The FCC Public Safety Bureau is working hard to wrap up a decision on the various longstanding applications from Oklahoma, New Orleans and other jurisdictions for waivers so they can build out early networks in the 700 MHz band, Chief Jamie Burnett said Wednesday. But Barnett, who spoke at a National Emergency Number Association conference, declined to provide a timetable for when the FCC will make a decision.

The National Emergency Number Association is still working with its members on the challenges public safety answering points face should the FCC mandate text messaging-to-911, CEO Brian Fontes said in a meeting with FCC officials. “We explained that some PSAP equipment such as log recorders may require upgrades in order to handle SMS text, depending on a particular PSAP’s posture with respect to NG911 readiness,” NENA said in a filing (http://xrl.us/bmy435).

Spectrum legislation approved by Congress last week as part of the payroll tax cut extension bill offers $115 million to help defray the costs of a next generation 911 (NG911) network. That’s the good news for public safety. The bad news is that amount is less than one twentieth of the expected cost. But public safety officials said other provisions should be helpful in making NG911 a reality.

The FCC should “discount” recommendations by the Alliance for Telecom Industry Solutions Incubator that the only feasible solution in the short term for sending texts to 911 should be based on Internet Protocol text relay technology, the National Emergency Number Association said in a comment filing. ATIS started its investigation in April 2011 using June 2012 “as the target deployment date,” NENA said (http://xrl.us/bmr3i7). “By arbitrarily limiting its consideration of possible solutions to those which could be deployed nation-wide in just over one year (including the 9 months required to generate its report), the Incubator effectively precluded consideration of many potential solutions that might have been implementable upon longer, but still reasonable timeframes.” IP text relay “has enormous shortcomings, however, that arguably exceed even those of some SMS-based solutions,” NENA said. It said said some companies, including Intrado and Neustar, have demonstrated or proposed SMS-to-911 solutions “that allow for location-based routing and varying degrees of handset- or network-based location reporting -- both critical elements of 911 service that IP text relay has not yet been shown to support.”

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.”