Text-to-911 Won’t Be Easy to Implement, Commenters Say

FCC Chairman Julius Genachowski unveiled the agreement between carriers and the public safety group in December (CD Dec 10 p1). Days later, the FCC approved a further notice of proposed rulemaking asking a battery of questions about how the commission can best make sure that all wireless subscribers will one day be able to send emergency text messages to 911 call centers (CD Dec 13 p12).

"We are of the opinion that the Commission should move equally aggressively to have all providers of text messaging services, including the remaining CMRS providers, follow suit, because the primary aim of the bounce-back message is to dispel confusion among end users of text messaging services about whether text-to-911 is available and whether the provider was unable to deliver any particular text-to-911 message due to transmission issues in the provider’s network,” AT&T said (http://xrl.us/bodord). “Any bounce-back message regime will fail unless all interconnected text messaging service providers are required to provide a bounce-back message to texting subscribers."

AT&T counseled the FCC not to impose a customer-generated testing requirement after the June deadline. Tests would require routing the messages to actual public safety answering points or a test site, AT&T noted. “In the case of the former, PSAPs could potentially be swamped with non-emergency texts, putting a strain on their staffing and systems and interfering with receipt of actual emergency texts,” AT&T said. “In the case of the later [sic], a test text to a dummy location would only indicate that the subscriber has a working text messaging service, not that an actual emergency text-to-911 message would be routed to, delivered, or responded to by the appropriate PSAP."

NENA said bounce-back messages are critical. “NENA believes the potential benefits of implementing bounce-back messaging are enormous because doing so would serve to dispel widespread consumer confusion about the availability of text-to-911 now, while setting the stage for effective text-to-911 service in the future,” the group said (http://xrl.us/bodorw). “Additionally, the relative additional cost of implementing bounce-back messaging now as compared with sometime in the future will be small, limited to the time value of capital expenditures required to implement bounce-back messaging over the period between the effective date of a potential mandate and the date on which deployment would have otherwise occurred.” The FCC also needs to make sure it keeps up with changing trends, NENA said. “If current or future originating services do not deploy 911 functionalities based on market forces, the Commission should compel their deployment,” the group said. “We therefore urge the Commission to be mindful of the consumer-driven trend of disaggregation of access networks and originating services as it prepares rules for the transition to and operation of [next generation] 911 systems."

T-Mobile said the FCC shouldn’t “underestimate the challenges” for all carriers to get their systems ready to transmit bounce-back messages. “Though T-Mobile already provides a bounce-back message to its subscribers who attempt to text to 911, smaller carriers may find it challenging to do so, particularly on a short timeframe and without cost recovery from state and local governments,” the carrier said (http://xrl.us/bodpa7). Implementation also isn’t cheap, T-Mobile warned. “As PSAPs begin to accept text messages, implementation will become much more complex and more costly, as carriers will have to determine when and where bounce-back messages should be sent.” T-Mobile also noted that the technology could pose a threat to carrier networks. “In situations where any text-to-911 implementation could permit harm to a carrier’s network -- via, for instance, a denial-of-service attack, ’spoofing,’ or ‘flooding’ -- carriers should be permitted to suspend the service,” the carrier said. “Where enabling text messages to 911 leaves carriers and PSAPs vulnerable to attack, carriers must be allowed to configure their networks specifically to exclude those messages that create security issues."

Smaller carriers represented by the Blooston law firm said compliance should be voluntary. “The Blooston Rural Carriers wish to further point out that, in many rural areas, wireless carriers have not yet received a PSAP request for E-911 Phase I or Phase II voice service, which clearly indicates that the PSAPs in those areas are not capable of processing text-to-911 transmissions,” the group said (http://xrl.us/bodpbo). “Accordingly, carriers serving rural areas where no valid Phase I or Phase II E-911 PSAP service requests have been received should be exempt from any and all requirements to provide text-to-911 service or bounce-back messages.” The costs also are not well understood, the group said: “These costs would be minimal or non-existent if the Commission were to require the four carriers signatory to the Agreement to provide the necessary software to small and rural carriers free of charge, and they request the Commission to adopt such a regulation or to condition these carriers['] wireless service licensees to so require."

CTIA said the FCC needs to carefully consider whether the FCC has legal authority to require carriers to send bounce-back messages to subscribers. “CTIA believes that the Commission can best achieve its important NG911 objectives by continuing to encourage the development of flexible, innovative solutions -- such as the voluntary Carrier-NENA-APCO Agreement -- by different groups representing a broad range of stakeholders,” CTIA said (http://xrl.us/bodpce). The FCC should also recognize the limitations of SMS for sending emergency texts to PSAPs, the group said. “Converting SMS text messaging into a current or next generation emergency communications medium continues to pose significant technical challenges,” it said. “CTIA and many others have emphasized that, among other issues, SMS does not have native functionality for the provision of automatic location information. At most, SMS is a ‘best-efforts’ service that is offered to meet the near term objective of providing a text-based emergency communications system."

Telecommunications for the Deaf and Hard of Hearing and other groups representing the hearing impaired urged the FCC to impose regulations rather than rely on industry cooperation. The voluntary proposal agreed to by the carriers should be “codified into regulations requiring that all service providers, including small and rural carriers do their part in implementing the error messages,” the groups said (http://xrl.us/bodpq4).