Disagreements Continue on Need for FCC Action on 911 Call Routing
The National Emergency Number Association said the FCC should address misrouting of 911 calls to public safety answering points. “Occurrence of 9-1-1 ‘misroutes’ is significant enough to merit action,” NENA said. Most industry players with replies in docket 18-64 urged caution and suggested the FCC wait for an industry-supported solution to emerge. In March, the agency released a notice of inquiry on ways to ensure wireless 911 calls are routed directly to the appropriate call center (see 1803230023). Initial comments were posted in May (see 1805080040).
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NENA said industry concerns about location-based routing are often overstated. “The Commission should not simply wait, as has been suggested, for Next Generation 9-1-1 to fix problems with call routing,” NENA said. “New location techniques are capable of quickly improving location accuracy in the near future. NENA agrees that thorough testing is required before novel routing solutions can be implemented in place of legacy cell sector techniques, these solutions must be pursued with great zeal by all parties.”
Emergency response delays due to Phase I misroutes occur at “significant levels,” said Colorado's Boulder Regional Emergency Telephone Service Authority. “The number of Phase I Misroutes far exceeds the number of 9-1-1 calls in which callers are unable to identify their location and Phase II location information is not received before First Responders are dispatched.” The FCC should require wireless providers to identify the level of misroutes occurring from each existing cellsite or sector, it said. The commission should require carriers consider PSAP boundaries and potential for misroutes when selecting cellsites, the agency said.
Most wireless 911 calls are routed quickly to the appropriate PSAP, so the FCC shouldn’t require wireless providers to modify the existing routing system to support location-based routing (LBR) “in ways that could result in delays for the majority of wireless 9-1-1 calls reaching the appropriate PSAPs today,” CTIA said. LBR should be viewed as part of the transition to NG-911, not a near-term solution for the existing 911 system, it said.
Delays from misrouting wireless emergency calls "can have devastating consequences, but any delays that result in callers hanging up and re-dialing 911 are equally bad,” AT&T replied. The FCC should encourage use of existing technologies, and reject processes that would add delay to routing, it said. LBR potentially could reduce misroutes, but “regulatory requirements are premature,” the carrier said. The FCC instead should seek further study of handset-based technologies that send location data faster than network-based systems.
ATIS said more work is needed before mandates. LBR "could improve public safety in some cases, but … there are significant technical hurdles to overcome,” the standards group said. “Additional industry work is needed to identify higher-accuracy, lower-latency solutions before wide adoption of location- based routing should be pursued.”
There need not be a choice between wireless 911 call routing and NG-911, replied the Texas 9-1-1 Alliance and other Texas entities. “Both E9-1-1 and NG9-1-1 need attention in the current environment, as E9-1-1 and NG9-1-1 are not currently mutually exclusive.”
“Many, perhaps most, 911 calls that are labeled ‘misroutes’ are not actually misroutes,” said the National Association of State 911 Administrators. “Cell sector coverage and PSAP boundary coverage may not match perfectly.” NASNA agreed with CTIA “that existing routing technology can be improved with better communication between PSAPs or 911 authorities and the provider when routing problems are identified, or when a carrier makes changes to its network that may impact 911 call routing.”
Motorola Solutions encouraged FCC action. To ensure the location-based routing makes the best routing decisions possible and reduce the misrouting of 911 calls, require "all providers with available ‘call’ locations make this information available to the routing system through various paths,” Motorola suggested. “To leave room for future advances, providers should not be precluded from also delivering data, including ‘call location,’ to PSAPs via an interface that complies with industry standard protocols."
Comtech said the FCC needs to get a better handle on the extent of the problem. It's "useful to try and quantify the problem in terms of the number of cell site sectors potentially affected, and, perhaps more importantly, the estimated volume of emergency calls from these sectors that have had to be re-routed,” the company said.