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4G Americas Evaluation Of Text Based SMS to NextGen 911 Service – “SMS-to-911 is Simply Not Viable”

October 14, 2011

Please find below 4G Americas 31 August, 2011 opinion and recommendation to the FCC regarding text-based NextGen 911 service.

In short 4G Americas believes that  “SMS-to-911 has significant limitations, not the least of which is substantial widespread modifications at PSAPs that state and local governments can ill afford.  SMS-to-911 is simply not viable. The Commission should not propose that carriers implement SMS-to-911.”

4G Americas is a trade association dedicated to supporting the deployment of 4G mobile broadband technologies throughout the Americas.

 31 August 2011

BY ELECTRONIC COMMENT FILING SYSTEM

Marlene H. Dortch, Secretary

Federal Communications Commission

445 12th Street, SW Washington, DC 20554

Re: Framework for Next Generation 911 Deployment, PS Docket No. 10-255

Dear Ms. Dortch:

4G Americas commends the Federal Communications Commission (“FCC” or “Commission”) for initiating the proceeding on Next Generation 911 (“NG911”) and for facilitating the transition of legacy 911 networks to NG911. 4G Americas, a trade association dedicated to supporting the deployment of 4G mobile broadband technologies throughout the Americas, agrees with the Commission that replacing today’s 911 “system with a broadband- enabled, IP-based 911 network will offer far more flexibility, resilience, functionality, innovation potential, and competitive opportunities than is presently possible.”1

Chris Pearson, President of 4G Americas, presented to the Commission’s Emergency Access Advisory Committee (“EEAC”) on August 12, 2011 and reviewed 4G Americas’ recent White Paper, Evaluation of Short-Term Interim Techniques for Multimedia Emergency Services. A copy of the MMES White Paper is attached for inclusion in the record of the Framework for Next Generation 911 Deployment proceeding, PS Docket No. 10-255.

4G Americas, its member companies and others are studying NG911 technology solutions in the Third Generation Partnership Project (3GPP) standards organization, with the leading technology appearing to be an Internet Protocol Multimedia Subsystem-based (IMS- based) Multimedia Emergency Systems (“MMES”). The 3GPP IMS-based MMES standard being developed will offer more flexibility, resiliency, functionality, and innovation than interim solutions being considered today and is consistent with the Commission’s goals.

The 3GPPIMS-based MMES will also facilitate emergency communications by persons who are deaf,deaf-blind, hard of hearing, or with speech impairments, consistent with the goals of the Twenty- First Century Communications and Video Accessibility Act. 4G Americas expects that the MMES being specified in 3GPP will be supported in the LTE and IMS environments. However, the 3GPP MMES being developed will take several more years to deploy.

Appreciating that the emergency services and disability communities want a more immediate, text-based NextGen 911 service, 4G Americas undertook an evaluation of the various interim technologies that might be a solution. 4G Americas investigated possible interim techchnologies that were actually supported by wireless networks and PSAPs. In the current budget environment, it does little good to study technologies that would require massive investments by PSAPs or require complete overhaul of the existing emergency communications systems.

Moreover, an “interim” solution should be just that – available in the immediate term with little or no changes to end-user devices and networks, since the 3GPP MMES will be available in several years.  Given that economic and temporal reality, the scope of 4G Americas’ evaluation was minimal impacts to end user devices, wireless infrastructure and PSAPs.

4G Americas’ evaluation found that none of the short-term interim techniques for MMES can be supported without a significant, costly development effort. As detailed more fully in the attached White Paper, the implementation of any “interim” technique for a short-term MMES solution will require significant resources and time to develop and deploy. Sources of funding for the development and deployment of any short-term technique have not been addressed at any level.  Even if funding were available, all of the potential techniques evaluated in the White Paper have operational limitations that would impact the use of the technique as an interim short- term solution.

One of the many techniques evaluated by 4G Americas is SMS-to-911. Some proponents have suggested SMS-to-911 in part because of the growing use of SMS in the general population.   In its Notice of Inquiry, the Commission asked a number of questions about “whether NG911 networks should be configured to support SMS emergency communications.”2

SMS is a store and forward service with no service or performance guarantees. No locationinformation is provided, so the originating network may not accurately route the message to the correct PSAP. SMS is not a session-based protocol, so subsequent messages from the subscriber may be delivered to different PSAP call takers.3   In short, SMS-to-911 has significantlimitations, not the least of which is substantial widespread modifications at PSAPs that state and local governments can ill afford.4   SMS-to-911 is simply not viable.

The Commission should not propose that carriers implement SMS-to-911. Allowing industry to focus on the 3GPP standards process for MMES, rather than forcing industry into a costly retrofit of legacy 911 for only an interim period, is more consistent with President Obama’s recent Executive Order on Regulation and Independent Agencies.5

4G Americas believes the wisest course is to focus on development of NextGen 911 through 3GPP which will provide far more innovation, flexibility, resilience, and functionality than any “interim” solution under discussion.

Sincerely,

Patricia Paoletta

Counsel to 4G Americas

1    See Framework for Next Generation 911 Deployment, Notice of Inquiry, 25 FCC Rcd. 17,869, ¶27 (2010).

2  Id. ¶42.

3  See 4G AMERICAS, EVALUATION OF SHORT-TERM INTERIM TECHNIQUES FOR MULTIMEDIA EMERGENCY SERVICES at 15 (2011), avail. at http://www.4gamericas.org/UserFiles/file/White%20Papers/Evaluation%20of%20Short- Term%20Interim%20Techniques%20for%20Multi-Media%20Emergency%20Services.pdf.

4  See 4G AMERICAS, TEXTING TO 9-1-1: EXAMINING THE DESIGN AND LIMITATIONS OF SMS (2010), avail. at

http://www.4gamericas.org/documents/SMS%20to%20911%20White%20Paper%20Final%20October%202010.pdf.

5  Exec. Order No. 13,579, 76 Fed. Reg. 41,587 (July 11, 2011), avail. at http://www.whitehouse.gov/the-press- office/2011/07/11/executive-order-regulation-and-independent-regulatory-agencies.

Attachment

cc:   Rick Kaplan Ruth Milkman Josh Gottheimer Paul de Sa

Margaret McCarthy Angela Giancarlo Louis Peraertz

Jamie Barnett Jennifer Manner Cheryl J. King

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