Some Disagreements Remain on Implementing Location-Based Routing
Wireless industry commenters and public safety groups agreed on the need for some flexibility, in reply comments on an FCC proposal that carriers more precisely route wireless 911 calls and texts to public safety answering points through location-based routing (LBR). Disagreements remain on some implementation details (see 2302170044). Comments were posted Monday and Tuesday on an NPRM commissioners approved 4-0 in December (see 2212210047).
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
The record demonstrates that carriers “should have the flexibility to implement LBR for text-to-911 in ways that are consistent with their unique network and handset configurations,” CTIA said. “At most, the Commission should require wireless providers to route texts to 911 on the basis of ‘best available location information’ and subject to a valid PSAP request,” the group said. CTIA noted nationwide providers are “well on their way to deploying LBR capabilities within their IP-based networks.”
Non-national providers haven't determined “the actual cost and time required to implement LBR,” said the Boulder Regional Emergency Telephone Service Authority. The FCC should require these carriers “to implement LBR within six or twelve months, but grant waivers or extensions upon showings of the actual costs of and impediments to deployment of LBR by these providers,” the authority said.
“In general, there is significant consensus in support of the spirit of the Commission’s proposed rules for location-based routing and IP-based origination for 9-1-1 calls,” said the National Emergency Number Association, opposing a PSAP readiness test. LBR should be required on a nationwide basis “until ubiquitous end-state” next-generation 911 is fully deployed, NENA said. Disagreements remain whether LBR should be initially deployed nationwide “or based on a ‘readiness’ test and/or upon request by the PSAP or 9-1-1 authority,” NENA said. It also cited a need for clarity on some of the terminology used by the FCC and questions about whether the requirements should apply to interim SMS- and MMS-based texts to 911.
The Rural Wireless Association said small carriers will need 18 months longer than the FCC's proposed timelines to implement LBR for voice calls and texts to 911. Some comments supported deadlines proposed in the NPRM but did so without showing that compliance by small carriers is possible, RWA said. The Competitive Carriers Association “correctly concludes” that LBR “will be economically and practically infeasible in the eighteen months that the Commission proposes to allow for implementation by non-nationwide carriers,” the group said.
“As the comments in this proceeding demonstrate, rules requiring a blanket deployment of location-based routing for calls and texts-to-911 are not appropriate at this time,” CCA said: If the FCC adopts rules, it should approve deployment benchmarks “based on carrier size and PSAP readiness rather than extremely aggressive uniform timelines nationwide.”
Initial comments show “significant support for Verizon’s recommended implementation approach -- deployment on a per-PSAP basis, using flexible outcome-oriented accuracy and other standards for LBR,” Verizon commented: “To the extent any wireless providers face implementation challenges, including smaller providers, they should be free to establish alternative deployment timetables through good faith cooperation with the PSAPs involved.”
The rules should take into account the challenges of serving Alaska that are “not present in the 48 contiguous states or Hawaii,” the Alaska Telecom Association said: “Moreover, 911 issues that would otherwise support LBR largely do not exist in Alaska. The group noted Alaska “has few of the jurisdictional boundary issues that lead to an increased likelihood of misroutes because it does not have dense metropolitan areas that may be served by several PSAPs with potentially overlapping boundaries.”