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FCC mandates text-to-911 for all carriers and some OTT providers like iMessage, but big gaps remain

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The FCC voted to require all wireless carriers and certain over-the-top messaging providers support text-to-911 services by the end of the year. However, only a tiny number of 911-answering centers across the country currently support text-to-911 service, and wireless carriers are worried that too many OTT messaging apps will be exempted from the rules because of technical concerns.

The FCC voted 3-2 to approve the new rules, which the commission said will ensure that all wireless carriers and certain IP-based text application providers like Apple's (NASDAQ: AAPL) iMessage are prepared to support text-to-911 by the end of 2014. After then, if a 911 call center requests text-to-911 capabilities, text messaging providers will have six months to deploy the service in that area.

Verizon Wireless (NYSE: VZ), AT&T Mobility (NYSE: T), Sprint (NYSE: S) and T-Mobile US (NYSE:TMUS) started offering text-to-911 service in mid-May under an agreement they struck in December 2012. However, smaller carriers and OTT messaging providers were not covered, and the FCC's new move brings them into the fold.

"Texting is now as important a function on a mobile device as talking. Some of those text messages are cries for help," said FCC Chairman Tom Wheeler. "Some of those are from people who can't hear or speak. Call 911 if you can. But if you can't, what are you going to do?"

The FCC's three Democratic commissioners hope the new rules will spur more Public Safety Answering Points (PSAPs) to support text-to-911 service. They said the new rules represented a significant improvement in public safety services for the deaf, according to The Hill.

"This is about people's lives," Wheeler said in impassioned remarks defending the order. "This is about the expectation that our first responsibility is to provide for the safety of Americans. This is a step to continue to fulfill that responsibility and it is not the final step."

However, according to the National Journal, only 122 counties in 18 states (including the entire states of Maine and Vermont) are able to handle text messages to 911. If a PSAP cannot handle text-to-911, carriers are required to send a "bounce back" message telling the subscriber to call 911.

Republican Commissioner Ajit Pai hammered this point home in his statement noting his vote against the rules. "Less than 2 percent of our nation's 911 call centers…accept text messages. So in your moment of need, if you try texting 911 in over 98 percent of the country, you won't reach emergency personnel no matter what application you use," he said.

Texting to 911 can be useful in situations where a natural disaster has made it tough to complete a wireless voice call or if a person is in a dangerous situation where they can't speak. However, there are many limitations to text-to-911, including the fact that it's often quicker to get information across to 911 dispatchers via calling, and the PSAPs often need more information about the situation and the location of the texter because text messages do not provide exact locations.

In addition to the new rules, the FCC is also seeking comment on the continued evolution of text-to-911, including the delivery of location information and support for text-to-911 when roaming.

Pai said the rules may actually set back the FCC's transition to Next-Generation-911 systems that use IP-based protocols and not SMS.

"By contrast, SMS has inherent limitations that, for 911 purposes, render it inappropriate for use as anything other than an interim, stop-gap measure. SMS messages can be delayed, lost, or delivered out of sequence," Pai said at FCC's open meeting. "I've experienced that when I send SMS messages, and I'm sure many of you have as well. These limitations might not matter for everyday communication. But they can have serious consequences in an emergency."

Another hiccup in the rules is that the FCC has limited authority to tell OTT messaging apps how to design their apps. The rules also only apply to Internet-based text messaging services that are set up to send texts to phone numbers, which could confuse consumers who do not know the difference between apps that do that and those that don't.

Pai said the FCC's rules leave too many fundamental questions unanswered. "Who is responsible for transmitting bounce-back messages to consumers now that over-the-top apps will be invoking the device's native SMS software--the OTT provider or the wireless carrier?" he asked. "Will any reply messages from a PSAP be delivered to the OTT app or will it go instead to the device's native text messaging app? Will consumers sending a 911 text from their OTT app really need to press send twice--once when they use their OTT app and then a second time when that app invokes the native SMS--as the item suggests? Will the FCC allow a migration from SMS to IP-based messaging if the only feasible method for delivering OTT texts relies on the SMS network? This decision offers no guidance at all on these and many other technical issues."

Bob Quinn, AT&T's senior vice president of federal regulatory, touched on the issues related to OTT apps in a company blog post ahead of the FCC's vote. "The problem is that a lot of the OTT apps actually used by consumers don't use telephone numbers but are instead 'closed' applications which only allow you to communicate with others who have downloaded the app," he wrote. "Moreover, even the applications that have integrated with SMS, like iMessage, only fit the definition so long as the SMS technology remains in service; once that technology is retired, those apps no longer fit the definition. So the 'Interconnected Text Provider' extension doesn't capture some of the larger applications out there and most of the OTT apps it does capture will lose those requirements when SMS technology goes away. The Commission has put off consideration of those issues into a Further Notice.  Given that it has some hard decisions to make in that area and seeing how this market is in throes of a dramatic evolution, more analysis is probably not a bad thing."

For more:
- see this release
- see this Re/code article
- see this The Hill article
- see this National Journal article

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