Subscriber Testing of Emergency Texts Could Cause Problems for PSAPs, APCO and NENA Agree
Allowing subscriber testing of whether an emergency text message to 911 results in the required bounce-back message saying the service isn’t available could cause big problems for 911 call centers, the Association of Public-Safety Communications Officials told the FCC. The National Emergency Number Association made similar arguments. In December, the FCC approved a further notice of proposed rulemaking posing questions on how the commission can best ensure all wireless subscribers will one day be able to send emergency text messages to public safety answering points (CD Dec 13 p12). Replies were due Friday.
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"Subscriber testing would run counter to long standing public education that 911 should only be used when there is a genuine emergency,” APCO said (http://bit.ly/Wze0jC). “The number of ’test’ texts could also easily outnumber the potential number of actual emergency texts, especially since the average subscriber is unlikely to ever be in a situation where a text to 911 is a better alternative than a voice call.” This could “disrupt PSAP operations,” APCO said. “Various technical components of text-to-911 do need to be tested, of course, but such testing should be in a controlled ‘closed-loop’ to prevent disruption to PSAPs and other elements of the 911 infrastructure."
"Despite some record support for testing capabilities, NENA and others remain unconvinced that a consumer testing function can be implemented effectively and securely without either providing a false sense of security to the consumer or risking an avalanche of non-emergency texts reaching text-enabled PSAPs,” NENA said (http://bit.ly/W4nNfX).
APCO also said “non-service initialized handsets,” phones that no longer work on a carrier network, shouldn’t be subject to the bounce-back requirement. APCO and NENA have complained in the past that voice 911 calls from old cellphones, which carriers are required to transmit, pose a problem for PSAPs and can’t be traced to the source (CD March 5/08 p5). NENA said some questions remain about imposing bounce-back mandate on companies that offer interconnected text messaging services. NENA “cautions that the lack of any participation in this docket by such providers may indicate a need for further consideration of the unique technical considerations (and resulting timeframes) applicable to such applications,” the group said.
The Rehabilitation Engineering Research Center for Wireless Technologies agreed with arguments in the initial comment round that the FCC should impose a requirement on all carriers that they be able to transmit bounce-back messages. In December, Verizon Wireless, AT&T, Sprint and T-Mobile voluntarily agreed to implement systems for transmitting bounce-back messages by June 30 (CD Dec 10 p1). The FCC is deciding whether to make the agreement a mandate. “The consumer group that stands to benefit the most is people with disabilities; particularly, people with hearing loss and speech disabilities,” the center said (http://bit.ly/11v2bPH). “People with speech disabilities are a large and diverse group which includes individuals with Autism, traumatic brain injury, stroke, physical trauma to the vocal chords, cleft lip or palate, and others with difficulties vocalizing (e.g., stuttering). Of course, other situations may require ’silent calls’ by the hearing population, as well."