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.

The FCC’s decision on Pulver.com petition “doesn’t mean the Commission has made its mind up on the questions raised in the NPRM” opened last week (CD Feb 13 p1), FCC Chief of Policy Development Robert Pepper told reporters at a briefing Wed.: “I wouldn’t read to much into this. It doesn’t address many issues, such as 911 and CALEA -- that’s why the Commission has an NPRM… In Pulver.com, the Commission confirmed what was true for 20 years. It was a first easy decision.” The petition, granted by the Commission earlier this month (CD Feb 13 p1), had asked the FCC to rule that IP- to-IP service provided by Pulver.com was neither telecom nor telecom service. Wireline Bureau Senior Deputy Chief Jeff Carlisle said the Pulver decision was “useful in terms of setting up a flag -- okay here is an easy case, but the NPRM will address more complicated issues.” Pepper told us there were “some general principles in Pulver decision that speak to the question of why [and] how is Pulver’s service defined as an information service.” He said the principles the FCC used to define whether Pulver.com was an information service “could be applied in other cases, but not necessarily, because each petition is very fact-specific and will be evaluated separately and on its own merits… I can envision lots of things that would fit into information service definition based upon the principles that have been clearly articulated.” Pepper -- also co-chmn. of the FCC Internet Policy Working Group created by FCC Chmn. Powell last Dec. to address policy issues related to IP-based services -- said his group would hold a series of “solutions summits” in spring on 911/E911, CALEA and access for people with disabilities issues. The first meeting on 911/E911 is scheduled for March 18. Pepper encouraged the industry to address technical aspects of issues such as 911 and CALE, and come up with standards: “The industry has an enormous technical expertise and it’s not the same but it’s analogous to the standards setting process.” As an example, he cited an MOU between the VON Coalition and NENA on 911 solutions announced last Dec.: “So, it’s already an industry-led process. It would be wonderful if [the industry] would come together with a proposal that they can submit… and we could then open a proceeding based on what they come up with.” Pepper said his working group hadn’t developed any possible solutions since it was created in Dec. to address social policy issues: “What we want to do is hear from the industry… about defining what the issues are, setting up an agenda of questions that need to be resolved, and then ask the industry about what the best ways are to solve those. So, we are still in the stage of defining specifically those questions.”

The Assn. of Public Safety Communications Officials (APCO) said Tues. it didn’t agree with a recommendation in the National Emergency Number Assn. (NENA) Strategic Wireless Action Team (SWAT) report on E911 handset replacement. The report recommended that the FCC relax a current mandate that required wireless carriers using a handset-based E911 Phase 2 solution to meet a 95% penetration rate by the end of 2005. APCO said it “strongly disagrees” with that recommendation. NENA also said last week it opposed any delay in the FCC deadline for wireless service providers using a handset-based solution (CD Feb 9 p8). Nextel last year called on the FCC to lift its Dec. 31, 2005, deadline for handsets to be Phase 2 capable as long as interim benchmark dates for handset deployment were met. APCO said the extent to which a public safety answering point could locate callers depended on the rate at which “old handsets are replaced by new models with location capabilities.” APCO said all carriers should be held to the current handset penetration requirements. “Why wouldn’t we hold the carriers accountable for making their handset penetration requirements?,” asked APCO 2nd Vp Wanda McCarley.

The National Emergency Number Assn. (NENA) stressed Fri. it opposed any delay in the FCC mandate for wireless service providers using an E911 handset-based solution. NENA Thurs. released the findings of a Strategic Wireless Action Team (SWAT) effort in which private sector, govt. and public safety officials examined E911 implementation (CD Feb 6 p6). Among the findings, the report recommended that performance requirements for wireless carriers focus on “near-term handset and network cell site activation” goals. It said FCC enforcement should prevent “unintended consequences” such as forced handset replacement. In a joint statement, NENA Pres. Richard Taylor and SWAT Chmn. John Melcher said Fri. that NENA opposed any delay in FCC deadlines for providers using a handset-based solutions. “NENA continues to support current FCC rules and regulations as written,” they said. They cited pending House and Senate bills that would provide additional money and accountability measures to ensure that E911 was rolled out as quickly as possible. Handset replacement has been a particularly important issue for Nextel, which last year called on the FCC to lift its Dec. 31, 2005, deadline for wireless handsets to be Phase 2 capable as long as interim benchmark dates for handset deployment were met.

Vonage CEO Jeffrey Citron warned Fri. that “premature regulations could kill the nascent VoIP industry.” Speaking at a policy lunch sponsored by the Progress & Freedom Foundation in Washington, Citron said regulations could slow broadband deployment, undermine the U.S. position as a technological leader and force service providers offshore. He urged legislators to “bring clarity to the VoIP regulatory framework to protect competition. New laws are needed to ensure Internet applications remain free from regulation.”

Only 1/2 of all public safety answering points (PSAPs) will be able to pinpoint wireless callers with the precision of Enhanced 911 Phase 2 by 2005, the National Emergency Number Assn. (NENA) said in findings announced Thurs. NENA’s Strategic Wireless Action Team (SWAT) wrapped up a year-long effort by private sector, govt. and public safety officials to examine E911 implementation. But disagreements over some findings indicate rifts on issues such as carrier cost recovery, state coordination and federal funding.

AT&T said it had signed an agreement with Intrado, a provider of 911 infrastructure, systems and services, to develop an emergency calling solution for its residential broadband VoIP service. The feature, which would allow AT&T to route 911 dialed calls from its IP network to public safety answering points but wouldn’t be able to identify a caller’s location, will be available in spring when AT&T will begin to provide residential VoIP service in select metropolitan markets. “It’s not an absolute solution, it’s an interim step,” an AT&T spokesman said. He said AT&T would continue to work with Intrado and the National Emergency Number Assn. (NENA) to “upgrade 911 technology. The ultimate goal is to have no difference” between the regular 911 services and the ones provided by VoIP.

The National Emergency Number Assn. (NENA) told the FCC it backed a request by BellSouth for more time to comment on a further notice involving wireline-to-wireless local number portability (LNP). BellSouth recently asked the FCC to extend the comment deadline a month to Jan. 30, citing the holidays and a N. American Numbering Council meeting set for mid-Jan. NENA said it wanted to identify technical problems and solutions involving porting that crossed wire telephone rate center boundaries. “Because any conclusions reached and recommendations offered must be approved by a technical committee structure that brings to bear data transfer and networking, among other perspectives, these multiple reviews would be difficult to complete by the Dec. 30 date falling between Christmas and New Year’s,” NENA said.