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Beyond SMS

FCC Should Consider Move to NG-911 in Imposing Emergency Text Requirements, Public Safety Groups Say

APCO and the National Emergency Number Association urged the FCC to require that texts to 911 contain information allowing 911 call centers to locate the sender, as soon as practical. But both public safety groups also recognized in filings that short message service (SMS) texts are not the wave of the future and cautioned that the FCC should make allowances for the development of next-generation 911 networks.

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The FCC proposed in an August NPRM (http://bit.ly/1rpJMug) that within two years, all interconnected text services, including SMS, be capable of delivering the “best available” location information to public safety answering points (PSAPs). Carriers, meanwhile, sounded a note of general caution. Comments were posted Monday and Tuesday in docket 11-153.

The FCC’s goal “should be to provide ‘dispatchable’ location information to PSAPs to speed emergency response when the “caller” is unable to provide such information by keystroke,” APCO said (http://bit.ly/10ikMjh). But APCO acknowledged that the move is to LTE and other IP-based protocols. “Adding location capability to legacy SMS texts should not distract the relevant parties from important long-term location-related efforts that will have a more lasting impact on public safety,” APCO said.

APCO said it supports the FCC’s stated goals of moving rapidly to a world where location-information is embedded in emergency texts. But APCO added the caveat “provided that the SMS requirement would not divert significant resources that could be better spent on a more rapid deployment of dispatchable location technology for newer text services that will be widely used by the public long after SMS fades away.”

NENA said the FCC should establish a “general proposition” that all 911 enabled services -- voice, video or text -- must be able to transmit location information to PSAPs by “some relatively near-term date certain.” But NENA said the FCC could offer flexibility, allowing the FCC to extend the deadline for compliance for companies as they move past SMS (http://bit.ly/ZMQFiR). NENA said that doing so “would provide a powerful incentive for the deployment of NG911-ready text platforms capable of supporting more advanced location determination capabilities, and would provide a safeguard against stranding investments in location technologies for platforms that phase an imminent phase-out.”

Verizon said it has deployed an SMS-based text messaging platform for almost 250 PSAPs, with another 150 requests in the pipeline. The FCC shouldn’t impose requirements based on aging technology, the carrier said (http://bit.ly/1vIY7rU). “Imposing roaming and enhanced location standards for legacy SMS networks would inappropriately divert resources from forward-looking technologies.”

The FCC should not ignore the significant costs to carriers of putting in place interim solutions for technologies facing imminent retirement, as it develops its cost-benefit analyses, T-Mobile said (http://bit.ly/1rae3hC). “While T-Mobile does not dispute that extending access to interim SMS-to-911 will have benefits, it is concerned that the Commission’s calculations are difficult to validate, particularly given that the record indicates the costs of implementing the proposed enhancements to SMS-to-911 will be extremely high and will take several years to implement.”