The FCC should avoid imposing regulations and rely...

further comment on issues including whether to impose a text-to-911 mandate on interconnected over-the-top (OTT) text providers like Apple’s iMessage or Samsung’s ChatOn. Carriers, the Association of Public-Safety Communications Officials and the National Emergency Number Association reached agreement on emergency texting in December 2012. Among the provisions, Verizon Wireless, AT&T, Sprint and T-Mobile agreed to make their networks capable of transmitting texts to 911 call centers by May 15. The FCC should “continue to encourage voluntary industry initiatives to support text-to-911 services,” CTIA said in the new filing (http://bit.ly/1emHsyX). “The Commission should not codify or attempt to enforce the Carrier-NENA-APCO Agreement. Rather, it should allow stakeholders the flexibility to develop creative, voluntary solutions to evolving text-to-911 issues.” CTIA assured the FCC the industry “remains steadfast in its commitment” to next-generation 911. NENA said the FCC should make sure that receiving emergency texts is not overly complicated for public safety answering points (PSAPs). “NENA continues to believe that a reasonably uniform, technology-neutral approach to the 911 obligations of text Originating Service Providers (OSPs) will best serve the Commission’s statutory mandate with respect to the preservation of life and property,” NENA said (http://bit.ly/PHal36). “Consistent with that principle, NENA supports the Commission’s proposal to apply a December 31st, 2014 deadline for the implementation of service support for Text-to-911 by all covered text OSPs.” NENA also said the FCC should impose a unitary text-to-911 service request model “to reduce burdens on service providers and PSAPs alike.” Microsoft said the FCC shouldn’t impose the same requirements on non-interconnected OTT text message services as it does on interconnected services. “Such an expansion presents a host of challenges -- on technical, competitive, and enforcement fronts -- that must be fully considered before it is implemented,” Microsoft said (http://bit.ly/1h9fuLS). “Unlike traditional communications services that are tethered to a network and, as a result, have high barriers to entry and require a significant investment of time and capital, apps are easily developed and rapidly enter the marketplace from anywhere on the planet that an app developer has Internet access and the ability to publish her app in an app store.” Among the questions Microsoft raised is the fairness of imposing a mandate on U.S. app developers but not on developers living abroad.