FCC Announces Agenda for Alerting Roundtable

The FCC’s Public Safety and Homeland Security Bureau today announced the agenda for a workshop on emergency alerting that is scheduled for next Tuesday. The event is scheduled to run from 1 p.m. to 4:30 p.m. FCC Chairman Ajit Pai will deliver opening remarks, and two panels will focus on (1) the benefits of training and best practices for testing, and (2) coordination and partnerships. – Courtesy TR Daily 

O’Rielly: Congressional Action on 911 Fees Would Help

WILLIAMSBURG, Va. — FCC Commissioner Mike O’Rielly says that while the FCC is “having some success” in getting states to stop engaging in 911 fee diversion, legislative action by Congress to address the issue would be helpful.

Commissioner O’Rielly was responding to a question about the extent of the FCC’s legal authority to address the issue during a panel session with fellow Commissioner Brendan Carr at a Federal Communications Bar Association seminar here on Saturday.  Commissioner O’Rielly recently sought and received assurances from the governor of Puerto Rico that the territory will not divert future 911 fees for non-911 purposes before the commissioner voted to allocate $750 million in universal service funding to support the restoration and expansion of communications networks in Puerto Rico (TR Daily, May 4).

Asked by moderator Scott Blake Harris, chairman of Harris, Wiltshire & Grannis LLP, whether Commissioners hear different things from stakeholders when they travel around the country than they do in Washington, Commissioner Carr said, “We get to see both sides of the digital divide.”  He recalled meeting “farmers with coffee mugs full of USB drives” that they use to download data from drones because the drones can’t get a wireless connection to the Internet during their daily travels across the farmers’ acreage.

In response to a question about 5G wireless deployment, Mr. Carr emphasized that beyond spectrum and wireless facilities, an “important third piece is having a skilled workforce not only to deploy these networks” but to make use of the networks.  He added that while large companies may be able to “self-provision” training workers in these skills, it’s important to think about “reorienting” Department of Labor programs to support medium and small companies in worker training.

Mr. Harris asked whether the FCC’s enforcement process is “as effective as it should be.”

Commissioner Carr said, “I think we’re really heading in a good direction on the Enforcement Bureau and the leadership we have under Rosemary [Harold, the bureau chief].”  He added that robocalling and pirate radio have been “elevated” as enforcement priorities, while the agency is “reorienting away from seeking headlines” by issuing attention-grabbing large fines.

Mr. Harris asked whether the greater public prominence of FCC issues which has burned FCC Commissioners into “public personalities in ways they weren’t before” has had an impact on the agency’s decision-making process.

“I am more noticeable than I used to be,” Commissioner O’Rielly acknowledged, noting that comedian “John Oliver … called me the most boring man in America.”  He said that he had recently been recognized by a member of the general public at an airport.  However, he said, “I really try to stay grounded in the issues.”  Still, the public prominence can help in trying “to move issues in the right direction,” he said.

Commissioner Carr said that “a lot” of the debate over net neutrality has moved “the wide grounds [where] reasonable minds [can] disagree,” adding, “I think every member of the Commission has received death threats over that.”

“I think some of the characterization that we saw out there didn’t do the issue credit, didn’t do the American public credit,” Mr. Carr said.

From the audience, Julie Kearney, vice president–regulatory affairs for the Consumer Technology Association, asked what advice they would offer the yet-to-be-nominated individual who will take Commissioner Mignon L. Clyburn’s place on the FCC.

“I look forward to get to know that individual,” said Commissioner O’Rielly.  “If I’ve done something they think is wrong, come and talk to me about it,” he continued, adding, “My family was always don’t stab me in the back, stab me in the front.”

Commissioner Carr said that Commissioner Clyburn is going to be hard to replace, praising how she would be ready to discuss each new issue, despite what disagreements might have occurred on the last decision, and “not just go to corners on every issue.” —Lynn Stanton, lynn.stanton@wolterskluwer.com


Public Safety Advocate: Public/Private Partnerships

Before FirstNet, those in the public safety community who were working toward the goal of a nationwide public safety broadband network (NPSBN) understood that even if Congress was convinced to offer up the additional 10 MHz of 700-MHz spectrum known then as the D-Block, and even if it reached deep into the government’s pocket and came up with $billions to fund the build-out and operation of the network, the public safety community was not capable of putting together a nationwide network. Nor was the federal government based on the failure a number of years ago of the nationwide Land Mobile Radio Network that was designed to bring together all the federal agencies that used LMR. That network, known as iWIN, was bid and rebid and failed to be built except for a portion in the Northwest.

The decision to ask Congress to form a public/private partnership between the federal government and a private company to build the FirstNet network seemed to be the answer to this dilemma. This would be the largest public/private partnership ever attempted and some predicted it would fail. In spite of that, the project moved ahead and instead of Congress putting in all the funds, it settled on a starter fund of $7 billion, which sounds like a lot of money. However, when the dust settles on FirstNet’s first five years of build-out, the cost of the network will be in the $30 or $40-billion range. Further, in order to avoid using federal funds for this starter kit, Congress elected to take the seed money from the next spectrum auction so it would not impact, in any way, our national debt, and citizens who did not agree with the concept would not be able to accuse Congress of using tax dollars for this project.

FirstNet was created in February of 2012 and it took until 2017 for a bidder to be accepted and to get the project off the ground. The best news for public safety was that when the bid was awarded to AT&T, it announced it would not merely build out yet another network using only the FirstNet spectrum, which would take years to complete. AT&T was ready to make all of its LTE spectrum available to agencies in any state that opted into the project. By the end of 2017, that included 100-percent of the states, plus Washington DC, and the six territories.

Today, the network is in use,FirstNet built by AT&T has signed up more than 650 agencies in 48 states and six territories, and the build-out of Band 14 (FirstNet’s spectrum) has begun in earnest, only a year after AT&T became the winning bidder. In the days before FirstNet, no one would have thought FirstNet, complete with priority, pre-emption, and its own Evolved Packet Core (EPC) would have been this successful and in operation this quickly after the bid award. AT&T’s vision to use its own spectrum and to build out Band 14 over time, and to add public safety-grade functions over time, makes a lot of sense and is providing great value to the public safety community right now along with the ability for agencies on board to learn, experiment, and help develop the applications needed in the field.

Public-Private Partnerships

FirstNet (built by AT&T) and the FirstNet Authority (reporting to the NTIA) have worked through a number of issues and are now working well together. It should also be noted that FirstNet (built by AT&T) is also making use of rural network operators as required in the agreement and has entered into agreements or partnerships with a multiplicity of other vendors. It is a shame that on the federal government side the only partnership is with AT&T. What do I mean by that? I am talking about parlaying what FirstNet (AT&T) is doing, and the requirements to cover rural areas as quickly as metro and suburban areas. The federal government has not reached out to other agencies including its own (NTIA) to add partners to the mix for rural broadband.

Rural Broadband Gaining National Attention

Rather than extended partnerships, FirstNet continues to be going it alone, even though several sources of government assistance are available. The FCC has its Lifeline funding program for poverty and rural broadband and its Connect America fund, the NTIA has a multiplicity of grants for rural broadband under its BroadbandUSA organization, and the Farm Bureau offers grants as do other agencies. However, as I wrote in a previous Advocate, rural broadband is like a headless horseman. There are legs under it, there is bulk to it from multiple agencies, and Congress has a number of bills in process to augment it. Some states have taken over the idea of working with rural areas since the feds are so disorganized but the fact remains that there is no coordination or master plan.

Plans and Management Are Key

AT&T and the other network operators had a plan before they built out their networks. They assigned priorities, moved quickly, listened to their customers, and added more coverage and capacity as needed. FirstNet already has a huge AT&T LTE footprint though more coverage is needed in some areas, and Band 14 is being built out in a logical manner. The design engineers, site engineers, and other LTE experts are taking direction from those in charge and are filling in the holes and meeting the FirstNet goals, so far, always ahead of schedule.

Why don’t we have real take-charge leadership for rural broadband? When I look at rural America I see it as the many different groups and services that need broadband. These include:

  • Public safety
  • Schools and libraries
  • Students at home after school
  • Medical facilities and remote medicine
  • Farmers and livestock farms
  • Interstates and other roadways
  • To provide communications for the coming autonomous vehicle onslaught
  • Electric and other utilities for automatic meter reading and command-and-control
  • And more

However, those with grants for rural broadband focus on only one element of the list. For example, there have been a number of grants to take fiber to schools and libraries but that does not take care of the students at home. A number of grants have paid for fiber to the home and farm but farmers need broadband that is usable over their entire farmland. Farmers have been using cellular to automate some of their tasks. Analog cellular was the early version of machine-to-machine cellular communications well before it became the Internet of Things (IoT). It seems logical that private/public partnerships can and should be put together to solve all of these issues at once, or to expand on FirstNet Authority/FirstNet (built by AT&T) to provide more broadband to more of these segments.

I am aware that some states and regions are moving forward with a more ubiquitous plan for rural broadband. I also realize it is difficult to bring all the various stakeholders in rural areas together and then to reach a consensus. However, right now we are simply throwing taxpayer dollars at some of these groups and solving broadband connectivity issues in small segments of the rural community. A more centrally focused approach based on federal government grants and low-cost loans, partnered with one or more private sector companies, would go a long way toward addressing our “digital divide” so often mentioned in the press and in Congress.

Radio and Fiber

Some in various federal, state, and local agencies still believe fiber alone is the answer to rural broadband. Yet most of us know fiber to a central location followed by wireless broadband for distribution is more cost effective, covers larger areas, and is, I believe, the key to solving rural connectivity issues. Fiber to a school carries broadband to that school. If that broadband is then pumped through a broadband wireless pipe it can serve entire neighborhoods. In places where running fiber to a central location is too costly, there is microwave for bridging the gap. However, a fiber-only solution for rural America means that portions of our rural population will never have access to broadband.

How to Proceed?

I do not have the answer to how to convince people to work together to make rural broadband a reality. Certainly, where FirstNet is built out public safety gains broadband access. Also, as a side benefit, the citizens in that area will finally have broadband service. FirstNet is required to provide broadband service for the public safety community in rural areas but that does not mean, according to FirstNet Authority’s RFP, that every rural citizen will also be covered and have access. In order to accomplish that goal, we need to expand this very successful private/public partnership or we need to form a new one dedicated to combining all the resources the feds have made available in the form of grants and loans.

One big hurdle could be overcome if the various agencies that offer grants and loans pooled their resources and did not, as many do today, prohibit any entity that has received one grant or loan from being considered for another, even from a different agency. Solving a problem has always been about teamwork. FirstNet is a team of dedicated folks in the federal and private sectors, and it is working well. Yes, there were some rough spots and it did take a while before the two parties became a well-oiled machine. It did so because everyone involved shared the vision of taking public safety’s communications into the 22ndcentury.

What will serve as the catalyst for expanding the FirstNet mandate or using FirstNet as a starting point and forming one or more partnerships to build on its accomplishments? The federal government reminds me of a consulting assignment I once had for an international company that was the leading supplier of PC processors. I was asked to find all the groups and divisions that were working on some form of wireless technology and write a report to management so they could be brought together under one management structure. I wrote the report but nothing ever happened. When I asked the vice president who had hired me he explained that not one program I had identified was interested in working with others on common goals because each manager had his/her own set of milestones they were judged on when it came time for a promotion and/or raise. The unfortunate thing about this is that the company could have become a major force in the wireless arena had it chosen to work in unison.


We continue to work with counties and states on rural coverage issues, but it certainly would be easier for everyone involved if there was a centralized clearinghouse of rural funding, planning, and deployment. The largest private/public partnership in the form of FirstNet has been hugely successful, why does it not serve as a model for another to work hand-in-hand with FirstNet to eliminate, once and for all, the Digital Divide?

Some public safety folks feel that FirstNet is all about public safety and they are right. However, with priority, pre-emption, and a special core for public safety, I see no danger in using the spectrum to provide broadband for citizens in these rural areas when public safety is not using it.

Andrew M. Seybold
2018 Andrew Seybold, Inc.©

Subcommittee Approves FY 2019 CJS Bill

The House Appropriations Committee’s Commerce, Justice, science, and related agencies subcommittee today approved by voice vote a fiscal year 2019 appropriations bill. Despite the voice vote, Democrats complained about portions of the bill, including gun riders. Under the bill, the National Telecommunications and Information Administration (NTIA) would get $39.5 million for FY 2019, the same the amount it received for FY 2018. The Trump administration had requested $33.6 million for NTIA for FY 2019 (TR Daily, Feb. 12). The U.S. Patent and Trademark Office budget for FY 2019 would total $3.37 billion, all of which would be covered by fee collections. Its budget totaled $3.5 billion for FY 2018, and the Trump administration asked for $3.4 billion for FY 2019. – Courtesy TR Daily

Senate Committee Advances DHS Undersecretary Nomination

The nomination of Christopher Krebs to become undersecretary–national protection and programs at the Department of Homeland Security was approved late yesterday by the Senate Homeland Security and Governmental Affairs Committee.  As senior official in the unit, Mr. Krebs has been performing the duties of the vacant post, which oversees the National Protection and Programs Directorate (NPPD).  He previously was director–cybersecurity policy at Microsoft Corp. and worked at DHS as a policy adviser during the George W. Bush administration. – Courtesy TR Daily

Lawmakers Introduce Non-Emergency Mobile Number Bill

Reps. Susan W. Brooks (R., Ind.) and Anna G. Eshoo (D., Calif.) today introduced the National Non-Emergency Mobile Number Act (HR 5700), which would direct the FCC to take steps to facilitate the creation of a unified wireless short code for critical, but non-emergency, situations on highways.

“This commonsense, bipartisan bill ensures our 911 telecommunicators can focus on responding quickly and efficiently to phone calls reporting time-sensitive and urgent emergency matters,” said Rep. Brooks. “When people are traveling from state to state, the short non-emergency number people call to report an instance deserving of attention but may not classify as an emergency varies across state lines. Designating a code for this specific use promotes a more cohesive and effective public safety response. This bill will make it easier for travelers to contact public safety officials when reporting non-emergency situations and enables our 911 telecommunicators to focus on helping people who are dealing with an emergency.”

“In an interconnected nation, it is essential that we have a streamlined communication system across all states,” said Rep. Eshoo. “The National Non-Emergency Mobile Number Act simplifies travelers’ access to assistance in non-dire times, regardless of what state they’re in and eases unnecessary call traffic to 911. I’m proud to partner with Rep. Brooks on this straightforward legislation that will allow emergency call centers to focus on urgent matters and save the lives of those in danger.”

“Currently, there are at least eighteen different wireless short codes in operation across 29 states throughout the country,” according to a news release on the bill. “Mobile wireless non-emergency numbers primarily used on highways allow individuals, especially the traveling public, to quickly and easily contact public safety officials (typically state highway patrols) in critical times of need that do not exactly rise to the emergency level, such as car malfunctions. These numbers shift unnecessary calls away from 911 systems to help with congestion and allow emergency call centers, or public safety answering points (PSAPs), to focus on more significant matters.” It added that the bill “would help consolidate the multiple numbers existing today, thereby reducing traveler confusion and hastening response times.”

“I applaud Representatives Brooks and Eshoo for introducing the National Non-Emergency Mobile Number Act,” said FCC Commissioner Mike O’Rielly. “This is a commonsense bill that will bring uniformity to wireless short codes used today by states to redirect non-emergency calls on the highway away from 9-1-1 call centers and to state highway patrols. Just as we have one, unified number to call in times of need, it is logical to have one unified short code to call when travelers see car malfunctions or suspected drunk drivers along the highway. This bill is an important first step in eliminating traveler confusion and potentially to saving lives.”- Paul Kirby, paul.kirby@wolterskluwer.com

Firm to Pay $61,000 Fine for LED Signs

The FCC’s Enforcement Bureau today released a consent decree resolving an investigation into whether a company violated the FCC’s rules in the marketing of LED signs. “To settle this matter, Liantronics admits that it marketed LED signs without the required equipment authorization, labeling, and user manual disclosures, will implement a compliance plan, and will pay a $61,000 civil penalty,” the bureau said in an order in file no. EB-SED-17-00024694. – Courtesy TR Daily

Fewer than One-Third of Providers Have 911 Circuit Diversity, Monitoring

Fewer than one-third of the 188 communications service providers that offer 911 capabilities and filed certifications with the FCC reported having 100% diverse 911 circuits and diverse network monitoring in 2017, according to a report released today by the Public Safety and Homeland Security Bureau. But nearly 90% reported having backup power in all central offices that service public safety answering points (PSAPs).

“Of the 188 covered entities that filed certifications, 48 certified that they have diverse 911 circuits to all PSAPs to which they provide 911 circuits. Twenty covered entities certified that they have implemented alternative measures in lieu of circuit diversity for all of the PSAPs that they serve. Fifteen covered entities certified that they provide diverse 911 circuits to some PSAPs and that they have implemented alternative measures to other PSAPs to which they provide 911 circuits,” the report said. “There were 6,769 unique PSAPs listed in the certifications for 911 circuit diversity. The certifications showed that of these 6,769 PSAPs, 3,855 PSAPs had diverse circuits and 2,914 had implemented alternative measures.”

The report added that of those providers that filed certifications, “51 stated that they have diverse monitoring in all of their 911 service areas, and ten stated that they have certified alternative measures in all 911 service areas. Seven covered entities certified that they provide diverse monitoring in some of their 911 service areas and have implemented alternative measures in all other 911 service areas.”

The report also said that of the carriers that submitted certifications, “165 indicated that they have certified backup power in all central offices that serve PSAPs. Nine certified that they have alternative measures for backup power in all such central offices, and four covered entities certified that they have back-up power in some central offices and have implemented alternative measures in all other central offices.”- Paul Kirby, paul.kirby@wolterskluwer.com

Parties Weigh in on Ways to Address Misrouted 911 Calls

Public safety and industry entities have weighed in at the FCC with suggestions on ways to ensure that 911 calls place from cellphones reach the correct public safety answering points (PSAPs), even though some say hard data on the scope of the problem is elusive. Parties offered diverse opinions on whether technologies currently exist to address the problem and if they should be deployed, or whether it would make more sense to focus resources on the deployment of next-generation 911 technology.

The comments were filed in PS docket 18-64 in response to a notice of inquiry adopted in March seeking input into ways to address situations where 911 calls from cellphones are misrouted to the wrong PSAP because the location of the cell tower being used by phone is not in the same PSAP jurisdiction as the caller (TR Daily, March 22).

The NOI seeks input on ways call-routing could be improved, and on ways the FCC could facilitate and encourage such improvements. It notes that recent technological improvements could enable routing based on the caller’s actual location.

The item also seeks comments on recommendations regarding location-based routing made by the FCC’s Communications Security, Reliability, and Interoperability Council (CSRIC) in 2016 and asks about the costs and benefits of adopting location-based routing.

In its comments, the Association of Public-Safety Communications Officials-International said that the lack of interoperability among PSAPs can exacerbate the impact of misrouted 911 calls.

“There are still instances where PSAPs have to manually call each other to convey the information about an emergency. This holds true both for misroutes and for other incidents that would benefit from seamless voice and data sharing between PSAPs, such as calls for mutual aid,” APCO said.

“Unfortunately, early-adopter deployments of NG9-1-1 components such as ESInets have shown that the introduction of IP-based technology alone is not solving the interoperability problem,” the filing said.  “Policymakers, industry partners, and 9-1-1 authorities must recognize and work to resolve this problem.”

APCO also said that it “would welcome additional data but anticipates that precisely quantifying the scope of the problem will be difficult. PSAPs may have different policies and capabilities for transferring as well as tracking misrouted calls. Additionally, the dynamic nature of wireless networks can mean that even two 9-1-1 calls made from the same location could route to different PSAPs because one call might route based off of the nearest tower while the other call might connect through a different tower or cell sector that has been set up to route to a different PSAP based on pre-established boundaries. The frequency of misroutes likely varies greatly across PSAPs.”

“The Commission seeks comment on the CSRIC Report’s recommendations about several location-based routing solutions. APCO generally supports the Report’s recommendations. In particular, APCO agrees with the recommendations that the Commission should take steps to ensure that any location estimates considered for routing 9-1-1 calls are accurate, and support the independent testing and analysis of new location technologies that promise significantly increased accuracy and speed. PSAPs are all too often approached by companies promising solutions, without feasible methods to verify the claims or hold the providers accountable,” APCO said.

APCO noted that “the Commission asks whether the NEAD [National Emergency Address Database] will be capable of being leveraged to obtain a caller’s location for the purpose of routing a 9-1-1 call. APCO would urge caution on prematurely considering the use of the NEAD for routing purposes. While the NEAD holds great promise for achieving a dispatchable location solution for wireless 9-1-1 calls, particularly inside buildings, it remains in development. At this point, efforts concerning the NEAD should therefore remain focused on its intended purpose.”

“Finally, the Commission asks what role, if any, it should play in the creation or implementation of standards or practices for location-based routing. Standards are best handled by industry standards bodies. As a general matter, the introduction of new technology and architectural approaches will make it increasingly difficult for 9-1-1 authorities and service providers to be clear on their respective responsibilities for allocating costs,” APCO said. “Accordingly, the Commission can provide much-needed support by continuing to offer clarification and ensuring that PSAPs do not bear costs that the Commission’s rules would otherwise allocate to service providers.”

“Until the IP-native routing features of NG9-1-1 arrive, NENA supports the development and implementation of proven interim processes and technologies for location-based routing. However, NENA respectfully requests caution by the Commission that interim solutions neither cause harm to existing routing mechanisms or delay the implementation of NG9-1-1 native location-based routing,” said the National Emergency Number Association.

“The Notice requests comment on the viability and effectiveness of provisioned or registered civic addresses. Location based routing using civic address can be successful, assuming addresses are accurate. Registered or provisioned addresses have proven to be problematic if provided by customers, because the large percentage of these that are nomadic VoIP are not kept updated by their users,” NENA said. “Automatic location definition without customer action would be highly preferable to support effective 9-1-1 service. Further, wireless carriers do not currently support processes that can help 9-1-1 validate user addresses, or provide them for use by the NG9-1-1 systems for routing control.”

“The Notice also seeks information on ‘how quickly 911 calls can potentially be routed when using device-based hybrid location solutions.’ NENA notes that current trends — especially in the marketplace for third-party solutions — gravitate toward warm-start GPS processes. Assuming the data provided by these processes is properly handled and utilized, initial routing control could be accomplished within 2–3 seconds of call start for calls where the supplemental location data is determined to be dependable and adequate. However, the proprietary nature of these location services, the unknown nature of the databases that underpin them, and their management and maintenance causes questions about how well those services can be safely applied. The concepts noted in the NOI — including the NEAD — are all capable of improving call routing and timing, but not if they are applied only within the traditional routing processing timeframe of CMRS wireless 9-1-1 within the carrier networks. Many of the newer methods for location can provide data well within 5 seconds, but if it is not utilized in a timely way, little progress will be enabled.”

The Texas 911 entities, which include the Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communication Districts Association, provided some data on the frequency of 911 calls that are misrouted, saying that “recent data for a reasonably large sample of approximately 13,000 cell sectors in Texas shows that the percentage and number of misroutes varies considerably between sectors and between Public Safety Answering Point (‘PSAP’) serving areas. For example, that data appears to show approximately 70% of the cell sectors indicated no misroutes, while approximately 10% of the sectors have greater than 50% misroutes, with certain enclave areas or cities surrounded by another city often being materially impacted by misroutes. Because the data varies considerably between sectors and between PSAP serving areas, utilizing only a general aggregate average for many sectors can completely obscure a considerable number of misroutes, and obscure the potential benefits of improvements in individual sectors.

“In the absence of sufficient public disclosure of information and informed discussions between various 9-1-1 stakeholders (e.g., wireless service providers, handset manufacturers, third-party vendors, 9-1-1 authorities, etc.), the nature of the competitive market and the sheer number of stakeholders can present some challenges to making informed decisions and strategic transition planning regarding device-based handset initiated location technology solutions,” the entities added. “Given the current frequency of misroutes, in the absence of documentation of material costs to wireless service providers being submitted into the record in this proceeding, at the present time it appears that Commission action would withstand ‘the test of feasibility and functionality relative to costs.’ The manner in which device-based handset initiated location technology solutions and NG9-1-1 transition may sync up together, including interoperability and timing considerations, and how much cost responsibility is placed on wireless service providers as compared to the NG9-1-1 systems, are appropriate issues to clarify in this proceeding.”

The filing continued, “Delaying the delivery of 9-1-1 calls more than fractionally beyond 6 seconds to achieve LBR [location-based routing] should generally be avoided. This is especially the case when other alternatives appear to be available to achieve improvements towards LBR. Finally, with regard to mobile VoIP, continuing to provide only a registered and provisioned civic address from a smartphone or tablet for mobile VoIP 9-1-1 calls is quite concerning. Accordingly, the Texas 9-1-1 Entities urge the Commission, at a minimum and as recommended in the NENA Non-Mobile Technical Information Document, to consider the issue of a location sanity check when a customer with mobile VoIP changes locations and has not reregistered a caller civic location.”

“There are a number of measures which can and should be taken to remedy Phase I Misroutes of wireless calls,” said the Boulder (Colo.) Regional Emergency Telephone Service Authority. “The first two are for wireless providers to consider jurisdictional boundaries in siting and cell sectorization decisions, and for providers to evaluate available data to determine which existing cell sites produce a high percentage of Phase I Misroutes. For sites identified to have a high percentage of misroutes, remedies are available and should be considered in consultation with PSAPs from (i) flagging for dispatchers calls from cell sites or sectors with high percentages of Phase I Misroutes, and low percentages of misroutes, (ii) modifying orientation of cell sectors, to implementing Phase II Routing or ‘Phase III Routing:’ routing calls based on a location technology which is more granular than Phase I Routing and can provide a TTFF [time-to-first-fix] of five-seconds or less.”

The filing continued, “The 9-1-1 system and services must accommodate a variety of location technologies which are suitable to different environments, or may be developed in the future. A 9-1-1 location technology should be secure, reliable and provide data in a format consistent with other location technologies. BRETSA raises the prospect of terrestrial GPS signals embedded in high power broadcast signals capable of penetrating buildings, or special purpose beacons. These terrestrial GPS signals would allow WiFi, Bluetooth or BLE access points or beacons to determine their coordinates and signal timing requirements, and in turn provide GPS signals to devices located in indoor locations. This would require Commission requirements or authorizations of the terrestrial GPS transmitters, as well as of devices which would utilize these signals to become GPS transmitters themselves.”

“Given the potential synergy between the various efforts the FCC has already enabled and the vast technologies at hand the FCC should simply replace the cell site based requirement with a device based routing requirement on a short time-line for implementation,” said Robert Oenning, former enhanced 911 administrator for Washington state. “The question is not if device location based routing can be done but rather how those in the industry who have already demonstrated an ability to collaborate on improving 911 services can be enabled to make it happen.   The action the FCC takes to move forward location based routing should be tempered to assure that the industry does not again get trapped again into retaining 911 methodologies well past the point where it is practicable to move toward improved systems.”

“As the wireless industry continues to deploy technologies that enhance location information about wireless 9-1-1 calls, the Commission is right to ask whether new technologies can also reduce the number of 9-1-1 calls delivered to PSAPs in neighboring jurisdictions,” CTIA said. “The Commission should use the record developed here to carefully weigh the costs and benefits of different policy approaches to improvements in wireless 9-1-1 call routing. For example, the Commission should assess the tradeoffs associated with different 9-1-1 call routing mechanisms, such as the potential for a general delay to routing all 9-1-1 calls. The Commission also should consider whether location-based routing solutions would be better suited for, and more easily implemented in, the next generation 9-1-1 (NG911) environment. Finally, the Commission should consider alternative methods that can prevent misroutes and/or help to mitigate the impact of misrouted 9-1-1 calls, such as encouraging additional coordination among PSAPs and by PSAPs with wireless providers.”

“Such alternative techniques can be implemented far more efficiently and effectively than wholesale, standalone changes to current routing mechanisms,” CTIA added. “Therefore, as part of this proceeding, the Commission should examine and draw attention to successful techniques that can reduce misrouted 9-1-1 calls, as well as those that can mitigate the impact of calls that are misrouted.”

T-Mobile US, Inc., said it “supports improving 911 call routing, utilizing emerging location technologies, and the transition to NG911 systems. The technological improvements capable of producing high-accuracy/low-latency locations that are becoming available for use in 911 solutions have been aggressively sought-after and are welcomed by all stakeholders. But today, the single most important contribution that public safety and the Commission can make in this regard is to encourage PSAPs to expeditiously make the transition to NG911, so that public safety and consumers can benefit from these technological advancements.”

T-Mobile added “that focusing limited resources in an attempt to add location-based 911 call routing to legacy 911 systems would offer a poor return for a very significant level of effort. T-Mobile instead proposes that the concerted effort to improve 911 call routing be directly associated with the transition to NG911 systems. T-Mobile is already taking steps to help encourage this transition and subsequent testing and refinement of such improved call routing methods. In this effort, T-Mobile believes all parties would benefit from a better understanding of the real-world trade-offs between minimizing the delay of 911 call placement, and the ability to more precisely route the call to the desired PSAP. Which of these parameters is the highest priority? How long is too long to delay a 911 call to improve the precision of call routing? With better insight into these types of system design trade-offs, and a concerted effort from all relevant stakeholders, there is a strong potential for improvement.”

“Based on trial experience, Verizon agrees that location-based routing is technically feasible and can mitigate (although not eliminate) the number of instances in which 911 calls are routed to PSAPs outside the caller’s jurisdiction,” Verizon Communications, Inc., said. “The Commission is thus right to seek input on the measures that wireless, Next Generation 911 (‘NG911’) providers, and PSAPs will need to undertake to ensure that consumers benefit from location-based routing of 911 calls.”

“Stakeholders will need to carefully allocate the roles and responsibilities of wireless service providers and state/local governments in deploying and maintaining LBR capabilities to ensure that LBR is deployed efficiently and effectively,” Verizon added. “Most important for consumers’ public safety needs, LBR should be implemented in manner that does not undermine the reliability of wireless 911 call routing. That, as a practical matter, will require the continued availability of cell sector-based routing for the foreseeable future. Finally, in the interim period, the Commission should support the use of existing best practices to improve and maintain the reliability of cell sector-based routing.”

The Voice on the Net Coalition said the CSRIC report “does not address the specific challenges faced by interconnected VoIP providers (and their third party 911 vendors) who may not have the same access to location information as CMRS providers. Notwithstanding the challenges, it’s likely that location-based technologies will provide more accurate and timely routing information for mobile VoIP 911 calls than the required registered location. By moving to a routing paradigm based on acquisition of a real-time location calculation, the FCC and industry standards bodies have the opportunity to significantly improve emergency calling services by routing mobile VoIP calls to a more appropriate PSAP. To the extent that location information can be used in a manner that rapidly and efficiently routes a 911 call to the most appropriate PSAP, VON believes there is great promise in leveraging these available technologies. There is much work to be done to effectuate a new emergency call routing paradigm, but the foundation is evident in the location capabilities available in the marketplace today.”

VON also asked “that the FCC take a broader view than simply the US market. While we recognize that the FCC’s authority does not extend beyond the US, the FCC can be a leader by encouraging the use of available technologies through consistent technical standards developed across the globe.”

“The location accuracy problems inherent with the routing of wireless 9-1-1 calls can be addressed by migrating to device-based hybrid location solutions, which combine data from various sensors on the user’s mobile device and provide the best information about the user’s actual location based on context and environment. Numerous test results confirm the viability of these device-based hybrid location solutions, which can provide more accurate location information on a more timely basis as compared to the legacy 9-1-1 routing architecture,” Motorola Solutions, Inc., said.

“The Commission should use this proceeding to explore the creation of incentives for deploying location based routing technologies. Such incentives should include sufficient and sustained levels of funding for Next Generation 9-1-1 (‘NG9-1-1’) deployments, of which device-based hybrid location solutions should be an integral part,” Motorola added. “Specifically, the Commission should explore the creation of incentives for: (1) ongoing testing and pilot activity validating improvement/benefits derived from location based routing technology; (2) PSAPs to use location based routing technology; and (3) the migration to NG9-1-1 and the use of location based routing technology at the state and local levels.”

“As the Commission recognizes, the path forward to achieve successful 9LBR [911 LBR] requires striking a balance between the industry’s concerns over disruption to existing processes and that of providing more accurate information more quickly to aid in essential lifesaving services,” Comtech Telecommunications Corp. said. “Indispensable elements along this path include, identifying and measuring the problem, consistent use of technical terms and operational processes, application of appropriate (existing or new) industry standards, specifically addressing the ‘delay of call’ issue, safeguarding the sources and destinations of location data, and promoting consistent and systematic testing of call and location data. Also, new entrants need to understand and accept that public safety operates differently than other business arenas. Public safety isn’t a game or a greenfield for the latest consumer product fad, it’s a highly regulated industry devoted to the public good. Serious vendors are encouraged, respected, and protected; less dedicated vendors may not be.”

Comtech continued, “While technological advancement brings new ways of solving difficult problems, much of today’s well-meaning progress is being promoted in a vendor-specific, proof-of-concept approach that competes with the time-tested and more inclusive public safety coordinated, and standardized approach. While Comtech shares in the desire for innovation, some of the current side effects experienced in the fray to overturn the ‘status quo’ of what is today’s emergency location processes include[:] lack of common goals, the inability to verify results, unanswered questions around whether there is statistical significance, and unknowns as to whether these experiments are replicable.

“Wireless 9-1-1 location based routing is not a panacea for all of 9-1-1’s ills, and the quest for 9LBR cannot impede the goal of maintaining reliable wireless 9-1-1 calling. It is imperative that for 9-1-1, we achieve consistent, reliable methods and solutions, avoiding at all costs, experiments that potentially jeopardize ‘live’ 9-1-1 calls without carrier and FCC notification,” Comtech concluded.

West Safety Services, Inc., said it “has experienced encouraging test results for handset-initiated location technologies that utilize device-based hybrid location information. Unlike network-initiated technologies, calls to 9-1-1 over these handset-initiated technologies do not have to traverse complex carrier networks or wait to reach the carrier’s routing element before initiating the process for location determination. West Safety believes these handset-initiated location technologies offer promise for significantly reducing the PSAP transfer rate. West Safety cautions the Commission, however, that carriers should maintain control over any implementations of device-based hybrid location solutions. Permitting third-party applications to deliver locations directly to PSAPs without interconnecting to the carrier’s routing element should be avoided. Carriers are in the exclusive position to ensure location uniformity, security, reliability and validation under centralized Commission oversight and clear jurisdiction.”

NextNav LLC said that the FCC “should ensure that any location-based routing solution that is employed for E911 calls incorporates adequate backup protection in scenarios where a technology might be used by a wireless carrier for location compliance, but fails to timely achieve an accurate fix in all instances. For example, in those cases in which a carrier employs A-GPS, other location technologies should be available to support the routing of calls originating from indoor locations where A-GPS may not produce a location fix. In addition, if a DBH [device-based hybrid] approach is used, consideration must be given to whether the resulting location information is sufficiently reliable to support call routing, particularly in communities and neighborhoods where broadband penetration is low (such as in low income areas), where Wi-Fi devices may be subject to frequent relocation (such as college dorms or apartment complexes), or in cases in which individuals may have turned off the location functions on their wireless handsets due to privacy concerns.”

NextNav also said that its location technology could be deployed to quickly ensure that 911 calls are accurately routed to the correct PSAP.

LaaSer Critical Communications said it “has created patented technology that pinpoints a 911 caller’s location using any mobile device, efficiently routes them to the appropriate Public Safety Answering Point (PSAP), and provides the emergency operator and responders with precise location information.” It said “that the answer to the question ‘what is the best way to avoid delays’ caused by ‘misroutes’ is inclusion of DBH location within the existing wireless carrier routing systems. Such a deployment leverages the best of what DBH has to offer, ensures that routing improvements are only ever additive with existing systems providing a consistent and reliable base level of performance, allows for ubiquitous PSAP availability, and is available in current-state environments, NG911 environments, and transitional environments.”

Precision Broadband LLC described its prototype fixed broadband 911 location and routing system and said that “[b]y utilizing fixed broadband for 911, state governments would be justified, and legally empowered, to assess 911 fees on home broadband service (as is done today on landline and mobile phone service). When applied to the 106 million US broadband households, an additional $1 billion annually could be collected for 911 services. These fees, along with revenues from new entrants in the 911 market, could be used to implement the solutions being developed by Precision Broadband and other market participants as well as expediting the deployment of NG911 technologies.”

Onvoy LLC (d/b/a Inteliquent) said it “appreciates and supports the Commission’s efforts to solve the very real problem of wireless 9-1-1 call misroutes due to the outdated cell-tower-based call routing system. Inteliquent’s experience counsels that device-based solutions are the way forward to delivering fast and accurate location information to the correct PSAP at the outset. Inteliquent is already working with its partners on developing such a solution, and looks forward to real-world testing of the solution later this year. Any steps taken by the Commission should facilitate and encourage device-based location routing for 9-1-1 calls, and avoid solutions that rely on centralized databases that are costly to update and maintain at the level necessary for use in emergency services.”

Mission Critical Partners LLC encouraged the FCC “to promote the uniform adoption of location-based routing technologies, especially with universal transition to Next Generation 911 (NG911). Particularly, the Commission should encourage the implementation of Advanced Mobile Location (AML) or the vendor-specific variations, e.g., Emergency Location Service (ELS), a proven life-saving technology. MCP believes the Commission can support the implementation of location-based routing by removing liability barriers that could be raised by the Commercial Mobile Radio Service (CMRS) providers and NG911 solution providers for using third-party location.”

Charity Feb of Camas, Wash., whose 911 call about her husband, who had a fatal heart attack in 2012, was routed in Portland, Ore., thanked the FCC for launching its proceeding. – Paul Kirby, paul.kirby@wolterskluwer.com

Pai Tells ACS It May Not Decline Service to Rural Healthcare Providers

FCC Chairman Ajit Pai has reminded Alaska Communications Systems Group, Inc., (ACS) that it has an obligation under the Communications Act and FCC rules to comply with a “bona fide request” for telecom services “which are necessary for the provision of health care services in a State,” and that it must not charge rural healthcare providers more than the urban rate for such services.

In a letter dated today, Chairman Pai told ACS President and Chief Executive Officer Anand Vadapalli that he was “disheartened to hear this past week that Alaska Communications, because of questions about its compliance with Commission rules, is reconsidering its participation in the [Universal Service] Fund’s Telecommunications Program, a program that is key to providing remote Alaskan villages with telecommunications services.”

Under the Act and FCC rules, Chairman Pai said, “Alaska Communications may not deny or cut off service to any of its existing rural healthcare provider customers.”  It also “may not deny or cut off service to any of its existing rural healthcare provider customers for lack of payment of any charge higher than the urban rate,” Chairman Pai said.

“I would also remind you that, as a telecommunications carrier offering telecommunications services to rural healthcare providers, Alaska Communications is prohibited from engaging in unjust and unreasonable practices or from discontinuing service to a community without prior Commission approval.” — Lynn Stanton, lynn.stanton@wolterksluwer.com – Courtesy TR Daily