NENA, APCO Urge Caution on Development of Text-to-911 Rules
The National Emergency Number Association and the Association of Public-Safety Communications Officials agreed with wireless carriers that the FCC must move with care as it moves toward a solution that will allow consumers to send text messages to 911 call centers. FCC Chairman Julius Genachowski has repeatedly stressed that he sees texting to 911 as an important component of a next-generation 911 network (CD Aug 11 p1). The issue is of special significance to deaf people who otherwise have difficulty making 911 calls. Comments were due this week on a notice of proposed rulemaking approved by the FCC at its September meeting (CD Sept 23 p6).
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The need for a text-to-911 solution is “concrete and immediate,” but quick deployment “standing alone ... cannot ensure acceptable outcomes for the safety of the public,” NENA said in a filing at the commission (http://xrl.us/bmkyxs). Any short-term solution “will likely need to continue in use for nearly ten years,” NENA warned. “Consequently, it is important that the Commission strike a careful balance between the need to deploy some text solution quickly, the need to deploy solutions that are sufficiently robust and full-featured to adequately meet the needs of the public and the public safety community over the next decade, and the need to conserve precious and increasingly scarce public resources.”
NENA said as a next step the FCC should issue a further notice of proposed rulemaking in the first half of next year, based on comments collected so far and a new report by the FCC’s Emergency Access Advisory Committee. “Each of the three options most frequently discussed -- direct SMS, application-based text, and IP-relay -- has different characteristics that, depending on how each is implemented, will have profound impacts on [call center] operations,” NENA noted. “For example, IP-relay text could require little retraining for telecommunicators already accustomed to handling other types of relay calls ... but would likely result in significant increases to call length and round-trip lag time. Direct SMS and application-based text, by contrast might require significant additional training covering everything from basic familiarity with new software packages to esoteric (to some) text abbreviations and jargon, but could yield lower average session lengths and round-trip lag time.”
APCO called on the FCC to appoint an NG911 Technical Advisory group and said solutions like SMS could help in the short term (http://xrl.us/bmky25). “SMS may be appropriate as a near-term solution for limited circumstances, it is not a long-term solution for the general public,” APCO said. “Therefore, the telecommunications industry, public safety, and the FCC should focus the bulk of their resources and regulatory attention on longer-term text-to-911 solutions involving standardized Session Initiation Protocol-based messaging and Real Time Text.” APCO said even after rules are put in place an advisory group “will be necessary to ensure that the Commission’s rules take into consideration state-of-the art technology."
The record shows that SMS won’t work even as a short term solution, said the Alliance for Telecommunications Industry Solutions (http://xrl.us/bmky32). Instead, ATIS urged the development of an Emergency Services Routing Proxy (ESRP) solution through either national or regional entities. “While an ESRP would require policy and funding changes, this solution would make NG911 more ubiquitous, ensure interoperability, minimize costs and accelerate deployment,” the group said. “ATIS does not believe that the Commission should establish a mandatory timetable for NG911 standardization or deployment of originating networks. Nor does ATIS believe that there is a need for the Commission to develop best practices or to align the standards efforts for deploying NG911. Instead, industry efforts regarding these matters should continue."
Wireless carriers counseled against adoption of an interim solution in filings made in response to the NPRM. The FCC “must not get ahead of the work of standards setting bodies,” AT&T said (http://xrl.us/bmkzkv). AT&T cited the problems encountered in Sweden, which tested a text-to-911 solution for four years before it went online last year. “Even then, when this text-to-911 solution was finally inaugurated, the program was subject to serious limitations and deficiencies,” AT&T said. Among them is that all users must register and usage is limited to the deaf and persons with hearing or speech impediments; the system does not test devices to determine if they work for texting; and under some conditions, devices have problems receiving return text messages. Registered users have at times also placed “unnecessary loads on the system by sending text messages just to test it,” AT&T said. “AT&T recommends that the Commission proceed cautiously in this area and seek to work cooperatively with all parties connected with making NG911 possible."
A “voluntary” interim solution “will most expeditiously bring about text-to-911 communications capabilities for individuals with disabilities” while not “imposing costly new regulatory burdens,” Verizon and Verizon Wireless said (http://xrl.us/bmkzkz).