Verizon Wireless (NYSE: VZ), AT&T Mobility (NYSE: T), Sprint (NYSE: S) and T-Mobile US (NYSE:TMUS) think that over-the-top messaging application providers should be solely responsible for complying with any requirements the FCC places on the apps to support text-to-911 procedures. Not surprisingly, they argued that wireless carriers should not be involved in ensuring OTT compliance.
Representatives from the Tier 1 carriers met with FCC staff members on July 29 to sketch out their position on the issue, according to an FCC filing. The FCC plans to vote at its Aug. 8 open meeting on an order that would set deadlines for all wireless carriers and OTT messaging players to support text-to-911, likely by the end of the year. The FCC also plans to solicit comment on potential improvements to current text-to-911 technology, such as through better location information.
Specifically, the carriers want to the FCC to ensure that "compliance with any text-to-911 obligation on OTT providers would be the sole responsibility of the OTT provider" and that "any requirements for wireless service providers would apply only insofar as they offer SMS via a legacy wireless network. They would not, for example, apply to wireless service providers' IP-enabled text messaging services and networks."
Verizon, AT&T, Sprint and T-Mobile started offering text-to-911 service in mid-May under an agreement they struck in December 2012. However, the FCC has cautioned that "the ability to contact 911 using text is only available on a limited basis in a few markets. For this reason, you should not rely on text to reach 911."
According to the FCC, as of June 30 the service was available in only several dozen towns and municipalities as well as across the entire states of Maine and Vermont. Since September 2013, wireless carriers and certain other text messaging providers have been required by the FCC to send an automatic "bounce-back" message to any consumer who tries to send a text message to 911 where the service is not yet available.
The carriers also want the FCC to make clear that "any rule would be limited to an obligation to not impede the transmission or delivery of 911 text messages from covered OTT text messaging users," as long as the 911 text message "is technically compatible with the wireless service provider's SMS networks and devices and in conformance with applicable technical standards," and "the user and the device are covered by a service plan that includes SMS."
Further, the carrier want to make sure that the rules do not "specify or require any contractual or other commercial terms or conditions to govern the relationships between OTT providers and wireless service providers," or presume that a direct commercial relationship between carriers and OTT providers is necessary. Instead, covered OTT providers "will likely need to work directly" with companies such as Apple (NASDAQ: AAPL), Google (NASDAQ: GOOG), Microsoft (NASDAQ: MSFT) and BlackBerry (NASDAQ:BBRY), which supply smartphone operating systems.
OTT players should also be responsible for educating consumers about using their services to send 911 text messages, the carriers said, "otherwise, allowing OTT text messaging applications to use SMS capability to satisfy their text-to-911 obligation may create customer confusion and defeat the purpose of allowing users to reach 911 via their preferred OTT application. For example, OTT providers may want to educate end users that the bounce-back message or the PSAP's return message may appear in the device's SMS interface, rather than the OTT application's interface."
"These parameters will provide OTT text messaging providers interested in pursuing an SMS-based solution with a meaningful option for implementing text-to-911, while also recognizing service providers' limited role in today's wireless device ecosystem," the carriers wrote. "They would provide OTT text message providers with incentives to work directly with OS providers and device manufacturers to develop device-level capabilities compatible with existing wireless networks. They also would provide OTT providers with appropriate incentives to develop their own text-to-911 solutions that are not dependent on the underlying legacy wireless networks."
- see this FCC filing
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