The Association of Public-Safety Communications Officials-International said that wireless carriers, not public safety answering points (PSAPs), should be responsible for leading outreach efforts to educate consumers about reduced access to 911 networks from non-service-initialized (NSI) mobile phones with the retirement of older systems.

“APCO pointed out that reduced NSI access to 9-1-1 resulting from technology retirements will only worsen as carriers shut down 2G, and then 3G networks,” the group said in an ex parte filing in PS docket 08-51 reporting on a meeting with officials from the FCC’s Public Safety and Homeland Security Bureau. “APCO stressed that in order to address this situation, it should be the wireless industry, not PSAPs, that leads efforts to educate affected consumers. The carriers should be responsible for managing expectations related to their networks, and their responsibility includes educating all affected parties, not just their remaining subscribers. Additionally, both nationwide and regional carriers are in a much better position than PSAPs to conduct outreach given their relatively larger resources, economies of scale, and routine marketing of new or upgraded services and devices to the general public.”

APCO’s filing was submitted in response to a filing by CTIA in November (TRDaily, Nov. 25, 2015). In that filing, CTIA said, “As educational efforts about any modifications to the ‘all calls’ rule may confuse or unnecessarily alarm the general public, CTIA continues to believe that efforts to reach those consumers should be led by PSAPs and the state and local governments that support them.”

CTIA also said that it “continues to believe that the appropriate means of reducing fraudulent or illegitimate 9-1-1 calls from NSI handsets lie with PSAPs themselves.” The group added, “The FCC should encourage PSAPs to implement 9-1-1 call blocking methods directly, either within their own networks or customer premises equipment. This approach will address the problem of fraudulent calls to 9-1-1 where it is felt the most, inside the PSAP.”

“CTIA also addressed the prospect of using a third party aggregator to intercept and pass only legitimate NSI calls to 9-1-1,” APCO noted in its filing. “In this respect, APCO noted that potential solutions such as third party aggregators present a number of complex challenges and questions. APCO further fundamentally disagrees with the suggestion that responsibility for implementing methods in lieu of sunsetting the NSI call-forwarding rule should rest with PSAPs.

“In determining the best path forward, APCO suggested that the focus should be on protecting consumers who rely on NSI phones for reaching 9-1-1. This includes vulnerable populations that most benefit from the NSI call-forwarding rule, many of whom possess handsets limited to older technologies set to be retired. APCO thus recommended that the Bureau seek additional information from the industry on the extent of carrier donation programs to vulnerable populations such as shelters, the elderly, underprivileged, etc.,” APCO added.

APCO also “reiterated its position that the Commission should sunset the call-forwarding rule and affirmatively prohibit 9-1-1 calls from NSI devices, following an appropriate transition period. This would have the important advantage of putting an end to the substantial number of harassing and fraudulent NSI calls to 9-1-1.”

APCO’s filing also said that “the Bureau offered a few potential solutions for APCO’s consideration. For example, a technology cut-off date could be set, whereby the call-forwarding requirement would not be applicable to certain networks and technologies, but without affirmatively prohibiting NSI call-forwarding. For carriers that continue forwarding NSI calls to 9-1-1, they could be made responsible for establishing and funding a mechanism for blocking fraudulent and harassing NSI calls before they reach PSAPs. APCO agreed to give further consideration to these alternatives.”

Last year, the FCC’s adopted a notice of proposed rulemaking proposing to eliminate, after six months, the NSI call-forwarding requirement (TRDaily, April 2, 2015). In response to the NPRM, public safety entities said the FCC should phase out the rule, while wireless entities said the Commission should keep it (TRDaily, June 8, 2015).- Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily