Industry Collaboration Critical to NG911, Carriers Tell FCC

CTIA said the FCC should take a long view and focus on a “long-term” solution for next generation 911. Short message service (SMS) should not be viewed as an “interim solution,” CTIA said. “The record developed in response to the NPRM reflects the substantial difficulties of mandating an interim text-to-911 solution and demonstrates that the Commission is at a critical juncture in leading the U.S. towards an NG911 system,” the group said (http://xrl.us/bmrmug). “CTIA believes that the Commission should focus its resources on the full and complete development and deployment of a NG911 system.”

A good model for devising a short-term fix is the voluntary, collaborative process followed by the FCC that is developing a system for carriers to send emergency alerts to their subscribers through the Commercial Mobile Alert Service, CTIA said. “By using this and other collaborative processes as a blueprint, the Commission can promote the development of technically and economically feasible solutions for NG911, including text-based communications to 911,” CTIA said.

The record shows the FCC should allow “service providers to offer interim solutions, including SMS-based solutions or IP Relay, on a voluntary basis,” Verizon and Verizon Wireless said. “Proposed SMS-based solutions would be time and resource intensive and divert resources from the deployment of IP-enabled LTE and NG911 technology that will more effectively improve the accessibility of emergency services for individuals with disabilities,” Verizon said (http://xrl.us/bmrmvh).

Sprint Nextel also raised concerns about the viability of SMS as an interim solution. “Should the Commission decide to move toward requiring an interim text-to-911 solution, Sprint recommends that the Commission look to IP Relay as an appropriate solution or facilitate development of an interim solution through an industry standards group created expressly for this purpose,” the carrier said. There are “fundamental problems” with SMS, Sprint said (http://xrl.us/bmrmwa). “Location information is not included with SMS text messages and would not be available for [call center] routing or position determination for dispatch purposes. Moreover, CMRS providers would have to determine how to prioritize SMS-to-911 calls, since currently SMS messages do not receive ‘head of the queue’ status on carrier networks.”

Comments confirm that IP Relay is the only viable solution that could be put in place relatively quickly, T-Mobile said. “SMS-to-911 is not a SIP-based solution, and thus is a technological dead end that will have to be replaced for NG911 deployment,” T-Mobile said (http://xrl.us/bmrmwt). “Implementing any kind of direct SMS-to-911 capability will thus divert both public safety and carrier resources from the development and deployment of long-term text-to-911 solutions.” SouthernLINC Wireless said the “costs and drawbacks” of SMS-to-911 “far outweigh the potential benefits,” in its reply comments (http://xrl.us/bmrmw9).

Given the technology cycles in the telecom industry, an interim solution is likely to be in place for as long as 10 years, NENA said. “It is important that the Commission strike a careful balance between the need to deploy some text solution quickly, the need to deploy solutions that are sufficiently robust and full-featured to adequately meet the needs of the public and the public safety community over the next decade, and the need to conserve precious and increasingly scarce public resources,” NENA said (http://xrl.us/bmrmyv).

The FCC should consider operational issues posed by any short-term fix, NENA said. “For example, IP-relay text could require little retraining for telecommunicators already accustomed to handling other types of relay calls (e.g., ASL video, foreign language, etc.), but would likely result in significant increases to call length and round-trip lag time,” NENA said. “Direct SMS and application-based text, by contrast might require significant additional training covering everything from basic familiarity with new software packages to esoteric (to some) text abbreviations and jargon, but could yield lower average session lengths and round-trip lag time.” The FCC should also keep in mind the cost to public safety answering points, NENA said. “Because of the high cost of PSAP upgrades and the imminent need to upgrade PSAP equipment, software, and service processes to NG911 capabilities, NENA considers it important that any interim text messaging solution leverage, to the maximum extent possible, existing assets and service processes."

"There are significant, inherent limitations with the use of SMS” for texting to 911 and “other transmission methods would be far more effective in the long term,” APCO said (http://xrl.us/bmrmz8). APCO said SMS “should only be promoted for use by those with an inability to use voice communications, whether due to disability, the nature of the emergency, or network congestion.”

The National Association of Telecommunications Officers and Advisors, the National Association of Counties and the National League of Cities said the FCC should keep in mind the costs of needed systems upgrades. “For example, there will be costs associated with equipment and software upgrades, new administrative burdens, and staff training,” the groups said (http://xrl.us/bmrmzy). “In addition, ... localities could lose vital 911 fees and other funding in the event they fail to meet performance mandates due to the increased time necessary to handle text-based calls. In the current financial climate, where local budgets are already stretched thin, the desire to provide enhanced public safety communications services must be tempered by economic realities and balanced against competing budget priorities."

"The challenges associated with direct SMS-to-PSAP communications have been well documented both by the industry and by the Commission,” ATIS said in its reply comments (http://xrl.us/bmrnd4). “SMS messages may be delayed or lost, senders may not receive error messages indicating that such messages have been delayed or lost, and senders do not receive confirmation of the receipt of these messages so there is no way for a sender to ensure that his or her message got through to the intended recipient. These challenges are not a flaw in the SMS technology -- they stem from the fact that SMS messaging technology was not developed to transmit emergency communications.” Proposed SMS-based solutions will require additional capabilities to be effective, ATIS said. “Without automatic location capabilities, for example, the caller would have to provide location information manually when contacting a PSAP. In some cases, callers may not know their exact location.”