The framework specifications of NENA i3 contain many gaps that may disrupt the transition to accessible next-generation 911, said a report from the FCC’s Emergency Access Advisory Committee Monday (http://bit.ly/12uJvuR). NENA 08-003 version 2, yet to be released, may fix some of these gaps, it said, calling the NENA i3 work a “tremendous accomplishment” despite the work to be done. The report pointed to test requirement inconsistencies and lack of testing specification, how 911 call centers will be able to accept text messages as TTY during the transition, TTY limitations generally, the risk of not using terminal procedures for NG-911 handling and other aspects. The report does not claim to be comprehensive but wants its points taken into consideration in any future revision of the standards. Accessibility should be implemented from the start in NG-911, it said.

The four national wireless carriers are on target to make text-to-911 messages available to all public safety answering points capable or receiving them by a May 15, 2014, deadline, they said in reports filed this week at the National Emergency Number Association. That deadline stems from a voluntary agreement Verizon Wireless, AT&T, Sprint Nextel and T-Mobile signed with NENA and the Association of Public-Safety Communications Officials last year, under FCC pressure (CD Dec 10 p1). All four carriers said they're already transmitting bounceback messages to subscribers who try to send emergency texts before 911 call centers can handle them.

"I do know there are very many larger areas where the PSAPs are not ready to handle that,” said Chris Littlewood, project coordinator at the Allstate Center’s Center for Public Safety Innovation at the National Terrorism Preparedness Institute, of text-to-911. Education and outreach needs “to happen at the PSAP level as well,” he said. “I can tell you that it’s not just rural areas that have no idea that they need to be handling text-to-911 by the beginning of next year. … Are the PSAPs going to be able to handle that?” Different procedures will need to be in place at different levels of the 911 call centers, he said.

With the comment cycle now complete, FCC staff members appear to be pushing forward on an order addressing new rules in the aftermath of the 911 outages reported during last June’s derecho storm, said commission and public safety officials. The National Emergency Number Association and AT&T both reported last week on follow-up meetings with Public Safety Bureau staff to explain the comments they filed last month (CD May 30 p6).

The FCC should require all carriers to certify their systems meet “a core set of 911 resiliency practices,” which would be developed by public safety and other stakeholders, Verizon and Verizon Wireless said in reply comments. The comments responded to a March NPRM (http://bit.ly/YtIwc5) from the commission, reacting to last year’s derecho wind storm. It led to outages that affected 77 public safety answering points across Ohio, the central Appalachians and the Mid-Atlantic states, with 17 PSAPs losing service completely (CD March 21 p4).

The FCC should require carriers to notify public safety answering points within 15-30 minutes of a detected outage, CEO Brian Fontes and others from the National Emergency Number Association said in a meeting with Public Safety Bureau officials. NENA reacted to proposed rules by the commission, saying a requirement of immediate notification should be further refined. “The requirement under the PSAP notification rule should substantially differ from that under the Commission’s general network outage reporting rules,” NENA said. It said that a single notice of an outage won’t suffice. “We recommended that the Commission consider requiring regular supplemental notices, no less than twice per day, to keep PSAPs up-to-date as carriers and other service providers gain further information about an outage,” the filing said. “We also noted that while telephone and email contacts should be mandatory, PSAPs, carriers, and service providers should be free to adopt other notification methods, provided that PSAPs have a legitimate private choice as to whether they will adopt any particular method offered by a carrier or service provider.” NENA also weighed in on when PSAPs and carriers should be responsible for the connection of 911 call centers to the larger carrier network. “Diversity of circuits connecting end office switches with selective routers, as well as those connecting selective routers with the main distribution frames (or their equivalents) of end offices serving PSAPs should be the responsibility of carriers or service providers while the diversity of circuits connecting the ‘outside’ faces of main distribution frames with PSAPs should be the responsibility of PSAPs and 911 authorities,” the filing said. The FCC had said 911 calling problems were widespread following the derecho that hit the Midwest and East Coast June 29 (CD July 20 p1).

CTIA raised questions about a proposed FCC requirement that public safety answering points must provide bounceback messages for 911 calls in cases where they normally can handle emergency texts but are unable to for a given period. The FCC is set to take up an order at its meeting Thursday requiring all wireless carriers and providers of interconnected text message services to give consumers automatic bounceback messages by Sept. 30 when they try to send a text message to a 911 call center that isn’t capable of handling texts. Major carriers must be able to transmit bounceback messages by June 30 under an agreement reached last year between the four major national carriers, the National Emergency Number Association and the Association of Public-Safety Communications Officials (CD Dec 10 p1). One issue that hasn’t been part of public discussions is the PSAP requirement, the subject of recent meetings between CTIA and FCC officials, said an ex parte filing (http://bit.ly/10CoVpM). The mandate isn’t necessary, CTIA said. “The concept of providing PSAP initiated bounce back messages was not previously considered as part of the Carrier-NENA-APCO voluntary agreement,” the group said. “Even if the Commission does require a PSAP initiated bounce back messages, CTIA and the wireless participants noted that a standard method should be developed in order to avoid diverting critical PSAP resources when such bounce back messages are necessary.” CTIA said the requirement would apparently kick in only when “1) the wireless provider offers text-to-911 services to its subscribers, 2) the appropriate PSAP has requested and is accepting such text-to-911 messages sent from wireless subscribers, and 3) the PSAP, at that point in time, determines that the PSAP can no longer accept or process text-to-911 messages and requests that a wireless provider send a bounce back message to its subscribers.” Commission officials noted in December that it will likely be many years before most PSAPs are capable of handling emergency texts to 911 (CD Dec 13 p12).

Critics of Progeny’s proposed rollout of its E-911 location service told FCC Chairman Julius Genachowski that the agency should carefully consider the impact the service would have on fellow users of the 900 MHz Multilateration Location and Monitoring Service band before greenlighting it. The members of the Part 15 Coalition, a group of unlicensed Part 15 device users which occupy the 902-928 MHz band, said they're concerned the FCC was moving too quickly toward a decision on the Progeny 911 location service, which they said has the potential to cause “unacceptable levels” of interference. Coalition members and Progeny officials each said told us Friday that the other side was attempting to draw attention away from the technical record. The service would help locate wireless callers to 911.

Carriers are moving toward a voluntary solution so subscribers can send emergency text messages to public safety answering points, Verizon and Verizon Wireless said in reply comments at the FCC. But a group representing the deaf and hard of hearing said the FCC should impose a mandate on all carriers. In December, 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 911 text messages, amid warnings that widespread ability to do so could be many years way (CD Dec 13 p12). Verizon pointed to continuing progress. “Just last week, the Alliance for Telecommunications Industry Solutions and the Telecommunications Industry Association released a new technical standard that will provide service providers and PSAPs with a clear and feasible technology path toward text-to-911 implementation,” Verizon said (http://bit.ly/10Q16hU). “The Competitive Carriers Association also announced that most of its members will be able to implement the ‘bounceback’ requirement by the Agreement’s June 30 target. And Verizon Wireless launched text-to-911 service in Frederick, Md., where the Maryland School for the Deaf is located, and is working with PSAPs and other officials on deployments in several other states and localities.” A coalition led by Telecommunications for the Deaf and Hard of Hearing said the FCC should impose a mandate. “Text- to -911 is critical for more than just disability access,” the coalition said (http://bit.ly/Zbs7fP). “This Text-to -911 solution would not only provide access for people who are deaf and hard of hearing, and other TTY users, but provide a viable alternative for hearing people who are unable to use their voice while calling 911 due to speech disabilities or emergency circumstances where silence is necessary to avoid detection and further harm to their well being.” Earlier comments in general support the use of SMS as an interim solution for carriers to put in place for texting to 911, AT&T said. “While there is some diversity of opinion on the scope of the obligation to provide text-to-911 and on aspects of its implementation, in the main the comments applicable to CMRS providers support using the Carrier-NENA-APCO Agreement as a template for any interim solution,” AT&T said (http://bit.ly/14ejPIL). “NENA is encouraged by the many supportive comments filed in response to the FNPRM,” the National Emergency Number Association said in reply comments(http://bit.ly/10Q5a1B). “In addition to providing a factual record for the Commission’s interim text proceeding, the comments relating to interconnected- and applications-based-text providers clearly demonstrate the additional capabilities (e.g., enhanced location determination) that can come from these now-common services.” In the earlier comment round CTIA warned the FCC that a text-to-911 mandate on carriers may not survive a judicial challenge (CD March 13 p12). “NENA agrees with AT&T that the 21st Century Communications and Video Accessibility Act of 2010 (CVAA) provides clear authority for the Commission’s proposed Text-to-911 rules,” the group said. “Despite trade-group insistence to the contrary, the CVAA cannot be read so narrowly as to exclude Commission authority over the transition to IP-enabled emergency services like interim Text-to-911."

Progeny’s controversial network offering advanced location services in its 900 MHz Multilateration Location and Monitoring Service spectrum could play a big role in improving E911 location accuracy, the National Emergency Number Association said in a filing at the FCC. “NENA takes no position with respect to the technical aspects of Progeny’s test methods or results,” the letter said (http://bit.ly/ZrLv7D). “However, ... M-LMS technologies such as Progeny’s represent a tremendous opportunity to enable immediate and dramatic improvements in wireless location accuracy in precisely those areas of the country that are the most challenging for existing technologies.” The FCC’s decision on whether it will grant Progeny a waiver has big implications for the entire M-LMS industry, NENA said. “Progeny is the first M-LMS provider to begin deployment of a functioning network,” the group said. “Should Progeny be excluded from the market based on the objections of incumbents seeking to override the shared nature of the ... band by essentially squatting on that spectrum, the M-LMS market envisioned by the Commission’s Part 90 rules could be destroyed before it even comes into existence.”