Public Safety Groups Express Concern about Exclusion of 911 Calls from Reports

Three public safety groups say they are concerned by the wireless industry’s plan to exclude certain calls from quarterly 911 live call data reports mandated in the FCC’s 911 indoor location accuracy order adopted last year (TRDaily, Jan. 29, 2015). In an ex parte filing yesterday in PS docket 07-114, the Association of Public-Safety Communications Officials-International, the National Emergency Number Association, and the National Association of State 911 Administrators responded to a recent filing by CTIA concerning a proposed template for reports and details on calls that carriers plan to exclude. The first reports are due Feb. 3, 2017.

“APCO, NENA, and NASNA worked with CTIA in an attempt to ensure the reports are consistent with the Commission’s rules, and thus reflect as closely as possible the actual numbers of 9-1-1 calls acted upon by PSAPs,” the groups said in their filing. “Unfortunately, CTIA’s filing indicates that the carriers intend to unjustifiably exclude a significant number of calls.  APCO, NENA, and NASNA are particularly concerned that the carriers intend to exclude 9-1-1 calls made from roaming handsets and non-service initialized (NSI) devices.

“The Commission’s location accuracy rules make no exceptions when it comes to the collection and reporting of aggregate live 9-1-1 call location data: ‘CMRS providers … shall identify and collect information regarding the location technology or technologies used for each 911 call in the reporting area.’ As the Commission explained, ‘[w]e will use this data as a complement to the test bed in determining compliance,’ and the corresponding indoor location accuracy standards speak to ‘all’ wireless 911 calls. PSAPs do not have exclusions — they must be able to process all 9-1-1 calls, including by obtaining location information, regardless of whether the caller is roaming,” the groups said.

“Similarly, PSAPs are expected to process all NSI calls, which may be delivered with location information, in some cases, and can constitute a significant portion of total call volume,” the filing added. “Many PSAPs have policies in place that require them to expend significant and painstaking resources tracking down the location of NSI callers, and thus these calls should be counted for this reason as well. Inconsistent with CTIA’s proposal to exclude NSI calls from the reports, a number of carriers continue to advocate for the Commission to retain the call-forwarding requirement, arguing that identifying such calls as NSI is problematic. Accordingly, carriers should have no basis to exclude calls from NSI devices.”

APCO, NENA, and NASNA also complained that “CTIA also seeks to exclude calls delivered to PSAPs that cannot yet accept wireless Phase II location data. CTIA has asserted to APCO, NENA, and NASNA that there may be a valid technical basis supporting this exclusion. APCO, NENA, and NASNA would thus recommend that the Commission request CTIA to supply this technical basis into the record of this proceeding. Similarly, and as noted above in terms of the unmet request for a definition from the industry of ‘roaming,’ the Commission should request CTIA to supply definitions of ‘gray market devices’ and, with respect to excluding test calls, describe what limitations CTIA intends by qualifying the test call exclusion with the phrase, ‘to the extent they can be identified.’”

The filing continued, “Notwithstanding what may be permissible to exclude under the Commission’s rules, the Commission should require the carriers to report the number of calls that they exclude, along with clear definitions, for each category. Given that one of the contemplated purposes of the reports on live 9-1-1 call data was for the Commission, APCO, NENA, and NASNA to be able to assess trends in positioning performance over time, it is critical that the reports contain comprehensive and useful data.”

CTIA declined to comment today on the filing by the public safety groups. — Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily