February 9, 2017–Public safety and industry entities disagree on the demarcation point for text-to-911 offerings between wireless carriers and next-generation 911 (NG-911) systems. Comments were filed at the FCC in PS dockets 11-153 and 10-255 in response to a public notice issued last month by the Public Safety and Homeland Security Bureau seeking views on a request by the Maine Public Utilities Commission “for assistance in resolving a conflict related to the implementation of text-to-911 via message session relay protocol (MSRP) service” (TRDaily, Jan. 9).

Specifically, the bureau noted, the PUC is seeking clarification regarding the demarcation point for text-to-911 between wireless providers and Maine’s NG-911 system. Maine said that it implemented an interim text-to-911 solution at two of the state’s public safety answering points (PSAPs), relying on TTYs (teletypewriters), and that following statewide deployment of an NG-911 system, it received conflicting migration price proposals from text control centers (TCCs).

The PUC told the FCC that “the root cause” of the pricing dispute “appears to be the point of demarcation between carriers and Maine’s Emergency Services Internet Protocol Network (ESInet).” Whereas Maine believes that “the point of demarcation should be at the ingress designated by the Session Border Controller (SBC) of the State of Maine ESInet,” it told the FCC that the TCCs, “acting on behalf of wireless carriers, argue that the point of demarcation should be the egress side of the SBC used by the TCCs.

“The basis for Maine’s argument is the FCC’s [2001] ‘King County Letter.’ In the King County Letter, Thomas Sugrue, Chief of the FCC’s Wireless Communications Bureau, states the FCC’s view that ‘the proper demarcation point for allocating costs between the wireless carriers and the PSAPs is the input to the 911 Selective Router maintained by the Incumbent Local Exchange Carrier (ILEC).’ Thus, the King County Letter established the demarcation for Wireless Phase I service as the E911 Selective Router,” the PUC noted. “In the NG 911 environment, the equivalent to the E911 Selective Router would be the State ESInet SBC, not the TCCs’ SBC. To be clear, it is not Maine’s NG911 system that requires a TCC with interim text functionality; rather, the need arises from a limitation of the wireless carriers’ native networks. If the wireless carriers were able to provide a Session Initiation Protocol (SIP) message complete with location directly to the State’s network, the network would be capable of routing the SIP message to the appropriate PSAP via its own SBC.”

In the public notice, the Public Safety Bureau also sought “comment on whether any demarcation point identified for text-to-911 could be generally applied to future multimedia communication (e.g., delivery of photos, video, and other data) in the NG911 environment.”

In their comments, public safety entities generally sided with the Maine PUC, while industry parties took the alternative position. “In concept, and consistent with the Commission’s reasoning in the King County letter, the demarcation point should be the functional element designated by PSAPs for receiving communications to 9-1-1 from telecommunications carriers and forwarding the communications to the particular PSAP that services the caller’s area. Thus, as Maine described its ESInet session border controller (SBC), it seems the SBC ingress should be the demarcation point in this case,” said the Association of Public-Safety Communications Officials-International. “To ensure comprehensive applicability across network designs and naming conventions, the Commission might benefit from considering the need for a functional definition of the demarcation point, rather than identifying a specific piece of equipment or network element.”

But APCO said that “it is unclear whether the record contains sufficient information for a thorough analysis of the issues raised in the Public Notice. Without more detail, it may prove difficult for the Commission to draw well-reasoned conclusions, both for SMS text-to-911 and especially for a fully-functional NG9-1-1 environment.”

“Since at least 2012, NENA has repeatedly raised with the Commission and with the private sector the importance of resolving the location of critical demarcation points between access network providers and originating service providers, on the one hand, and legacy, transitional, and NG9-1-1 systems on the other,” the National Emergency Number Association said. “As demonstrated by the letter from Maine’s Public Utilities Commission that generated the Public Notice to which we herein respond, the need for some determination as to these critical locations has only grown more acute in the interim.” NENA added that it “remains committed – for now – to a multi-stakeholder-based resolution of this issue. Assuming a comprehensive consensus view can be reached on a reasonable timeframe (e.g., by the end of 2017), NENA would prefer to resolve these issues through discussion. Should that effort prove unsuccessful, however, NENA would then urge the Commission to fully, finally, and clearly resolve the points of demarcation for access network providers and originating service providers with respect to legacy, transitional, and NG9-1-1 systems.”

“Without regard as to the appropriate cost demarcation for interim SMS text-to-9-1-1 service or other legacy technologies, as a general good faith presumption, the Texas 9-1-1 Entities assert that the cost demarcation point with regard to future multimedia communications and new Internet Protocol (‘IP’) services for the ultimate end state of IP-to-IP interconnection should be the Session Border Controller (‘SBC’) of the Emergency Services Internet Protocol Network (‘ESInet’) with Next Generation 9-1-1 Core Services (‘NGCS’) (hereinafter collectively referred to as ‘ESInet with NGCS’), unless otherwise negotiated between the parties,” said the Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications, and the Municipal Emergency Communication Districts Association.

“Because 9-1-1 calls are jurisdictionally intrastate, it is up to the states to determine where the demarcation point for financial responsibility for delivery of 9-1-1 calls (including text messages and other formats of calls) should lie,” the Boulder, Colo., Regional Emergency Telephone Service Authority said. “To the extent the Commission determines the demarcation point, however, the determination should be consistent with the King County Letter and King County Reconsideration Decision and place the demarcation point at the SBC for the state ESInet.”

The National Association of State 911 Administrators also expressed support for the clarification sought by the Maine PUC. “We request the Commission consider establishing a standard point of interconnection, absent other agreements and regardless of how it rules regarding Maine’s specific request, similar to what it did in King County. This would aid states that are moving aggressively toward NG911 to better serve the evolving communication preferences of consumers and hopefully minimize the transition timeline. It is our opinion that the Commission has the legal authority to make this determination just as it did for King County.

“We concur with comments filed by the National Association of State 911 Administrators (NASNA), and support the State of Maine’s request for a clarification of the point of demarcation between text-to-911 service providers and Maine’s NG911 system,” said the Division of Statewide Emergency Telecommunications in Connecticut’s Department of Emergency Services and Public Protection. “We agree with Maine’s position that the proper point of demarcation is at the point of ingress to their Emergency Services Intranet (ESInet) at the session border controller (SBC), and that the King County decision has established the precedent that the Commission should follow.”

The Washington State E911 Coordination Office said it agrees with Maine “that the ingress designated by the Session Border Controller (SBC)” should be “the appropriate point of demarcation for text-to-911, and for all other communications or data transmitted by service providers to the NG911 system.”

But industry entities disagreed with the public safety parties. “The norms established through that multistakeholder process and the Commission’s King County decision confirm that the egress side of the wireless providers’ Text Control Center (TCC) is the appropriate demarcation point for interim text-to-911 solutions,” CTIA said. “The Maine PUC offers no justification for upending the established cost allocation paradigm that public safety representatives and wireless providers have instituted and the FCC has recognized for interim text-to-911 solutions. Looking beyond the text-to-911 environment, CTIA foresees the benefits of pursuing further discussions and a consensus-based approach to identify the appropriate demarcation point(s) for the NG911 end state. The Commission should encourage interested stakeholders to engage in such discussions in the near future.”

AT&T, Inc., asked the FCC to deny the clarification sought by the Maine PUC. “As an initial matter, the King County Letter holding applied to the particular architecture of the TDM network,” the carrier said. “But even if the Commission extends the King County Letter precedent to the IP context today, it would not support Maine’s conclusion. When services are migrated to an all IP environment, the Selective Router is no longer part of the network configuration. Thus, to apply the King County Letter framework in the current context, it is critical to determine the text-to-911 equivalent of the ‘point at which the system identifies the appropriate PSAP and distributes the voice call and location data to that PSAP.’ For the interim text-to-911 solution, the Text Control Center (TCC) performs the analogous function of the Selective Router of identifying the PSAP and distributing, in this case, the text and any location information to the PSAP. Thus, the point of demarcation would be the egress side of the session border controller (SBC) used by the TCC.”

Comtech Telecommunications Corp. said that a 2012 industry-public safety agreement and an FCC order “require that the FCC find that treating the TCC the same as a Selective Router for purposes of cost demarcation is appropriate, and reject Maine’s request. That being said, Comtech agrees that this topic would benefit from cooperative industry discussion as the introduction of new NG911 services advances because confusion, especially regarding financial responsibility, can delay innovation and critically needed emergency services.” – Paul Kirby, paul.kirby@wolterskluwer.com

Courtesy TRDaily