It seems as though everybody has something to say about the FCC's Notice of Proposed Rulemaking (NPRM) proposing new rules to address failures that led to 911 outages, even bringing together some wireless carriers that usually are at odds with one another.
In its NPRM, the commission proposes specific rules designed to address failures leading to recent multi-state 911 outages, based on an October 2014 report of the Public Safety and Homeland Security Bureau. The FCC is also proposing additional mechanisms designed to ensure that the 911 governance structure keeps pace with evolving technologies; comments were due this week, with reply comments due by April 21.
According to AT&T's (NYSE: T) filing, the commission is proposing a sweeping extension of its authority over the entire 911 ecosystem, and the proposed expansion of the rule and intrusion into local and state governance of 911 systems is "unwise, unnecessary, and, given the fact that the ink is barely dry on the new 911 Reliability Rules, premature."
AT&T says that a rush to expand the 911 Reliability Rules will be "costly, burdensome, and, possibly, unworkable."
Historically, wireless 911 networks have been bifurcated at the selective router, which routes the call to appropriate public safety answering point (PSAP), with wireless carriers responsible for maintaining the service and network up to the selective router while other entities, like iLECs, 911 service providers and PSAPs among them, maintain the service and networks from the selective router to the PSAP, T-Mobile US (NYSE:TMUS) wrote in its filing.
"Although we certainly appreciate commission interest in examining the need for additional requirements, there is no clear indication of widespread 911 outages due to problems with the wireless portion of the network," T-Mobile said. "Therefore, it appears unnecessary to impose additional regulations on CMRS carriers at this time."
T-Mobile said the central premise underlying the NPRM is that the 911 network is being compromised by a failure to make necessary investments and the decreasing role being played by originating service providers (OSPs) in the design and maintenance of the 911 network. "Although this premise might accurately reflect the situation in parts of the 911 ecosystem, it does not hold true for the wireless industry," according to T-Mobile.
T-Mobile historically has purchased, operated and maintained the equipment necessary to provide 911 functionality, rather than outsourcing it. For example, it bought two Gateway Mobile Location Centers (GMLCs) and, to ensure resiliency, located them in geographically distant locations; the GMLCs were then connected into the T-Mobile network using redundant lines. The company also invested in extensive alarming capabilities that monitor the performance of the T-Mobile side of the 911 network.
The Competitive Carriers Association (CCA) points out that in most instances, wireless providers deliver a 911 call from the user to the cell tower, at which point it is delivered directly to the wired network and routed, via another provider, to a 911 call center. Wireless providers and their networks usually have not been the driver behind 911 call failures or 911 system outages, CCA said. Plus, rules already are in place requiring wireless providers to file reports regarding outages and governing their responsibility to provide reliable 911 call delivery to PSAPs.
During Hurricane Isaac, CCA member C Spire did not experience any significant service outages because it had taken preemptive measures to secure its network before the storm. CCA says while the pace of technological change is rapid, the FCC should not breed uncertainty by changing the regulatory landscape so quickly.
Verizon posits that at least one of the proposed rules would undermine, not promote, collaborative efforts among service providers and public safety stakeholders because it would create a potential conflict between state regulators/legislatures and state/local 911 authorities. Verizon also says the proposed rules would "chill" industry's support for next-generation 911 (NG911) initiatives because companies would need commission approval to make new service enhancements and other product changes.
Motorola notes that NG911 uses IP-based technologies administered by new routing and database methodologies different from those used in legacy 911 systems. In exercising their oversight over the transition, the FCC and other regulators should first consider promoting new best practices and methodologies tailored to new technologies instead of adopting regulatory approaches based on legacy technologies and methodologies, the company said.
The National Association of State 911 Administrators (NASNA) said any approach the commission adopts in its rules must complement and enhance state and local control over 911 services. NASNA said it is concerned about the commission's proposed rule that would assign the role of 911 Network Operations Center to the entity responsible for the transport of 911 traffic to the PSAP or PSAPs serving a jurisdiction.
In some states, the 911 NOC function is provided by the same entity that provides the transport or is the 911 System Service Provider (SSP), but in others it is not, and in still others, there is more than one NOC monitoring different aspects of the system, NASNA said in its filing.
The National Emergency Number Association (NENA) said revising the commission's rules along the lines proposed in its NPRM would accomplish several goals, such as ensuring that all providers with responsibility for 911 services and facilities would be on notice of their unique public interest obligations and provide a mechanism for state and local 911 authorities to evaluate service provider performance against an objective standard.
However, it also notes concerns on the part of both public and private sectors about the feasibility of some specific proposals, and it urges the commission to consider an alternative, consensus proposal, should one be achieved by relevant stakeholders. NENA says it will actively participate in discussions of such proposals before the commission makes a final decision.
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