gov.bc.ca/statreg/stat/F/96165_01.htm
Information and resources for BC public and government bodies using FOIPPA is available from the Office
of the Information and Privacy Commissioner for British Columbia (OIPC BC) website at:
http://www.oipcbc.org/sector_public/resources/index.htm

The Emergency Program Act outlines protocols and requirements for a local authority declaring a
state of emergency and implementing an emergency plan, and the temporary powers given to the local
authority once a state of emergency is declared. Of note is how the Emergency Program Act takes
precedence over all other acts, including FOIPPA, during a state of emergency.
The Emergency Program Act is accessible from the BC Queen’s Printer at:
http://www.qp.gov.bc.ca/statreg/stat/E/96111_01.htm
A guide to the Emergency Program Act is available from the Justice Institute of British Columbia
website at:
http://www.pep.bc.ca/management/Guide_to_New_Emergency_Program_Act_2005.pdf
PUBLIC SAFETY AND EMERGENCY PREPAREDNESS AGENCIES
FEDERAL

Public Safety and Emergency Preparedness Canada (PSEPC) is the Canadian federal agency with
the mandate to “support and coordinate public safety activities at all government levels, from federal to
municipal”. PSEPC provides emergency management training, funds safety initiatives, and provides
disaster assistance funds. PSEPC works to overcome jurisdictional barriers to effectively manage
response efforts.
The government section of the PSEPC website is accessible from:
http://www.psepc.gc.ca/chan/gov/index-en.asp

Environment Canada is responsible for monitoring environmental conditions and issuing severe
weather and other environmental warnings to threatened areas.
19
The Environmental Emergencies Program page of the Environment Canada site is accessible at:
http://www.ec.gc.ca/ee-ue/default.asp?lang=En&n=77BD210F-1
PROVINCIAL

The Ministry of Public Safety and Solicitor General is the British Columbia provincial government
agency responsible for emergency preparedness and management programs.
The Ministry’s Provincial Emergency Program (PEP) homepage is accessible at:
http://www.pep.bc.ca/index.html
Links to Community Emergency Planning, Response, and Recovery documentation are accessible
from the PEP site at:
http://www.pep.bc.ca/Community/community.html
EMERGENCY NOTIFICATION PRODUCTS AND SERVICES
As stated previously, there are several vendors offering emergency products and services using CNS reverse
dialing based on GIS, subscriber database, and IVR technologies. However, implementing an ILEC-hosted
solution appears to be the most effective means of operating an emergency notification service in Canada due
to the costs of maintaining contact database currency and reliability.
Hosted solutions are now being offered by Canadian telecommunications companies, and it is not
unreasonable to assume an integrated CNS solution accessing ILEC Emergency 9-1-1 databases will be
available once CRTC approval is given. It may be possible for the City to use a third-party CNS vendor to
access and extract ILEC emergency, white pages, and/or other database information, but this will depend upon
the regulatory framework laid out by the CRTC’s decision. A select list of vendor sources is provided below.

TELUS GEOMATICS - GEOEXPLORER
Telus Geomatics currently offers a hosted Emergency Management System product (GeoExplorer) based
on white pages and volunteer subscriber information. This would be altered to access their Emergency 91-1 database should CRTC approval be given. As the regional ILEC, any third-party CNS solution
implemented by the City would be access/extract Telus’ subscriber data.
More information on GeoExplorer is accessible at:
http://www.telusgeomatics.com/tgmain/geoexplorer/geoexp_911Response.htm

BELL CANADA – VOICE SELECT EMERGENCY RESPONSE MANAGEMENT SOLUTION (ERMS)
Voice Select ERMS is a hosted Emergency Management System product offered by Bell Canada, offering
automated call-out and messaging options via telephone, fax, text-to-voice communications, and e-mail to
recipients in a defined geographic area. It also offers tracking and report functions. It is similar to the Telus
GeoExplorer product.
Voice Select ERMS documentation is accessible from the Bell Canada website at:
http://enterprise.bell.ca/en/resources/uploads/PDF/ERMS_whitePaper_En.pdf
20

SIGMA COMMUNICATIONS – REVERSE 911 INTERACTIVE COMMUNITY NOTIFICATION
SOLUTION
Reverse 911 is the trademark name for a CNS solution offered by Microsoft partner Sigma
Communications. It is widely used in the United States. Reverse 911 uses a combination of GIS mapping
and database technologies to deliver outbound emergency notification messages to residents in a defined
emergency area, and has reporting functionalities. It is a third-party rather than an ILEC-hosted solution
and requires importing of ILEC data or building an in-house contact database to function.
More information on Reverse 911 is available from the Sigma Communications website at:
http://www.reverse911.com/products/faqs.php

DIALOGIC COMMUNICATIONS CORPORATION – THE COMMUNICATOR!
The Communicator! is a CNS solution offered by Microsoft partner Dialogic Communications Corporation
(DCC) in a hosted or on-site configuration. Like Reverse 911, The Communicator! uses a combination of
GIS and database technologies to deliver outbound messages in a defined emergency area, has reporting
functionalities, and is a third-party solution requiring access ILEC data or building an in-house database to
function. There may be FOIPPA issues regarding access, storage and transfer of data if the hosted
solution resides outside of Canada.
More information on The Communicator! and affiliated products and services are available from the
DCC website at:
http://www.dccusa.com/products.asp

GENUTEC BUSINESS SOLUTIONS INC. – AMERICAN EMERGENCY NOTIFICATION
American Emergency Notification is an integrated, fully-hosted emergency management and
notification system. It uses a combination of GIS mapping and database technologies to notify
emergency personnel and the public, and provides reporting functionalities. There may be FOIPPA
issues regarding access, storage, and transfer of data if the hosted solution resides outside of Canada.
More information on the American Emergency Notification system is available from the GenuTec
Inc. website at:
http://www.aenusa.com/aen.php?page=ps

EMERGEO SOLUTIONS INC. – EMERGEO and WebEOC
EmerGeo is a GIS mapping application developed by Vancouver-based EmerGeo Solutions Inc. It
allows users to directly access data stored in multiple mapping and emergency management systems
used by multiple agencies in order to draw/plot incidents, evacuation areas, resources, hazards, critical
infrastructure, and other information. It operates with or without a network connection, and has an
easy-to-use interface that does not require a GIS technician. EmerGeo is currently being used by the
City of Vancouver Emergency Operation Centre and the BC Office of the Fire Commissioner.
WebEOC is a web-based emergency management communications system that delivers/exchanges
real-time information to any size emergency operations centre or between emergency operations
centres and field personnel.
EmerGeo and WebEOC do not have CNS functionality but can be combined with other data sources
and applications to operate an integrated emergency notification system.
More information on EmerGeo and WebEOC is available at the EmerGeo Solutions Inc. website at:
http://www.emergeo.com/products.aspx
21

A collection of links to solution provider websites is accessible from the “Industry Canada
Emergency Telecommunications – Public Alerting – Links” page at:
http://strategis.ic.gc.ca/epic/internet/inet-tdu.nsf/en/wj00088e.html#providers
22
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