The wireless industry, the Association of Public-Safety Communications Officials-International, and the National Emergency Number Association have asked the FCC to issue guidance on 911 apps for smartphones “and supplemental data solutions” to ensure there is proper coordination of their use among 911 stakeholders.
According to a filing yesterday in PS docket 07-114 reporting on an ex parte meeting, representatives of APCO, NENA, and CTIA and its largest carrier members talked with representatives of the FCC’s Public Safety and Homeland Security Bureau about “the evolving 9-1-1 ecosystem in which smartphone apps and supplemental data solutions can offer features and capabilities designed to supplement and, in some cases, supplant information provided by wireless carriers with 9-1-1 calls. These supplemental data solutions can offer Automatic Location Information (ALI), routing information, or other data relevant to Public Safety Answering Points (PSAPs) for a wireless 9-1-1 call. To maintain the integrity, reliability and resiliency of the evolving 9-1-1 system, the parties encouraged the Commission to issue guidance to ensure that such solutions are reliable and secure for all stakeholders.”
The filing continued, “Recently, companies have begun offering supplemental data solutions to PSAPs to trial in live 9-1-1 environments with real, actual 9-1-1 calls, without the knowledge of the wireless providers operating in trial areas. Evaluating such solutions in live environments may yield important data, but doing so can have consequences for live 9-1-1 calls if not carefully coordinated among 9-1-1 ecosystem stakeholders. For this reason, the parties encouraged the Commission to issue guidance so that any testing, trialing or use of 9-1-1 apps or supplemental data solutions do not have unintended consequences that may adversely impact existing 9-1-1 capabilities or create confusion among PSAPs or members of the public.”
The filing cited a trial of West Corp.’s wireless dispatchable location services and Google LLC’s Android emergency location services (ELS) technologies in Florida, Georgia, and Washington state, and RapidSOS, Inc., and Google ELS testing in Texas, Tennessee, and Florida.
The industry and public safety representatives said the Commission should issue the following guidance:
“9-1-1 stakeholders, including app providers and supplemental data solution providers, should provide reasonable notice to the FCC, appropriate state or local public safety authorities, and wireless providers operating within the area of testing, trialing or use of 9-1-1 apps or supplemental data solutions that may impact live 9-1-1 calls; and 9-1-1 apps and supplemental data solution providers should disclose their testing methodology. Such disclosure will enable stakeholders, including public safety technical experts, wireless providers and the Commission, to assess any potential impact of the solutions. Disclosure will also foster a better understanding of test results to help stakeholders understand the basis for any statements regarding the solution’s capabilities. Test methodologies of such solutions should be disclosed in a manner equivalent to the availability of testing methodologies utilized by the 9-1-1 Location Accuracy Test Bed.”
The filing continued, “Consistent with these guidelines, the parties also discussed how stakeholders can take care to avoid unintended consequences or impact to 9-1-1 services caused by the activities of 9-1-1 apps and supplemental data solutions. Companies offering 9-1-1 apps and supplemental data solutions may not be subject to the same regulations and oversight that the Commission exercises over wireless providers. Accordingly, while wireless providers are responsible for compliance with the FCC’s 9-1-1 rules for capabilities and process within their control, 9-1-1 apps and supplemental data solutions have control over their capabilities and processes, including with respect to any consequences to 9-1-1 services. The parties intend to craft more specific best practices on notice and disclosures for the Commission to consider in offering guidance for any future location and other trials affecting 9-1-1 services. These best practices would help ensure that any new solutions are evaluated fairly and integrated into the 9-1-1 ecosystem in ways that are reliable and secure for stakeholders, including wireless providers, PSAPs and, most importantly, 9-1-1 callers.” —Paul Kirby, firstname.lastname@example.org