911 Location Info in Multi-Line Telephone Systems Feasible, But Commenters Differ on FCC’s Role

The National Emergency Number Association wants the FCC to give telecom providers five years to implement a Multi-Line Telephone System E-911 location capability requirement. The commission shouldn’t rely on states to impose such a requirement, because more than seven years after the commission asked states to do so, only 18 states complied, NENA said (http://xrl.us/bnfrep). Location-capable MLTS devices are already available, and nearly all legacy MLTS can support E-911 location service if properly configured, NENA said. “The benefits of extending E9-1-1 service requirements to MLTS manufacturers and operators are clear, if difficult to precisely quantify."

The Telecommunications Industry Association supports the commission’s inquiry into MLTS location information capabilities, but said a mandate for location accuracy is not appropriate yet (http://xrl.us/bnfre7). There are “significant hurdles limiting the feasibility of expecting that all MLTSs can provide accurate location information” to Public Safety Answer Points, including technical and cost feasibility, the need for further standard development, dependence on MLTS users to implement and update location information capabilities, and privacy concerns. “The Commission must consider these challenges carefully before requiring a blanket location information requirement for MLTS systems,” TIA said. But the NENA Model Legislation, which recommends that the commission take the lead in “encouraging industry to develop needed standards,” and incorporate into Part 68 “requirements for MLTS that will facilitate the implementation of Enhanced 9-1-1 on MLTS,” goes too far; the FCC shouldn’t place E-911 requirements into Part 68 “without heightened enforcement and needed clarification,” TIA said.

AT&T encouraged the development of MLTS standards that are “forward-looking solutions” -- focused on IP-based systems, not traditional circuit-switched or TDM-based communications, which are fast being replaced, the telco said (http://xrl.us/bnfrfh). “If policy makers are seeking to avoid the imposition of unduly burdensome obligations on manufacturers, providers, and operators of MLTS, then focusing on the future of communications -- as opposed to requiring a major re-tooling of existing, moribund technologies -- would make the most sense,” AT&T said. AT&T supports developing state-law model legislation, and the use of industry-developed national standards for manufacturers and providers. The commission should participate in standards setting, but should await the results of a collaborative process “before contemplating formal rulemaking,” AT&T said. “Taking a wait-and-see approach will not preclude future Commission action if it is deemed necessary."

The NENA Model Legislation is a “good starting point” for development of a nationwide approach to MLTS E-911 standardization, and such uniform technical standards are needed to determine technical feasibility, said Verizon and Verizon Wireless (http://xrl.us/bnfrhs). But just as the commission’s Communications Security, Reliability and Interoperability Council concluded last year that “private systems are not easily regulated” when it comes to E911 technical requirements for MLTS systems, the same uncertainties make it difficult to determine when it would be technically feasible for all MLTS systems to have “sufficiently precise” E911 location capabilities for purposes of the NG911 Advancement Act, they said. Adopting nationwide technical standards will promote deployment of MLTS location capability, they said.

The Texas 9-1-1 Alliance, Texas Commission on State Emergency Communications, and the Municipal Emergency Communication Districts Association thinks E-911 MLTS solutions are “feasible,” and well-documented by the public record (http://xrl.us/bnfriv). As evidenced by “incomplete efforts nationwide and the increasing number of states enacting VoIP and IP statutory restrictions, the Commission is now the proper regulatory authority to fully address E9-1-1 MLTS,” the groups said. They endorsed sections two, three and seven of the NENA Model Legislation, which deal with shared residential MLTS service, business MLTS, and industry standards. The commission should promptly address E-911 MLTS in rules or best practices, they said.

But the Voice on the Net Coalition cautioned that MLTS has limitations in providing the precise location of a 911 caller, particularly in wireless environments like Wide-Area Networks, cordless phones, and enterprise Wi-Fi networks supporting devices that run VoIP applications (http://xrl.us/bnfrik). “These limitations make it impractical to apply blanket 911 requirements for all MLTS,” VON said. A pre-programmed location may be incorrect when a nomadic user makes a 911 call, and there could be significant expenses for organizations implementing a wireless or nomadic or VoIP capability on their MLTS, VON said. - Matthew Schwartz