The record so far shows that commenters “overwhelmingly” support “voluntary, industry-led collaborative efforts” aimed at developing a mechanism allowing texting to 911, CTIA said in reply comments filed at the FCC. Carriers offered similar comments. But the National Emergency Number Association advised the FCC to act quickly and warned that any interim solution is likely to be in place for some time. Several commenters said the best short-term solution would be IP Relay, as identified by the ATIS Interim Nonvoice Emergency Services Incubator.

Despite “a substantial strain of caution in the initial comments received” by the FCC, consumers can’t wait seven to 10 years for text-to-911 to become “a reality,” the National Emergency Number Association said in a filing at the FCC. NENA CEO Brian Fontes and others from the group recently met with FCC officials, the group said (http://xrl.us/bmraw8). No review of existing text-to-911 solutions has been undertaken in sufficient detail or sufficiently absent artificial constraints to permit NENA to articulate specific recommendations about which solutions are operationally and economically viable for public safety answering points, consumers, and carriers, NENA said: “NENA committed, however, to conducting such a review with respect to PSAPs (at a minimum) and to communicate its findings to the Commission in short order.”

The National Emergency Number Association and the Association of Public-Safety Communications Officials agreed with wireless carriers that the FCC must move with care as it moves toward a solution that will allow consumers to send text messages to 911 call centers. FCC Chairman Julius Genachowski has repeatedly stressed that he sees texting to 911 as an important component of a next-generation 911 network (CD Aug 11 p1). The issue is of special significance to deaf people who otherwise have difficulty making 911 calls. Comments were due this week on a notice of proposed rulemaking approved by the FCC at its September meeting (CD Sept 23 p6).

A “negligible” amount of Skype customers expect to be able to make emergency calls from their accounts, the company told the FCC in reply comments on docket 11-117. Skype hired research company Penn Schoen Berland to do an online survey of 1,001 paying Skype customers about their attitude to the service, the company said. It found that “less than 5” percent of Skype customers “indicate they would be likely to use Skype to place an emergency call,” the company said.

FCC rules should be based on the assumption that the public will expect that any outbound-only VoIP service is capable of reaching 911, the Association of Public Safety Communications Officials said in reply comments filed at the FCC in response to a July 13 FCC notice of proposed rulemaking. “Even if a VoIP service subscriber uses a particular service without an expectation of making domestic outbound calls (let alone calling 911), to the extent a phone-like device is capable of doing so, others (such as a family member, friend, visitor, customer, or employee of a subscriber) may use that device in an emergency situation with a clear expectation that they will be able reach 911,” APCO said (http://xrl.us/bmho3t). “A subscriber might also obtain a VoIP service with the intention of using it in narrow circumstances (e.g., international calls), and then begin to use it more broadly over time, creating new expectations of its capabilities by the time an emergency occurs.” APCO conceded “there may be some basis for creating FCC-recognized consensus guidelines and standard of care best practices for situations that clearly do (or do not) create reasonable expectations of 911 capability” but those cases should be seen as an exception, APCO said. The National Emergency Number Association largely agreed with APCO in its reply comments. “Since the Commission adopted its existing definition of interconnected VoIP service in 2005, the consumer market for such service has changed dramatically,” NENA said (http://xrl.us/bmho4b). “While it was initially only facilities-based VoIP providers who marketed their services as true replacements for home telephone service, non-facilities-based providers now aggressively market their services to residential subscribers, emphasizing low cost and ease of use as key selling points. Indeed, even services that have not marketed themselves as replacements for POTS [plain old telephone service] are increasingly offering products that emulate the residential POTS experience.” The FCC previously imposed location-accuracy requirements on VoIP providers that originate and terminate calls on the public switched telephone network and is now examining whether similar requirements should apply to increasingly popular VoIP services like SkypeOut that allow outbound only calls. The commission sought comment in an NPRM approved at its July 12 meeting (CD July 13 p7).

National Emergency Number Association CEO Brian Fontes and others from the group discussed the “role and importance of standards in enabling innovative, consumer-focused emergency-calling services.” The discussion came during a meeting Friday with Chairman Julius Genachowski and others at the commission. “Second, we explained our view of how the Commission could facilitate the roll-out of [next generation] 911 by working collaboratively with state utility commissions. In particular, we noted that some regulations based on legacy service models such as monopoly wireline service may impede or outright prohibit the provisioning of NG 911 service by competitive entrants or the disaggregation of various aspects of NG 911 service,” NENA said in a filing at the commission (http://xrl.us/bma3ae). “Finally, we discussed the importance of interoperability considerations [to] the broader emergency communications enterprise.”

The National Emergency Number Association supported the AT&T/T-Mobile merger in a filing at the FCC (http://xrl.us/bkzstz). “NENA believes this merger will benefit the public safety and emergency response community as well as the public-at-large by speeding the build-out and expanding the foot-print of the combined entity’s advanced LTE network,” NENA said. “While the combined AT&T/T-Mobile network will operate in spectrum distinct from that of public safety services, the proposed merger will nonetheless produce economies of scale and scope in the market for LTE-capable infrastructure and equipment that will reduce the overall cost of providing service to the public safety community."

T-Mobile fired back at the National Emergency Number Association in a filing on testing requirements as the commission implements new E911 location accuracy rules. In a filing posted by the FCC Tuesday, NENA accused T-Mobile of advocating weakened rules (http://xrl.us/bkzca8). “As T-Mobile would have it, no network would be subject to a testing requirement unless localized position uncertainties grow beyond some threshold value or confidence metrics decline to unsatisfactory levels,” NENA suggested. “T-Mobile reads the [revised rules] to require testing only as means to remediate degradation of location over time.” Neither statement is true, T-Mobile said (http://xrl.us/bkzcb9) Wednesday. “Under the Second Report and Order, carriers will have to demonstrate compliance in each county for which they claim compliance. That requires empirical testing of county-level accuracy,” T-Mobile contended. The debate regarding periodic maintenance testing is only about what happens after compliance at the county level has already been established empirically, with uncertainty baselines."

Eight technology vendors Thursday backed the National Emergency Number Association’s Next Generation 911 Architecture Interface Standard (i3). “We fully advocate that NENA remain the ‘Voice of 911’ and continue its NG911 standards development and evolution efforts,” the companies said in a joint statement. “Doing so will enable the public safety community” end-user agencies and business ecosystem members “to enhance and accelerate the development and deployment of NG911 emergency communication solutions,” they said. They are: 911 Datamaster, Avaya, Cassidian Communications, Digital Data Technologies, GeoComm, RedSky Technologies, Solacom and TeleCommunication Systems.

The FCC should use its ancillary authority under Section 154(i) of the Telecom Act to apply anti-Caller-ID “spoofing” rules to VoIP providers, the Department of Justice said in a filing at the FCC. “Although the Commission has not classified interconnected VoIP service as a telecommunications service for the general purposes of Title II, it has previously used its ancillary authority … to extend many common carrier obligations to VoIP providers,” said criminal division Deputy Assistant Attorney General Jason Weinstein in Justice’s comments. “Here, the Commission’s ancillary authority under Section 154(i), in conjunction with the provisions of the Truth in Caller ID Act, is sufficient to empower the Commission to regulate such providers.” The commission is in the midst of a rulemaking on how to implement the 2009 Act, and comments came pouring into docket 11-39 this week.