Wireless Carriers Doubt Two-Year Time Frame Proposed in FCC Text-to-911 Proceeding
Large wireless carriers questioned the feasibility of implementing the FCC-proposed obligation that all interconnected text services be capable of delivering accurate location information to public safety answering points (PSAPs) within two years. They also held the proposal up to a voluntary industry agreement that was reached last week (see 1411170045), claiming that the rule goes beyond the scope of the agreement, in comments in the text-to-911 proceeding. A Colorado phone service authority asked the commission to address the impact that LTE would have on SMS-text coverage. Comments in docket 11-153 were due Monday.
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Sprint urged the FCC not to move forward with the proposals to require enhanced location accuracy and roaming support. A consensus-based approach is preferable to mandating specific requirements, it said in comments. Public safety organizations that want roaming to be supported within two years “fail to offer viable solutions to the complex technical limitations involved,” Sprint said. The FCC should address concerns raised by CTIA and AT&T that the language of the proposed rule puts unnecessary burdens on text providers, it said. The rule also goes beyond the scope of the voluntary commitment entered into by the four major carriers this month, it said: Mandating additional capabilities “will divert resources away from the deployment of next generation technologies,” it said. The agreement, formed with the National Emergency Number Association and the Association of Public-Safety Communications Officials, was criticized by first responders and some state and local emergency entities for not being inclusive.
The framework seeks to leverage indoor location technologies "increasingly available for commercial applications to deliver to first responders a ‘dispatchable’ location for indoor 911 calls," AT&T said of the agreement. "This approach improves on current technology as well as the solutions proposed by certain vendors that provide only a rough approximation of a caller's location," Joan Marsh, vice president-federal regulatory, said in a statement.
The voluntary agreement was “necessarily limited in scope,” said T-Mobile. That was an effort “to ensure that carriers were not burdened with extensive retrofitting of legacy technologies at a time when all parties agreed that the biggest priority should be moving forward to implement NG911,” it said of next-generation 911. A viable roaming solution will take much longer than two years to implement and deploy, it said. If the FCC moves forward with a roaming mandate for interim SMS-to-911, any obligations must account for the realities of implementation and deployment “as well as ensure carriers are not overly burdened with backwards-looking obligations when all stakeholders should be focusing forward on NG911 deployments,” it said.
The Competitive Carriers Association cautioned against adopting rules prematurely and discouraging voluntary industry agreements. There are multiple technical and implementation challenges with respect to enhanced location information and roaming for text-to-911, it said. There should be an efficient waiver process for providers who can’t deploy technical solutions for text-to-911 within a mandated time frame, it said. The association urged against discouraging voluntary agreements within the industry. Voluntary efforts will be stifled if the FCC codifies these agreements or imposes “onerous requirements that may not be able to be met,” it said. CCA added that such agreements should work for large and small carriers.
Boulder Regional Emergency Telephone Service Authority (BRETSA) agreed with the FCC decision not to adopt voluntary agreements as safe harbors. Establishing such safe harbors would result in “an unworkable collection of diverse requirements applicable to different providers,” BRETSA said. T-Mobile’s concerns that PSAPs may not timely return a questionnaire regarding their preferences for delivery of text-to-911 messages appears to be misplaced, it said. Once the FCC has established the database of PSAPs that are receiving text-to-911 messages, and PSAPs request delivery of such messages, “it would be improper for T-Mobile or any other provider to require that the PSAPs also complete questionnaires prior to provisioning text-to-911 service,” it said.
Verizon and Verizon Wireless urged the commission to reject proposals from commenters asking to extend service providers’ obligations to accommodate third-party text message services “in a manner that would contradict the policy framework the commission adopted just months ago,” they said. The record confirms that device operating systems, not technologies controlled by CMRS providers, “remain the principal factor necessary to enable access to messaging APIs,” it said. As with roaming requirements, any new requirements for location accuracy should be forward-looking and limited to LTE-enabled and IP-enabled devices, it said. If the FCC adopts new near-term interim location accuracy rules for text-to-911 service, it should enable service providers to comply through the availability of the existing commercial LBS-based solutions used today under the J-STD-110 industry standard, it said.
Microsoft urged the FCC to refrain from extending text-to-911 obligations. It isn’t realistic to impose accuracy requirements that result in enormous costs on free apps and services provided by small companies from every corner of the globe, it said. The FCC would have difficulties “enforcing Phase II-like E911 accuracy requirements against small Internet companies located outside the U.S.,” it said. Attempting to do so by imposing onerous obligations on over-the-top apps and services “would put U.S. companies at a competitive and financial disadvantage as they would strive to comply with obligations that their competitors would not,” it said.