MARTIN OUTLINES STATE ROLE IN E-911 ROLLOUTS

Among overarching 911 concerns flagged by conference participants were technical proposals for mitigating unintentional or harassing emergency calls, access for hearing disabled callers and challenge of identifying location of callers using PBX systems in large office buildings. Some public safety officials at one-day “critical issues forum” also stressed need for clarification of 1999 law on 911 on what kinds of subscriber information could be made available quickly from wireless carriers to public safety answering points (PSAPs) trying to track dropped 911 call.

In nod to last week’s Triennial UNE Review decision, Martin said, “As some of you may know, I recently advocated preserving the states’ role in local telecommunications regulations.” He said significant state role brought “significant responsibility” involving E-911 obligations, including working cooperatively when issues crossed state lines. He also stressed state role in LEC E-911 involvement. Typically, LECs charge PSAPs through state tariffs for inputs needed to link 911 call centers and wireless carriers. “The states need to police these tariffs carefully,” Martin said. “They must ensure these charges are fair and not prohibitively expensive.” He said some states had spent money collected for E-911 on other budget items instead. “We must do better. Public safety is critical and one of our most important priorities,” he said. “We must ensure that public safety officials have the resources they need to do their jobs and protect the public.”

Wireless Bureau recently released report that found wireless carriers and handset makers were taking steps to alleviate problem of unintentional calls made from wireless handsets, issue cited several times in conference. In Dec., bureau issued consumer alert that encouraged callers with auto-dial 911 feature to disable it and urged them to not program phones to speed-dial 911. Expressing optimism that carrier and consumer education efforts would be effective, Martin said if they weren’t, “I believe the Commission will be willing to pursue further action if necessary.” He sasid further notice adopted by FCC in Dec. examined whether E-911 rules should be extended to services not covered, such as PBX systems. “A phone in a large company’s PBX system might be anywhere in the country, and the PSAP will have no way of knowing where the phone is,” he said. In some cases, emergency responders have reported to wrong place because they didn’t receive adequate information from PBX. “This is a serious problem and we all need to work together to solve it as soon as possible,” he said.

Martin said he was hopeful FCC would be able to act “soon” on proposal by Emergency Services Interconnection Forum (ESIF) on non-initialized phones. ESIF proposal involves 911-only wireless handsets and donated handsets that aren’t service initialized. Bureau last year delayed date for programming such phones with ID number 123-456-7890 after ESIF outlined technology solution that involved mobile identification number. Problem with such phones now is that they don’t have callback capability when 911 calls are dialed. Proposal involves use of handsets’ electronic serial number for identification purposes. ESIF plan “would thus help prevent the misuse of the 911 system by identifying the source of harassing calls and make clear when a legitimate emergency caller is making multiple calls,” Martin said. “I think ESIF’s proposal makes a lot of sense.” In general, he said there had been “turnaround” in progress made by carriers, public safety community and FCC on E-911 deployment.

In panel discussion, Sam Feder, Martin’s wireless legal adviser, said E-911 report issued last year by former FCC Office of Engineering & Technology Chief Dale Hatfield had cited uncertainty on LEC obligations. In one of orders responding to Richardson, Tex., request for clarification, FCC said PSAP requests for E911 service were valid if any upgrades needed on PSAP network would be completed within 6 months and if PSAP had made timely request to LEC for trunking and other facilities needed for E-911 data to be transmitted. Requirements don’t explicitly spell out what occurs if LEC hasn’t provided input, Feder said. “So I think we are going to have to provide some additional clarification at some point. I'm not sure exactly what form it will take,’ he said. FCC’s Richardson rules cover what constitutes wireless carrier readiness and what makes up PSAP readiness for Phase 2.

Further notice on scope of E-911 rules was seen as necessary by both Wireless Bureau and 8th floor offices as proceeding to take step back and do more strategic planning in that area, said James Schlichting, deputy bureau chief. Question about applicability of those rules came up last year in context of where disposable phones fit with E-911 rules, he said. Wireline PBX issue also involves use of voice-over- IP technology as part of internal networks, he said. Such issues, along with potential applicability of E-911 to mobile satellite service (MSS) phones, created “critical mass of issues that were worth putting on the table,” Schlichting said. “It’s an important proceeding but it’s not a proceeding that we're taking on at the cost of slowing down Phase 2,” he said in response to question.

While wireless carriers have largely implemented TTY technology to enable hearing disabled callers to dial 911 over digital networks, “consumers still cannot with any assurance complete a call to a 911 PSAP because of the problems we have discovered with terminal equipment at the PSAP,” said Edward Hall, vp-technology at Alliance for Telecom Industry Solutions. TTY Forum has approached Dept. of Justice on funding for TTY devices at PSAP, but found that DoJ wasn’t prepared to take next step because it wasn’t familiar with issue, he said. “We need to somehow find some funding somewhere to make readiness possible at the PSAP to receive TTY calls over digital networks,” Hall said in Q&A. “This is an area, from your description, that we need to get back in,” Schlichting said. “If there’s something that the Commission can do to try to expedite movement on this particular issue, I think that would be very important,” he said, and FCC would be interested in feedback in that area. - - Mary Greczyn