With Vonage v. Minn. PUC oral arguments expected in Oct., Vonage urged the FCC during an ex parte meeting last week to act “expeditiously” on its pending petition concerning the jurisdictional nature of its service. “If the FCC chooses to act later, the [U.S. Appeals Court, St. Louis,] will render the decision prior to the FCC, and the Commission will be bound by the court decision,” Vonage attorney William Wilhelm told us: “If the FCC wants to set a precedent, it would have to act on the matter before the court ruling.” The 8th Circuit is expected to issue its decision this year. With respect to VoIP 911 services, Vonage said it continued to “devote substantial resources toward the development of standards and technology necessary to facilitate VoIP 911 services.” It said it was “a signatory to the NENA Statement of Principle with respect to the development of VoIP.” But it said it “concurs with NENA’s opposition to the fragmentation of 911 and agrees that consumer expectations for 911 are national and therefore require jurisdictional leadership and resources from the Federal Government.” Noting that the FCC promised to provide that leadership in its IP services rulemaking, Vonage said it would support Commission action that would endorse “a national approach to IP 911 that would marshal the regional expertise of the public safety community but preclude disparate state approach.” It urged the Commission to approach the development of VoIP 911 “just as it oversaw the national deployment of 911 for commercial mobile radio services.”

The National Emergency Number Assn. (NENA) endorsed the Cingular-AT&T Wireless (AWS) merger in a filing at the FCC. “We are pleased that Cingular and AWS continue to make progress in their E911 deployment,” NENA said. “Through FCC compliance efforts, Cingular and AWS have adhered to existing consent decrees governing E911 Phase I and Phase II obligations… We believe that capabilities of each company to implement and improve 911 services will be strengthened by their merger.”

The National Emergency Number Assn. (NENA) blasted Ill. Gov. Rod Blagojevich (D) Mon. for shifting funds from Enhanced 911 (E911) funding. NENA said Blagojevich was “putting lives at risk” to balance the budget. NENA said Blagojevich approved the 2004 Ill. budget that included a $1.3 million transfer of funds from the state’s E911 fund. NENA said Ill. has levied a 75 cents tax on each cell phone bill to help fund E911, which would give 911 operators an approximate location of a wireless caller. “The public needs to know that our state leaders are falling short of what is needed to keep up with new technologies and challenges,” said David Tuttle, pres.-Ill. NENA chapter. Members of Congress have been irked by several states that have diverted funds from E911. HR-2989, which has passed the House, and S-1250, which has passed the Senate Commerce Committee but stalled on the floor, would provide money for E911, but not to states that have diverted funding.

The National Emergency Number Assn. (NENA) is pushing a new angle in efforts to get stalled Enhanced 911 (E911) legislation through Congress. Seizing on the interest in new services like VoIP, NENA is presenting the case that E911 legislation is essential because it would establish a National Coordinating Office in the federal govt. That office would help integrate 911 services to VoIP and other new services, like Wi-Fi and Blackberries, said NENA Govt. Affairs Dir. Stephen Seitz. The national coordination office was the top priority cited in a document NENA delivered to Congress last week, ahead of funding.

Public safety and business telecom users expressed cautious optimism Wed. that negotiations could be restarted on E911 deployment requirements for multiline telephone systems (MLTS). In a further notice last fall, the FCC had concluded that state and local govts. for now were best positioned to set E911 deployment rules for MLTS, though the Commission said it would monitor their progress. Participants in an FCC E911 Coordination Initiative Wed. agreed the issue of how to locate emergency callers using private branch exchanges (PBXs) is ripe for renewed talks.

FCC Chmn. Powell touted the progress of Enhanced 911 deployment the past 6 months, Tues. telling an E911 Coordination Initiative 900 more public safety answering points (PSAPs) became Phase 2 capable in that period. The Commission a year ago kicked off the initiative to examine E911 implementation issues. At the previous, Oct. initiative meeting also, Powell had cited Phase 2 deployment growth, saying rollouts had jumped 300% in 7 months. At Tues.’ meeting, he said R.I. and Vt. are the first states to report implementing Phase 2 in 100% of PSAPs. “Tennessee is expected to join the list in June,” he said. Separately, Powell cited the agreement between the National Emergency Number Assn. (NENA) and the Voice on the Net (VON) Coalition on how VoIP providers will deliver location information to PSAPs. It “exemplifies what can be achieved from public/private partnerships,” he said. “While the Commission grapples with this issue, it is encouraging to know that consumers are being provided some basic level of E911 capability for VoIP services.” In opening remarks at the 2- day meeting, Powell said the effectiveness of location capability needed to continue improving in “challenging areas.” He recently outlined the creation of a technical group to focus on E911 network architecture and technical standards issues as part of the Network Reliability & Interoperability Council (NRIC). “Measuring and improving the accuracy of E911 location information will be a priority,” he said. The council’s latest iteration, NRIC VII, will examine issues presented by IP protocol and open network architecture for E911 and public safety. “This hard work should result in more accurate and reliable E911 service to wireless subscribers across the nation, whether in small rural communities or big urban corridors,” he said. “There may be deployment challenges in bringing E911 location capability to geographically challenging environments, but the lifesaving capabilities of the service are too vital not to be extended to all subscribers, including rural subscribers.” Another focus of the 2-day meeting is how 911 services can be provided to multi-line telephone systems (MLTS). In an order adopted in Nov. on the scope of E911 regulations, the FCC declined for now to approve national rules for MLTS, instead encouraging states to use model legislation adopted by public safety groups. The Commission said it expected states to act promptly, indicating it would release a public notice in a year to evaluate their progress. “While many may need more time to act, the danger associated with not having location technology for these systems is only growing and E911 capability is just as vital to consumers in this circumstance as with wireless,” Powell said.

Public safety groups urged the FCC in comments this week to expand the scope of Enhanced 911 requirements to include multi-line telephone systems (MLTS). The issue of how to provide caller location information to 911 centers from MLTS systems is among issues the Network Reliability & Interoperability said this week it would consider under a new 2-year charter (CD March 31 p6). But the Ad Hoc Telecom Users Committee backed an FCC decision last year to not enact E911 rules for MLTS, arguing states have clear jurisdiction and are a logical place for the issue to be resolved.

The National Emergency Number Assn. (NENA) asked FCC Wireless Bureau Chief John Muleta for a rule interpretation that would let wireless carriers undertake certain “congestion control” measures. NENA noted that incidents such as power outages trigger “spikes” in calls to 911 networks from both wireline and wireless phones. Wireless networks are particularly subject to this congestion because of the number of eyewitnesses who report critical incidents from a roadside location or other “mobile” spot. “For many years, wire telephone providers and public safety answering points (PSAPs) have engaged in ’sizing’ their respective network segments so as to minimize or contain the effects of ‘mass calling,'” NENA said. “For a number of reasons, this form of ‘congestion control’ has not been adopted in many wireless networks.” NENA asked the FCC for an interpretation of its rules on when a wireless carrier must transmit all wireless 911 calls. NENA asked the FCC to rule that a mobile operator discharges this obligation when passing emergency calls into the trunks that connect a mobile switching center (MSC) to a selective router (SR). To this end, NENA submitted a report from its technical issues director Roger Hixson. The FCC rules at issue, Sec. 20.18(b), require covered operators to transmit all wireless 911 calls without respect to their call validation process to a PSAP or statewide default answering point. Citing Hixson’s report, NENA said call containment through trunk sizing or other methods is closely related to “grade of service” measurements similar to what wireline networks use. The application of a non-discriminatory means of “sizing” calls from customers and non-subscribers wasn’t part of the policy calculus that led to the wording of this section “and therefore not meant to be proscribed by the new rule,” it said. The FCC determined all 911 calls should be passed through regardless of call validation process, NENA said. This was based on a belief that procedures seeking to “verify subscriber status were impeding the delivery of vital communications,” NENA said. It said: “The history of the wireless E911 rules, coupled with the present reality that mass calling about localized emergencies can affect public safety communications across much wider areas, suggests the prudence of the interpretation we request here.” NENA asked the FCC to “reassure wireless carriers” that this language doesn’t rule out reasonable decisions about sizing wireless MSC-to-SR trunks and other kinds of call containment in their networks. NENA said historically, all sources of calls have received equal treatment from origination to completion to give equal probabilities of 911 call delivery. This has been done through so-called P.01 sizing, which means the trunk group sizing is based on that quantity that will let 99 of every 100 calls be completed in the busiest hour over a period of monthly measurement. Hixson’s report said wireline carriers and many wireless carriers do congestion management through MSC-SR trunk group sizing. “Typically, carriers or their agents analyze call volumes over time, and use the engineering process to size, or adjust the size of, the originating trunk group to P.01 service levels,” NENA said. This provides equal access levels across all types of carriers and end offices. NENA said “typical wireless carrier arguments against this technique” have included the extent to which wireline P.01 sizing doesn’t apply to wireless. Mobile operators also have argued they don’t know how many calls are involved so they can’t size trunk groups to P.01 standards, NENA said. NENA said CLECs have addressed the same problem. “The need is to accomplish P.01 by active monitoring of call volumes over time. Make an educated judgment, then adjust,” NENA said.

Nortel Networks said Tues. it had submitted a proposal to the National Emergency Number Assn. (NENA) for an architectural framework to enable Enhanced 911 (E911) access on VoIP networks. Nortel Senior Consulting Engineer Mark Lewis told us the proposal, submitted last week, addressed “key technology challenges,” including: (1) Routing a 911 call to the correct public safety answering point (PSAP). (2) Transmitting caller’s correct location information. He said Nortel’s “technical, open-standards proposal” demonstrated “how leveraging existing wireless infrastructure can be used” to address E911 issues in relation to VoIP and “how industry can adopt it.”

FCC Chmn. Powell expressed optimism Mon. technology could address the challenges of providing Enhanced 911 services on broadband networks offering VoIP applications. “We do have that rare opportunity to join hands and develop the solutions early, before our citizens and our consumers are using these services in overwhelming numbers,” he told a National Emergency Number Assn. (NENA) forum in Washington.