Industry commenters largely acknowledged that Telecommunication Systems (TCS) identified a real problem in its petition last August -- companies providing E-911 and next-generation 911 call routing and location information and carriers face predatory lawsuits by patent assertion entities (PAEs). But commenters disagreed whether the FCC can grant the relief sought by TCS. Qualcomm said not denying the petition would have “devastating public policy consequences.”

Changing 911 technologies call for a change in behavior and federal advocacy, speakers told the National Number Emergency Association Monday. Public safety officials from around the country are gathering in Washington for the association’s 911 Goes to Washington meeting, which continues Tuesday. “We become a part of the government procedure,” said NENA Second Vice President Christy Williams of the 911 directors’ visits to Capitol Hill offices this week. She noted that more than 31 states and territories were represented at this year’s meeting. Speakers discussed the best ways to approach federal government officials as well as the challenge of text-to-911 and potential spectrum interference. (See separate report in this issue.)

The nature of 911 is changing, the members of the National Emergency Number Association were told at its 911 Goes to Washington meeting. Multiple new technologies are transforming how regulators and industry are seeing the service, and Monday sessions focused on text-to-911 initiatives, the broader move to an Internet Protocol-based next-generation 911 and the move within the wireless industry of tracking callers’ locations, all of which call for a reassessment of current codes, laws and practices, particularly at the state level.

The FCC Public Safety Bureau will refresh the record on what it should do about prank calls to 911 from “nonservice-initialized” (NSI) handsets -- cellphones no longer connected to a carrier network. In 2008, the FCC sought comments in response to a petition from public safety groups (CD March 5 p5/08). Many of the calls come from teens aware that calls on old cellphones must be forwarded by carriers under FCC rules, but can’t be traced. The FCC in 1996 at the urging of public safety imposed a requirement that NSI handsets can still make 911 calls. In seeking additional comment, the bureau cited a recent filing by the National Emergency Number Association. “According to NENA, ‘PSAPs face an ever-growing onslaught of non-emergency calls to 911 from NSI devices,'” the bureau said (http://bit.ly/1528R3X). “Moreover, in recently filed comments in another docket, NENA states that there is now a ‘consensus view that the promotion of NSI devices does more harm than good.’ NENA further asserts that ‘most charities and domestic violence advocates [have] abandoned the practice of distributing NSI devices.'” Comments and replies will be due following publication in the Federal Register.

Transition to a replacement for the text telephone (TTY) system for emergency communications for the disabled should last 12 years, the FCC Emergency Access Advisory Committee’s (EAAC) TTY Transition subgroup said in a draft report. That timeline would include three years for getting the TTY replacement “commonly available,” three years until “no more legacy TTYs should be deployed,” and an additional six years until TTY support can cease, the subgroup said. That timeline can be sped up or slowed down depending on conditions in the overall transition from the public switched telephone network to Internet protocol, the subgroup said in the report. The subgroup recommended implementing the National Emergency Number Association i3Detailed Technical specification 08-003 and Internet Engineering Task Force (IETF) request for comment 6443 to achieve interoperability between service providers when at least one uses IETF Session Initiation Protocol (SIP) for call control. The default interoperability protocols include: IETF RFC 3261 SIP for call control, ITU-T Recommendation T.40 for real-time text presentation and IETF RFC 4103 for real-time text transport, as well as “suitable audio and wide-band audio codecs” commonly used in the implementation environment and supported by Next-Generation 911 (N-G9-1-1). For IMS, the profile specified in GSMA PRD ir.92, including its Annex B, specify a “similar set suitable” for TTY replacement, the subgroup said. That profile also recommends IETF RFC 3261 SIP for call control and IETF RFC 4103 for real-time text, but also requires 3GPP TS 26.114 IMS Multimedia Telephony Codec Considerations for audio. A “suitable combination” with video as specified in GSMA PRD ir.94 should be considered, the subgroup said. Other real-time text protocols can also be used within each service provider’s network or between service providers, provided the functional goals for TTY transition are still met and other protocols are supported as a fallback, the subgroup said. For interoperability of calls between PSTN’s TTY and the TTY replacement, the subgroup recommended placing gateways in the network -- and that calls that may contain text should automatically be routed through the gateway. Other alternatives should also be considered and further investigated, the subgroup said. Recommendation T6.3, which allows for conversion of TTY to IP-carried real-time text at the point of entry to IP networks, is the “realistic solution” for TTY access to N-G9-1-1, the subgroup said. There should be coordination with the U.S. Access Board, the Telecommunications Equipment Distribution Programs and the National Deaf-Blind Equipment Distribution Program, the subgroup said. TSR rules should be updated to “specifically support relay calls based on the protocols used in accessible interchange with N-G9-1-1,” including information requested in the NENA i3 technical specification, the subgroup said. Videophone and VRS service providers should implement TTY replacement features in combination with video, the subgroup said. NENA recommendations to provide 9-1-1 access to instant messaging users should be encouraged separately from TTY replacement activities “in order to provide 9-1-1 access for current users of these services related to both accessibility and general needs,” the subgroup said. The draft report includes two possible versions of a recommendation for a move toward TTY replacement in industry practice and FCC regulations, as the EAAC “could not come to an agreement” on a common version (http://bit.ly/Y5tvjC).

CTIA warned the FCC that if it imposes a text-to-911 mandate on carriers, the order may not survive a court appeal. Verizon, which has sued the FCC over its data roaming mandate and net neutrality rules, said the FCC should monitor how well voluntary agreements work before imposing rules. The FCC approved a further NPRM asking questions about how the commission can best make sure that all wireless subscribers will one day be able to send emergency text messages to public safety answering points, amid warnings that widespread ability to do so could be many years way (CD Dec 13 p12).

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.

The FCC should impose a relatively early deadline on all interconnected text message providers to send bounce-back messages to their customers when text-to-911 isn’t available, not just the nation’s four biggest carriers, AT&T said in comments filed at the FCC. The National Emergency Number Association said the deadline for all should be “generous, but firm.” Under an agreement last year with the Association of Public-Safety Communications Officials and NENA, the top four providers said they would implement systems for transmitting bounce-back messages by June 30. T-Mobile warned that meeting the deadline won’t be easy.

T-Mobile and Sprint Nextel told the FCC in separate reply comments some kind of local or regional coordination is necessary for public safety answering points (PSAPs) to ensure a smooth transition to a next-generation 911 world. The National Emergency Number Association (NENA), meanwhile, offered some basic principles for an NG911 transition. Reply comments on a Nov. 13 public notice by the FCC’s Public Safety Bureau were due at the FCC Monday. Industry groups filed initial comments last month (CD Dec 17 p7).

The FCC should rely on a “cooperative, standards-based approach” in developing rules for the deployment of a next-generation 911 network, Verizon and Verizon Wireless said in comments filed at the FCC. The National Emergency Number Association (NENA) said rollout of a successful NG911 network will require “action at every level of government.” In November, the FCC Public Safety Bureau sought comments on a legal framework for NG911 (http://fcc.us/W6u2m7).