FCC, NRIC Separately Review Satellite’s Roles in Emergencies

The International Bureau and Enforcement Bureau, now updating the FCC’s review of the Emergency Alert System (EB Docket No. 04-296), are reviewing filed comments and meeting with industry for more details, an FCC official said. In its 2004 NPRM, the Commission sought comment on whether it should extend EAS obligations to digital broadcast media, including DBS and other satellite services. Specifically, the FCC asked what burdens would come with extending EAS obligations, and whether the benefits would outweigh them. FCC officials met July 7 with DirecTV, EchoStar, Dominion Video Satellite, SES Americom, PanAmSat and Intelsat to discuss the technical feasibility of EAS participation by satellite DBS and other DTH providers. EAS meetings later in the month with XM and Sirius included Media Bureau officials.

According to an Enforcement Bureau (EB) memo, the FCC raised technical issues regarding DBS -- ranging from how to feed an EAS signal to a DBS operator to how DBS operators would conduct EAS testing on the national and local levels. “For example,” said the memo: “If an EAS alert needed to be sent to an area on the border of a designated market area (DMA), where a DBS provider only provided local-into-local service in one DMA, satellite customers in the unserved DMA would not receive the signal.” And if software updates were needed in set-top boxes, asked the EB, how much time would be needed for implementation and how would operators transition legacy boxes already deployed? The EB’s memo also summarized the participant’s explanations.

According to the memo, DirecTV said it would take years and cost a lot for a DBS operator to be able to insert any EAS-type audio feed. Further, DirecTV said, it would be hard to reroute incoming signals and replace them with a single signal such as a national EAS alert. DBS is purely a “pass-through” system, DirecTV said, meaning DBS providers merely pass through programming they receive on the digital stream. EchoStar said it has up to 2,000 programming streams coming into its earth stations for relay to satellites and customers. Further, EchoStar said, its structure is organized by DMAs, and while there is only one primary entry point in each DMA, every signal is downlinked to the entire DMA. EchoStar said there are no alternative points from which to generate and at which to insert a separate stream in a non-affected area. Dominion Video Satellite, a DBS licensee in Fla. that runs family-friendly satellite TV service Sky Angel, said satellite customers need to learn what alternative alerting means. There’s no way to interrupt national feeds, Dominion said.

In separate but related news for the satellite industry, the Network Reliability & Interoperability Council’s (NRIC’s) Focus Group 1B is taking a stab at long-term E-911 requirements. NRIC, an industry group that advises the FCC on various issues, recently drafted a preliminary report on the properties E-911 architecture should embody by 2010. The report largely addresses whether E-911 requirements can be extended to satellite telephony. “Emerging mobile, satellite, VoIP and other IP enabled communications services do not fit into public policy requirements that set out 9-1-1 governance, funding and access to the 911 networks for the delivery of callback and location information,” the Focus Group 1B draft said. And, unfortunately, the pace of change of the emergency calling network is slow, the draft said: “It is not uncommon to wait 10+ years from first deployments to having most systems upgraded for new capabilities. Indeed there are some areas of the country that do not have 9-1-1 systems at all.”

But more than emerging technologies are of issue for Public Safety Answering Points nationwide, said the report: “The existing infrastructure has many undesirable and limiting characteristics.” It doesn’t extend beyond the local jurisdictional focus under which it was developed, limiting potential models for handling emergency calls, and limits handling emergency situations on a broad geographic scale. In fact, the E-911 system can be seen “as a barrier to advancing emergency service capabilities and creating a national response capability,” the report said. But it also should be noted that the system functions well in day-to-day handling of emergency calls, said the focus group: “It is important not to give up any of the good characteristics of the current system as it evolves in the future.”

Historically, satellite systems have gotten different treatment from wireline and wireless networks as regards E-911 requirements, the report said. Satellite services were exempted from the E-911 rules for terrestrial wireless due to unique satellite-related technological and economic factors, the report said. Most Mobile Satellite Services (MSS) services operating satellite telephony today went into orbit before the FCC issued E-911 rules, it said. MSS systems that provide conventional switched calling services already are obligated to support 911 through call centers, and those MSS operators have deployed PSAP database call centers for routing 911 traffic. Fixed Satellite Systems (FSS) have no requirement to support E-911, the report said. Further, the report acknowledged, LEO, GEO and MEO satellite systems’ architectures and technologies differ significantly. One unified satellite 911 recommendation can’t be made, it said.

“Ultimately, we believe that all satellite systems that support services that may reasonably be expected to support 9-1-1 calls should be able to support such calls with location and call back information as do other networks,” the NRIC said: “However, that retrofit of existing systems to accommodate such capabilities is not practical. Furthermore, there is a wide range of mechanisms and services that are provided over satellites and a uniform standard for all satellite systems would not be appropriate.” But the report did recommend MSS and FSS operators explore and implement E-911 technologies as they plan their next generation satellite systems.

MSS system operators should be required to prepare detailed feasibility and implementation plans for the FCC, regarding delivering calls to the appropriate PSAP, “where technically feasible and commercially responsible,” the report recommended. And MSS operators should provide automatic number identification by 2010 in existing and/or future systems when they can. As for FSS, the report said operators providing packet services should prepare plans for the FCC detailing how and when they will be able to meet requirements for delivering location to endpoints as any Access Infrastructure Provider does, “where technically feasible and commercially reasonable.” The recommendations should be completed with next generation upgrades, which may extend beyond 2010, the report said. No more requirements should be placed on current FSS systems, it said.

A final NRIC Focus Group 1B report on long term issues for E9-1-1 services, which will include best practices for network evolution, is forthcoming. The NRIC as a whole is to provide an all-inclusive E9-1-1 report to the FCC by Dec. 16. An NRIC Council meeting, which FCC officials said will include a vote, is set for Dec. 6.