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The FCC should “discount” recommendations by the Alliance for Telecom...

The FCC should “discount” recommendations by the Alliance for Telecom Industry Solutions Incubator that the only feasible solution in the short term for sending texts to 911 should be based on Internet Protocol text relay technology, the National Emergency Number…

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Association said in a comment filing. ATIS started its investigation in April 2011 using June 2012 “as the target deployment date,” NENA said (http://xrl.us/bmr3i7). “By arbitrarily limiting its consideration of possible solutions to those which could be deployed nation-wide in just over one year (including the 9 months required to generate its report), the Incubator effectively precluded consideration of many potential solutions that might have been implementable upon longer, but still reasonable timeframes.” IP text relay “has enormous shortcomings, however, that arguably exceed even those of some SMS-based solutions,” NENA said. It said said some companies, including Intrado and Neustar, have demonstrated or proposed SMS-to-911 solutions “that allow for location-based routing and varying degrees of handset- or network-based location reporting -- both critical elements of 911 service that IP text relay has not yet been shown to support.”