Wireless Group Criticizes FCC’s Text-to-911 Plans

From the Dispatch Monthly Magazine ( http://www.911dispatch.com/2012/02/wireless-group-criticizes-fccs-text-to-911-plans/)  In the wake of proposed rules by the Federal Communications Commission (FCC) to implement text-to-911 service, a wireless communications group says the FCC doesn’t have the legal authority to make the rules, and that SMS has significant limitations in reporting emergencies. The Cellular Telecommunications Industry Association (CTIA) submitted formal comments earlier this month raising the issues in response to proposed rules the FCC issued last September to quickly deploy text-to-911 services. The CTIA takes makes both legal and technical objections to the FCC’s proposals presented in a Notice of Proposed Rulemaking (NPRM) last year, but does acknowledge the “considerable” benefits of IP communications for those with hearing disabilities. The group says any interim NG911 solution should be “voluntary, collaborative (and) industry-drive,” rather than a mandated process focused on short-term goals. First, the CTIA claims the FCC does not currently have the authority to regulate SMS messaging, disputing the FCC’s claims that existing law provides the authority. The group picks apart the FCC’s specific claims of authority in the NPRM. The CTIA also raises specific technical concerns about SMS as a way to contact emergency services. “Wireless carriers, equipment manufacturers, and Public Safety entities all have highlighted numerous shortcomings of SMS-to-911 as an interim solution,” the CTIA wrote, and urged the FCC not mandate any interim text-to-911 solution based on SMS. The shortcoming includes possible transmission delays, the sender receives no acknowledgement of delivery and no intelligent routing. Download (pdf) the CTIA’s comments.


Among the technical objections the CTIA raised to the FCC’s text-to-911 plans are:

 SMS does not support real-time communications with a PSAP, and there could be significant delays in message delivery to the PSAP. Indeed, segmented or concatenated SMS messages may not be delivered in order.

 A sender of a SMS message receives no confirmation that the message was received by the intended recipient.

 Current SMS standards do not support automated routing to the PSAP or automated location information.

 Because SMS messaging is not a session-based protocol, a series of messages from the same user may be routed to different PSAPs.

 Delays in message transmission could result in PSAPs receiving SMS messages that are out of date.

 Voice calls to 9-1-1 enable the PSAP operator to ascertain information about the caller‘s current physical/emotional state and the severity of the emergency, information that is less easily ascertained through SMS messaging.