FCC URGED TO TAKE GO-SLOW APPROACH IN EXPANDING E911 SCOPE

But Assn. of Public-Safety Communications Officials (APCO) urged FCC to remain vigilant on holding other wireless services to 911 obligations. It said Commission should create threshold standard that if caller had “reasonable expectation” that service or device would provide access to emergency response, it should do so. “The Commission should eliminate its initial examination of whether the service is technically and operationally feasible to provide enhanced 911,” APCO said: “Instead, the hallmark of any analysis should be whether its customers reasonably expect access to 911 service.” Company seeking to compete for voice service should be required to invest in E911, APCO said. It also acknowledged challenges faced by public safety answering point (PSAP) infrastructure. “It is important to bring forth the needed investment to the PSAP infrastructure and not allow the challenge to be overcome by debate, instead of effort, regarding how a new service design and operational elements cannot be accommodated by the PSAP infrastructure.” Group said MSS operators and multiline phone systems in office buildings should be required to meet E911 requirements.

Growth in voice-over-IP service creates particular challenges, APCO said. Vendors are marketing that as replacement for local landline service without meeting requirements of state PUCs for 911 service. It cited as example provider that offered home voice service over DSL and allowed subscribers to choose their area code from among those in 25 states. APCO said provider offered no 911 capability. “The Commission needs to explore whether there are existing legal tools to address IP services and, if not, whether statutory or regulatory changes are needed,” APCO said. It said PSAPs were funded by fees attached to phone bills, which IP providers didn’t charge, “creating a potential decline in funding for PSAP operations.” Ability of callers to choose their own area code also posed problems for locating E911 callers, it said. WorldCom said FCC should proceed carefully in extending E911 obligations to IP-based service, particularly because existing emergency services infrastructure wasn’t built with IP in mind. “The incompatibility of the existing E911 infrastructure with IP- based services makes it quite difficult to deploy E911- capable IP-based services,” WorldCom said. Until that infrastructure is modernized “there can be no hope of achieving the potentially feature-rich emergency services that IP could make possible,” it said.

Motorola raised concern that FCC was studying new E911 requirements for wider pool of services “at a time when uncertainty and confusion still prevail with deploying the current set of requirements.” Company cited E911 report submitted to FCC last fall by former Office of Engineering & Technology Chief Dale Hatfield that said Commission should move cautiously in accommodating special services and extending new 911 mandates to other wireless technologies. “The Commission should heed this warning and refrain from imposing new E911 requirements on the wireless industry until the Phase 1 and Phase 2 processes are substantially completed,” Motorola said. It said agency shouldn’t impose 911 obligations on telematics service providers, which involve safety and security call centers systems. FCC shouldn’t “second-guess” driver’s decision to use such system by imposing different performance requirements on technology than user had chosen. Agency sought comment on possible extension of E911 to wireless and IP-based systems. In response, Motorola said Wi-Fi systems had expanded and efforts were under way to include voice services for future applications of wireless LANs that now provided only IP-based data. Such efforts are at “embryonic” stage and “any regulatory requirements or uncertainties now could stifle innovation,” Motorola said.

ICO told FCC that E911 requirements adopted for terrestrial commercial mobile radio service (CMRS) weren’t suitable for MSS. Instead, it endorsed agency’s proposal of national call center as workable way to provide 911 service to MSS callers. “Not only do terrestrial CMRS and MSS providers serve significantly different markets, but their customers have different expectations of the service that they may receive,” ICO said: “Unlike terrestrial CMRS, satellite telephone service is not viewed as a replacement for a consumer’s local wireline or wireless services.” It said MSS systems typically use single gateway to interconnect satellite calls to public switched telephone network (PSTN). So call originating at gateway and terminating at PSAP could be processed by “any number of switches along the way,” ICO said. To route data such as automatic location information from satellite gateway to PSAP could mean retrofitting every switch used to carry MSS calls, company said. Under national call center approach used by Mobile Satellite Ventures (MSV) and Globalstar, ICO said operators routed incoming MSS emergency calls to PSAP based on information that caller provided. Those systems can serve as models, ICO said.

MSV also touted national call center approach and urged FCC to ensure that its rules applied only to company providing MSS to end users and “not the entity merely providing MSS space segment capacity.” MSV stressed it would be neither technologically nor economically feasible to require current-generation MSS systems to meet E911 requirements. MSV said it would need to retrofit existing mobile terminals to include location capability, possibly having to add GPS capability, as well as upgrade gateway earth station and network switch. For next-generation MSS systems, MSV said it might be feasible to comply with E911, “provided any such requirements are clear and reasonable, uniformly applied among all MSS providers and established before it is too late to retrofit operational systems.”

One closely watched issue was whether E911 requirements should extend to multiline telephone systems (MLTS). Avaya said it was working with others on E911 standards for MLTS IP-based telephone and MLTS wireless access. Several states have imposed rules for MLTS to support E911 and others have passed laws that allow local govts. to adopt such requirements, Avaya said. That has led to patchwork of state and local requirements that differ on methods of providing caller ID and location information to PSAPs. “Absent Commission action preempting and occupying the field, the potential exists for these states and municipalities to create a patchwork of incompatible regulatory schemes that would leave MLTS manufacturers in an untenable position,” Avaya said. It said it generally supported implementation schedule outlined in model legislation crafted by National Emergency Number Assn., urging national uniformity in requirements. “Given the rigorous requirements of product development, the institution of a patchwork regulatory framework would drive the cost of MLTS systems beyond the reach of most businesses and possibly require manufacturers to limit their product lines to compatible states,” it said.

Several wireless carriers again urged FCC to require MSS providers to meet E911 requirements as rigorous as they faced. CTIA said caller wouldn’t understand “nuanced difference” between facilities-based, licensed CMRS provider and reseller or MSS licensee because end offering looked same. “While network-based solutions appear problematic in the MSS environment, handset-based solutions would seem particularly promising,” CTIA said. Group said FCC had recognized that adding GPS chipsets to satellite handsets might add as much as $30 to cost of handset and add to its weight and size. “There is no reason to assume that the cost and complexity of adding A-GPS capability to MSS handsets is any greater (and it may indeed be less) than what is required to provide handset-based Phase 2 location capabilities to terrestrial CMRS handsets.”

FCC should “adopt a sense of extreme caution” as it examines whether to extend E911 requirements to equipment- makers and services that aren’t covered under current rules, officials said. “With current E911 implementation efforts continuing to prove time consuming and technically complex, TIA believes new Commission initiatives here would be premature and would divert scarce resources from the ongoing efforts of not only industry but the overburdened PSAPs, as well,” TIA said. Commission sought comment on extent of its authority to require equipment manufacturers, including telematics providers, to meet E911 rules. TIA said FCC authority to adopt E911 regulations came solely from its jurisdiction over carrier-provided services. It said manufacturer didn’t have ability independently to ensure that E911 system in which its equipment was used met FCC rules.