Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; Framework for Next Generation 911 Deployment, 63257-63276 [2011-26258]

Agencies

• FEDERAL COMMUNICATIONS COMMISSION

[Federal Register Volume 76, Number 197 (Wednesday, October 12, 2011)]
[Proposed Rules]
[Pages 63257-63276]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-26258]


=======================================================================
-----------------------------------------------------------------------

FEDERAL COMMUNICATIONS COMMISSION

47 CFR Part 1

[PS Docket No. 11-153; PS Docket No. 10-255; FCC 11-134]


Facilitating the Deployment of Text-to-911 and Other Next 
Generation 911 Applications; Framework for Next Generation 911 
Deployment

AGENCY: Federal Communications Commission.

ACTION: Proposed rule.

-----------------------------------------------------------------------

SUMMARY: In this document, the Commission seeks to accelerate the 
development and deployment of Next Generation 911 (NG911) technology 
that will enable the public to send emergency communications to 911 
Public Safety Answering Points (PSAPs) via text, photos, videos, and 
data and enhance the information available to PSAPs and first 
responders for assessing and responding to emergencies. This Notice of 
Proposed Rulemaking seeks comment on a variety of issues related to the 
short-term and long-term transition to NG911.

DATES: Submit comments on or before December 12, 2011. Submit reply 
comments on or before January 10, 2012.

ADDRESSES: You may submit comments, identified by PS Docket No. 11-153 
and/or PS Docket No. 10-255, by any of the following methods:
     Federal Communications Commission's Web Site: https://fjallfoss.fcc.gov/ecfs2/. Follow instructions for submitting comments.
     People with Disabilities: Contact the FCC to request 
reasonable accommodations (accessible format documents, sign language 
interpreters, CART, etc.) by e-mail: FCC504@fcc.gov or phone: 202-418-
0530 or TTY: 202-418-0432.
    For detailed instructions for submitting comments and additional 
information on the rulemaking process, see the SUPPLEMENTARY 
INFORMATION section of this document.

FOR FURTHER INFORMATION CONTACT: Patrick Donovan, Attorney Advisor, 
(202) 418-2413. For additional information concerning the Paperwork 
Reduction Act information collection requirements contained in this 
document, contact Judith Boley-Herman, (202) 418-0214, or send an e-
mail to PRA@fcc.gov.

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Notice 
of Proposed Rulemaking (NPRM) in PS Docket No. 11-153, PS Docket No. 
10-255, FCC 11-134, released on September 22, 2011. The full text of 
this document is available for public inspection during regular 
business hours in the FCC Reference Center, Room CY-A257, 445 12th 
Street, SW., Washington, DC 20554, or online at https://transition.fcc.gov/pshs/services/911-services/.

I. Introduction and Executive Summary

    1. In the Notice of Proposed Rulemaking, we seek to accelerate the 
development and deployment of Next

[[Page 63258]]

Generation 911 (NG911) technology that will enable the public to send 
emergency communications to 911 Public Safety Answering Points (PSAPs) 
via text, photos, videos, and data and enhance the information 
available to PSAPs and first responders for assessing and responding to 
emergencies. Sending text messages, photos, and video clips has become 
commonplace for users of mobile devices on 21st century broadband 
networks, yet our legacy circuit-switched 911 system does not support 
these forms of communication. While continuing to ensure reliable 
voice-based 911 service will always be essential as we migrate to 
NG911, adding these non-voice capabilities to our 911 system will 
significantly improve emergency response, save lives, and reduce 
property damage. Incorporating text and other media into the 911 system 
will make it more accessible to the public, both for people with 
disabilities and for people in situations where placing a voice call to 
911 could be difficult or dangerous.
    2. In addition, these 21st century communications technologies will 
provide PSAPs with better information that can be synthesized with 
existing databases to enable emergency responders to assess and respond 
to emergencies more quickly and effectively. Not only will PSAPs be 
able to receive text messages, photos, and video clips from the public, 
but also NG911 can provide them with the tools they need to quickly 
process and analyze the incoming information. In addition, PSAPs and 
emergency responders will be able to combine information received from 
the public with other information sources (e.g., video feeds from 
traffic or security cameras, automated alarms or sensors in a 
neighborhood, building, or vehicle) to develop a detailed and data-rich 
assessment of the emergency in real time. This in turn will enable 
public safety officials to decide on the appropriate response more 
quickly, saving precious minutes and seconds that can be critical in 
many emergencies.
    3. In this NPRM, we provide a procedural history, together with 
technical background, regarding three broad classes of text-capable 
communications, namely Short Message Service (SMS), IP-based messaging, 
and Real-Time Text (RTT), comparing their characteristics, strengths, 
and limitations in supporting emergency communications. This 
description relies largely on current industry standards, early 
prototypes, and the record in this proceeding.
    4. We then examine potential short-term methods for sending text 
messages to 911. We do so because of the widespread availability and 
increasing use of text in communications systems and because many of 
the emerging IP-based mechanisms for delivering text also have the 
capability, with relatively minor technical adjustment, to support 
delivery of photos, videos, and other data as well. We seek comment on 
what role the Commission should play to facilitate--and, if necessary, 
accelerate--the implementation of text-to-911 capabilities by providers 
in the short term. We explore the full range of options for the FCC, 
including both non-regulatory and regulatory approaches, and seek to 
adopt the least burdensome approach that would achieve the desired 
result. We also recognize that we must carefully assess the costs and 
benefits of different regulatory options to determine the Commission's 
proper role.
    5. We seek to strengthen the record to determine whether to 
encourage development of interim text-to-911 solutions and, if so, how 
to maximize their effectiveness and utility to the public and to PSAPs, 
while minimizing cost and the potential for negative PSAP operational 
impacts or consumer confusion. Specifically, we explore the potential 
for using SMS as an interim solution for text-based communication to 
911, given the near-universal availability and consumer familiarity 
with SMS. The responses to our December 2010 Notice of Inquiry in this 
proceeding identify a number of possible limitations when using SMS for 
emergency communications, but some commenters also contended that these 
limitations could be surmounted by appropriate engineering approaches. 
We also examine other short-term options that would rely on software 
applications capable of delivering text over the existing IP-based 
infrastructure. We examine the potential costs and benefits of both 
SMS-based and software-based interim approaches as compared to 
developing more comprehensive text-to-911 solutions over the longer 
term that will provide more reliable real-time communication and can 
also support delivery of photos and video.
    6. Next, we seek comment on whether 911 traffic should be 
prioritized to ensure that people in need of assistance have reliable 
access to emergency services, especially during times of serious 
emergencies such as large-scale natural and manmade disasters. The 
August 23, 2011 East Coast earthquake and Hurricane Irene have been 
recent reminders that concentrated demands on the capacity of 
commercial communications networks during and immediately after 
emergencies can hinder the ability of consumers to make voice calls, 
which in turn can jeopardize their ability to contact 911. We seek 
comment on how best to address this concern in both legacy networks and 
the emerging broadband networks that will support NG911, including 
options for prioritizing 911 traffic.
    7. We then turn to long-term implementation of NG911, with 
particular focus on IP-based alternatives for delivering text, photos, 
videos, and other data to 911 that would leverage the increasing 
percentage of mobile devices that have the ability to access the 
Internet. We seek comment on the potential for developing downloadable 
smartphone applications that both consumers and IP-capable PSAPs could 
acquire to support capabilities for an early roll-out of text and 
mulitimedia functionality. We note that such applications could also 
provide early access to key NG911 capabilities for mobile callers, 
especially those with hearing and speech disabilities.
    8. We also seek comment on the path towards integration and 
standardization of IP-based text-to-911 as commercial providers migrate 
to all-IP networks and as 911 authorities deploy Emergency Services IP 
networks (ESInets) that will enable PSAPs to receive the full range of 
IP-based traffic, including voice, text, photos, video, and data. In 
this all-IP environment, text-to-911 is one of several non-voice 
services that will be supported by ``native'' IP communications end-to-
end solutions, such as the Internet Multimedia Subsystem (IMS). 
However, providers may have varying timetables for developing the 
capacity to deliver IMS communications to PSAPs. PSAP deployment of 
ESINets is also likely to be non-uniform. We seek comment on the 
necessary steps for providers and PSAPs to support integrated IMS-based 
communications and the time that this process is likely to take.
    9. With over 6,800 PSAPs in the United States, spanning a wide 
range of sizes and resources, individual PSAPs are likely to have 
highly varying timetables for developing the technical and operational 
capability to handle incoming texts in the short term, as well as texts 
and other media in the longer-term implementation of NG911. While there 
are significant public safety benefits to enabling the public to send 
texts and other media to 911 in areas where PSAPs are capable of 
receiving and processing them, we seek to avoid imposing unnecessary 
costs on providers to implement NG911 in areas where PSAPs have not yet 
achieved

[[Page 63259]]

such capability. For this reason, we seek comment on whether PSAPs 
should demonstrate a threshold level of technical NG911 capability as a 
precondition to any obligation by providers to deliver text or other 
media to PSAPs and whether such demonstration should be at the state or 
regional level. We also seek comment on potential state or local 
regulatory barriers to NG911 deployment and whether states should 
demonstrate that they have adopted legal or regulatory measures to 
eliminate such barriers to facilitate NG911 deployment.
    10. Given that text-to-911 and other NG911 capabilities will likely 
not be simultaneously deployed nationwide, consumers may be uncertain 
where non-voice communication with 911 is available. Even where text-
to-911 or other NG911 applications are available, the specific 
capabilities and operational characteristics of these applications may 
vary. We therefore seek comment on how to best educate consumers about 
the availability and limitations of text-to-911 and other NG911 
solutions, particularly during the transition from legacy 911 to full 
implementation of NG911, without imposing an undue burden on providers.
    11. As noted above, adding text and other media capabilities to our 
911 system promises to bring significant benefits for people with 
disabilities. In this regard, we seek comment on the relationship 
between this proceeding and our ongoing implementation of the Twenty-
First Century Communications and Video Accessibility Act of 2010, 
which, among other things, sets goals for achieving equal access to 
emergency services for people with disabilities ``as a part of the 
migration to a national Internet protocol-enabled emergency network.'' 
We believe that the transition to NG911 and the implementation of the 
CVAA can be achieved through development of common text-to-911 and 
multimedia-to-911 solutions that serve both objectives. In this NPRM, 
therefore, we seek comment on the potential for coordinating the two 
proceedings to promote broader and more rapid NG911 deployment.
    12. Throughout this NPRM, we seek comment to further strengthen our 
record on these important aspects of the evolution towards NG911 
systems and capabilities. In particular, we seek detailed data that 
quantifies the benefits that text-to-911 and other NG911 applications 
will bring to the public and to emergency responders, while also 
quantifying the costs to providers, PSAPs, and consumers. We emphasize 
the importance of comments being detailed, specific, and supported by 
data where appropriate. We intend to confer particular weight on 
arguments and estimates that are supported by data or are otherwise 
well documented.

II. Background

    13. In this section, we review the procedural history leading up to 
this NPRM. We also provide technical background information classifying 
the likely technical options for text-to-911, and we recap the record 
on those options that the Commission received in response to the Notice 
of Inquiry.

A. Procedural History

    14. In December 2010, as recommended in the National Broadband 
Plan, the Commission released a Notice of Inquiry on NG911 (FCC 10-200, 
released Dec. 21, 2010), which initiated a comprehensive proceeding to 
address how NG911 can enable the public to obtain emergency assistance 
by means of advanced communications technologies beyond traditional 
voice-centric devices. The Notice of Inquiry sought comment on a number 
of issues related to the deployment of NG911 networks, including: (1) 
NG911 capabilities and applications; (2) NG911 network architecture; 
and (3) the proper roles of the FCC, other federal agencies, and state, 
tribal, and local governments.
    15. In the last several years, there have been other important 
efforts to address the need for a transition to an NG911 network. In 
the New and Emerging Technologies 911 Improvement Act of 2008, Congress 
tasked the National E9-1-1 Implementation Coordination Office (ICO) 
with developing ``a national plan for migrating to a national [Internet 
Protocol] IP-enabled emergency network capable of receiving and 
responding to all citizen-activated emergency communications and 
improving information sharing among all emergency response entities.'' 
The Department of Commerce's National Telecommunications and 
Information Administration (NTIA) and the Department of 
Transportation's (DOT's) National Highway Traffic Safety Administration 
(NHTSA) jointly manage ICO and released its migration plan in September 
2009.
    16. In March 2010, the National Emergency Number Association (NENA) 
released a handbook to serve as a guide for public safety personnel and 
government officials responsible for ensuring that federal, state, and 
local 911 laws and regulations effectively enable the implementation of 
NG911 systems. Specifically, the NENA Handbook provides an overview of 
key policy, regulatory, and legislative issues that need to be 
considered to enable the transition to NG911. The NENA Handbook states 
that ``it is critical that state regulatory bodies and the FCC take 
timely and carefully scrutinized action to analyze and update existing 
9-1-1, PSTN, and IP rules and regulations to ensure they optimize 9-1-1 
governing authority choices for E9-1-1 and NG9-1-1 and foster 
competition by establishing a competitively neutral marketplace.''
    17. 3GPP has also published a report on the use of Non-Voice 
Emergency Services (NOVES) that provides a general description of 
perceived needs. In addition, ATIS has created its own Interim Non-
voice Emergency Services (INES) Incubator. The ATIS INES Incubator 
``provides the industry with a `fast-track' process for resolving 
technical and operating issues'' and serves as ``an alternative 
approach toward solutions development.''
    18. On October 8, 2010, the President signed the CVAA into law. As 
directed by the CVAA, the Chairman established the Emergency Access 
Advisory Committee (EAAC) for the purpose of achieving equal access to 
emergency services by individuals with disabilities as part of our 
nation's migration to NG911. The EAAC is composed of state and local 
government representatives responsible for emergency management and 
emergency responder representatives, national organizations 
representing people with disabilities and senior citizens, 
communications equipment manufacturers, service providers, and subject 
matter experts. The CVAA directed the EAAC to conduct a national survey 
of people with disabilities and then to make recommendations on the 
most effective and efficient technologies and methods to enable NG911 
access. The EAAC conducted its survey from March 16, 2011, to April 25, 
2011, and received over 3,000 completed responses. On July 21, 2011, 
the EAAC submitted the report on the completed survey to the 
Commission. The EAAC will make its recommendations to the Commission in 
December 2011, which the Commission is then empowered to implement by 
regulation.
    19. In addition, other federal agencies have initiated efforts to 
address access to 911 in an Internet-enabled environment for people 
with disabilities. On March 17, 2010, the United States Access Board 
proposed draft guidelines for real-time text functionality for adoption 
by federal agencies as part of its efforts to update guidelines on 
section 508 of the Rehabilitation Act. In a separate

[[Page 63260]]

proceeding, the Department of Justice is currently reviewing comments 
received in response to an Advanced Notice of Proposed Rulemaking 
(ANPRM) on NG911 access to emergency services by people with 
disabilities. Current DOJ regulations under the Americans with 
Disabilities Act (ADA) require direct and equal access to telephone 
emergency services for people with disabilities who use TTYs. In its 
ANPRM, DOJ notes that many individuals with disabilities are now 
relying on IP-based and digital wireless devices instead of TTYs as 
their primary mode of telecommunications ``and that 9-1-1 call-taking 
centers are shifting from existing traditional telephone emergency 
services to new IP-enabled NG 9-1-1 services.'' The ANPRM addresses two 
objectives: (1) To identify and remove accessibility barriers for 
people with disabilities and who attempt to use personal digital or 
telecommunications devices to directly interact with PSAPs in voice, 
sign language, or text; and (2) to enhance the ability of PSAPs to 
incorporate essential accessibility elements into their IP-based system 
in a coordinated and effective manner. Finally, in compliance with the 
NET 911 Act, the ICO's national plan for migrating to an IP-enabled 
emergency network explored various solutions for providing enhanced 911 
access to people with disabilities.
    20. In March 2011, the Communications Security, Reliability, and 
Interoperability Council's (CSRIC's) Working Group 4B (CSRIC 4B) 
released a report entitled ``Transition to Next Generation 9-1-1.'' 
CSRIC is a Federal Advisory Committee that was tasked with providing 
guidance and expertise on the nation's communications infrastructure 
and public safety communications. Notably, the CSRIC 4B Report 
highlighted that ``the FCC must establish clear rules for accomplishing 
the transition to NG9-1-1'' and that ``[i]f SMS has a role as an 
interim non-voice service used to contact a PSAP, how it is deployed * 
* * will need to be resolved by the FCC.''
    21. On August 30, 2011, the Transportation Safety Advancement Group 
(TSAG) released a report summarizing information that experts in law 
enforcement, fire-rescue, emergency medical services (EMS), and 
transportation operations would like to receive as end users of NG911 
systems. The report provides insight into the cultural, organizational, 
and operational environments of these organizations.

B. Technical Background

    22. In the Notice of Inquiry, we distinguished between use of 
``primary'' and ``secondary'' media types to communicate with PSAPs. In 
brief, primary media types are those that are used to initiate a call 
or communications session with the PSAP, while secondary media types 
are those that are used to provide additional information to the PSAP 
after the call or session has been established. In the current E911 
system, voice and TTY-based text are the only primary media that are 
widely available, and secondary media, such as photos and video, are 
not available.
    23. In addition, while we focus in this NPRM on enabling consumers 
to deliver text and other non-voice media to PSAPs, we note that the 
adoption of NG911 technology will also provide PSAPs with new tools to 
process and analyze this information. In the Notice of Inquiry, we 
cited the potential for NG911 to accommodate a full range of 
specialized devices and functionalities that would enable PSAPs to 
combine multiple streams of information in real time to fashion 
responses to particular emergency scenarios. Examples of such devices 
and functionalities include environmental sensors capable of detecting 
chemicals, highway cameras, security cameras, alarms, gunshot sensors, 
personal medical devices, and telematics in vehicles or on consumer 
devices. For example, in a traffic accident, NG911 would not only 
enable the PSAP to receive the 911 call for help from the caller 
seeking assistance, but also would enable it to correlate the call with 
911 calls from others at or near the scene and combine the information 
with video from nearby traffic cameras to assess the impact on traffic 
and identify the first responders that could reach the scene the 
fastest. In addition, if any vehicles in the accident had automatic 
collision notification systems, the PSAP would receive additional 
information regarding the severity of the crash that could help 
determine the likely medical needs of accident victims and the 
appropriate emergency medical response. Similarly, in a 911 call 
scenario reporting a crime such as a robbery or assault, NG911 would 
enable the caller to send important visual information such as a photo 
of the suspect or a vehicle involved in the crime, and would enable 
first responders to correlate this information with other sources, such 
as nearby security cameras, gunshot sensors, or alarm systems, and to 
quickly access relevant databases that could help identify the suspect 
or the suspect's vehicle.
    24. In this NPRM, we primarily focus on developing text-based 
mechanisms that would serve as new primary media types for contacting a 
PSAP, supplementing voice calling capability and also supplementing or 
replacing TTY-based text. We consider photos and video as secondary 
media that may be used to augment a voice or text call. We recognize 
that this to some degree oversimplifies the potential media 
combinations that NG911 will ultimately support, ranging from single-
medium communications (i.e., voice-only or text-only) to multi-media 
``calls'' that may encompass combinations of interactive and stored 
media, including interactive voice, message-based and real-time text, 
photos, and both stored (previously recorded) and live video. However, 
for purposes of this NPRM, we focus on text as a primary media type and 
photos and video as secondary media types because in early NG911 
deployments, primary communication between a caller and a PSAP is most 
likely to be voice-only or text-only and the availability of secondary 
media may differ based on caller device capabilities, PSAP and ESInet 
capabilities, and PSAP operational choices.
    25. Based on the comments we received in response to the Notice of 
Inquiry, we can distinguish between a number of technical options for 
providing text-based and, in some cases, visual information (photos, 
video) to the PSAP. We briefly summarize these approaches below. We 
note that these options are not exclusive (i.e., a mobile device may 
support more than one option, either as an interim measure, or over the 
longer term). For purposes of this NPRM, we use the term ``caller'' to 
refer to the originator of the 911 communication, whether based on a 
traditional voice call, TTY call, or text message. We also discuss (1) 
mechanisms for providing caller location, both for routing and 
dispatch; (2) the ability of a caller to know whether his or her text 
message has been received by the PSAP; and (3) the possibility of 
establishing a session that permits the caller to conduct a 
conversation with the call taker.
    26. TTY. With a TTY, a person with a hearing or speech disability 
can use a special text telephone to directly contact the PSAP, where 
the call taker uses a similar device to receive and transmit text. TTYs 
have a keyboard and allow people to type their telephone conversations. 
This two-way typing communication can occur with the person with the 
disability and the PSAP

[[Page 63261]]

call taker reading each other's responses on a small LED or backlit LCD 
screen. The disabilities community considers TTY an antiquated 
technology with technical and functional limitations, including its 
slow speed and half duplex mode; the inability of TTY tones to travel 
well using IP audio compression, transmission, and packet loss repair 
techniques without introducing text errors; and its Baudot text 
encoding standard used in the United States that does not include all 
of the characters used in modern text communication. Consequently, it 
is difficult for users to communicate URLs or email addresses, for 
example.
    27. Text-to-Voice TTY-based telecommunications relay service (TRS). 
A TRS system is a telephone service that allows persons with hearing or 
speech disabilities, or who are deaf-blind, to place and receive 
telephone calls. With traditional TRS, a person with a communications 
disability uses a TTY to make a call through a communications assistant 
(CA), who is located at a relay center. To make a relay call, a TTY 
user calls a TRS relay center and types the number of the person he or 
she wishes to call, including 911. The CA then makes the call to the 
receiving party and relays the call back and forth between the parties 
by speaking what a text user types and typing what a voice telephone 
user speaks.
    28. SMS-based. In SMS-based systems, the caller uses a mobile phone 
to send a short text message to the destination, which is typically 
either another mobile phone or an Internet-connected receiver. SMS 
messages are usually limited to 160 characters, although many modern 
handsets support concatenated messages that exceed this limit. Almost 
all existing mobile phones support SMS, except that non-service 
initialized (NSI) devices currently do not permit a caller to send an 
SMS message. SMS messages do not contain any information about the 
caller's location and do not identify the cell tower that received the 
SMS message from the caller's handset. SMS messages are delivered 
through an SMS gateway that relays the messages when capacity is 
available. Thus, SMS messages could in some circumstances be delayed, 
or even occasionally lost, when there is network congestion. Senders of 
SMS messages also may not receive confirmation that their message was 
delivered. More importantly, the sender may not receive an error 
message if the message was not delivered. SMS also does not support 
two-way real-time conversation, although SMS messages have identifiers 
that can allow users to exchange messages in a conversation-like 
manner.
    29. IP-based messaging. There are at least three IP-based messaging 
mechanisms. However, not all of the IP-based messaging mechanisms are 
based on Session Initiation Protocol (SIP), which can be offered as 
part of the Internet Protocol Multimedia Subsystem (IMS). We provide a 
brief description of the three IP-based messaging mechanisms below.
     SIP-based pager-mode. In this mode, the mobile or 
stationary device uses SIP MESSAGE method to send text or Multipurpose 
Internet Mail Extensions (MIME) attachments, including photos, to a SIP 
user agent. Due to the messaging method employed, this method is often 
referred to as pager-mode, in contrast to session mode, which uses 
Message Session Relay Protocol (MSRP). Pager-mode requires an end-to-
end IP connection between the originator and the PSAP, and either the 
originator or the SIP proxy may insert caller location using the SIP 
Geolocation header field. SIP responses allow the originator to 
determine whether the message has been delivered to the recipient. The 
SIP Call-ID may be used to maintain a conversation.
     Message Session Relay Protocol (MSRP). MSRP establishes a 
session between the message sender and the receiver that allows the 
exchange of a series of related instant messages. Typically, MSRP 
sessions are set up via SIP, similar to an audio or video session. As 
with SIP pager-mode, MSRP exchanges complete instant messages; however, 
MSRP imposes less of a burden on the signaling infrastructure.
     Other IP-based message-based protocols. We note that there 
are other proprietary and standards-based Internet text messaging 
protocols, such as Extensible Messaging and Presence Protocol (XMPP). 
However, it appears unlikely that a PSAP would be able to support all 
Internet text messaging protocols; thus, we believe that proprietary 
protocols are likely to be converted to one of the options above or to 
XMPP.
    30. Real-Time Text (RTT). In RTT, individually-typed characters or 
groups of characters are transmitted as separate media packets, using 
the same basic protocol as audio and video sessions. This means that 
with RTT, unlike SMS or IP-based messaging, the recipient sees each 
character or word in the message almost immediately after the sender 
types it. RTT sessions can be established along with audio and video 
sessions and typically use SIP for session signaling.
    31. The table below compares some of the core technical 
characteristics of the options discussed above.

----------------------------------------------------------------------------------------------------------------
                                                                                                Real-time text
                                          TTY              SMS-based      IP-based messaging         (RTT)
----------------------------------------------------------------------------------------------------------------
Delivery to PSAP................  Voiceband modem...  SIP MESSAGE.......  SIP MESSAGE or      RTP payload.
                                                                           MSRP.
Text............................  Only upper case     160 characters of   Any amount of text  Any amount of
                                   letters, numbers,   plain text (some                        text.
                                   limited             may allow longer
                                   punctuation.        text).
Photos, videos in same message?   No................  No................  Yes...............  No.
Real-time audio and video in      No................  No................  Yes...............  Yes.
 same session?
Real-time text..................  Yes...............  No................  No................  Yes.
Full-duplex conversation (both    No................  Limited...........  Yes...............  Yes.
 sides can send messages at the
 same time).
Location information............  Yes, like voice     Maybe (cell tower;  Yes...............  Yes, via SIP
                                   call.               may require                             signaling.
                                                       cellular system
                                                       changes).
End-to-end message reliability    No................  No (may provide     Yes...............  Loss detection and
 and delivery confirmation.                            some confirmation                       redundancy.
                                                       for delivery to
                                                       SMSC).
Message delay...................  Minimal...........  Variable--seconds   Almost always <     Almost always <
                                                       to minutes.         500 ms.             100 ms.

[[Page 63262]]

 
Authentication and message        None..............  Limited (relies on  Messages can be     SRTP.
 integrity.                                            caller ID).         cryptographically
                                                                           signed.
Conversation (session)..........  Like voice call...  Only based on       Yes...............  Yes.
                                                       caller ID.
----------------------------------------------------------------------------------------------------------------

    32. We seek comment on whether our description of texting methods 
and their capabilities in the above discussion is accurate and 
complete. Are there additional technical options that are likely to be 
available in the next few years? Are there additional key 
characteristics that the Commission should consider in evaluating these 
alternative technologies?

III. Discussion

    33. Based on our analysis of information submitted in response to 
the Notice of Inquiry, we find that additional information is needed on 
the following issues related to text-to-911 and multimedia NG911 
applications, and we therefore seek comment on these issues. First, 
what role, if any, should the Commission play in facilitating the 
short-term deployment of text-to-911 using existing infrastructure? 
Second, what role, if any, should the Commission play in facilitating 
the long-term deployment of non-voice emergency messaging services, 
including IP-based messaging and RTT, as well as multimedia 
applications that support delivery of voice, text, photos, video, and 
other data? Third, as the transition to NG911 occurs, what efforts are 
needed to educate the public and minimize consumer confusion, and what 
role, if any, should the Commission play in such efforts? Underlying 
all three of these issues is the question of whether the benefits of 
any potential Commission action to consumers and to public safety will 
substantially outweigh the associated costs. While acknowledging the 
potential difficulty of quantifying benefits and burdens, we need to 
determine whether those benefits outweigh the costs that enabling text-
to-911 and other NG911 services impose on providers and PSAPs. Fourth, 
we seek comment on how best to coordinate this proceeding with our 
implementation of the CVAA and the recommendations of the EAAC. Fifth 
and finally, we consider the Commission's legal authority to take the 
regulatory and non-regulatory actions discussed in this Notice based on 
the record that develops on the issues described herein.

A. Facilitating the Short-Term Deployment of Text-to-911

    34. In the Notice of Inquiry, the Commission highlighted the 
popularity and ubiquity of text messaging and the increasing likelihood 
that consumers will expect to be able to text to 911 during an 
emergency. Indeed, consumers send billions of SMS messages per day and 
more than two-thirds of mobile phone users have used text messaging. At 
the same time, many consumers are acquiring more advanced mobile 
devices (e.g., 3G and 4G handsets) that enable them to send texts using 
``over the top'' software applications that they install on their 
phones and computers. Hence, any discussion about possible short-term 
deployment of text-to-911 must consider the feasibility of both SMS and 
currently available software applications (or software applications 
that could be developed relatively quickly) as interim platforms for 
text-to-911 until providers deploy more advanced NG911 technologies 
based on SIP and RTT. In deciding what role, if any, the Commission 
should play in such an interim deployment, we seek to maximize the 
benefits to consumers while also considering the burden on providers. 
We therefore seek comment on the expected benefits of facilitating 
NG911 deployment, the results of any ongoing trials and standards 
activities involving SMS and software applications, and the relative 
merits of using various approaches to achieve those benefits. When 
evaluating submitted comments, we intend to place more weight on the 
estimated impacts that are supported by hard data or are otherwise 
well-documented.
1. Expected Benefits of Text-to-911 Availability
    35. Although quantifying the benefits of short-term deployment of 
text-to-911 may be difficult, we need to determine whether such a 
deployment will significantly benefit consumers and public safety. On 
this issue, responses to the Notice of Inquiry were divided. Several 
commenters argue that PSAPs and service providers should support SMS-
based text-to-911 on an interim basis. Conversely, a number of 
commenters highlight the disadvantages of using SMS for emergency 
communications and argue that supporting SMS as an interim approach 
would undermine and divert resources from efforts to develop more 
comprehensive long-term solutions. These commenters urge the Commission 
to support standards-setting bodies that are working to develop a 
uniform approach for the delivery of NOVES. No comments were received 
on application-based approaches to text-to-911. Accordingly, we seek 
further comment on the benefits of using SMS and software applications 
for emergency communications, particularly with respect to improving 
911 accessibility for people with disabilities, meeting consumer 
expectations, providing PSAPS with valuable additional information that 
they can in turn share with first responders on the ground, and 
increasing reliability and resiliency of 911 networks.
    36. Accessibility of 911. The ability to text to 911 in the short 
term could substantially improve accessibility to 911 services for 
people with disabilities. In recent years, people with hearing and 
speech disabilities have increasingly migrated away from specialized 
legacy devices such as TTYs and towards more widely available forms of 
text communications because of the ease of access, availability, and 
practicability of text-capable communications devices. This migration 
is most apparent in the declining use of telecommunications relay 
service (TRS) over the PSTN, where the average monthly usage for TTY-
voice based relay service dropped 87% between 2000 and 2010. Moreover, 
as noted in the NOI, the ICO Plan found that ``[t]he biggest gap 
between the technologies used for daily communication and those that 
can access 9-1-1 services is that for the deaf and people with hearing 
or speech impairments.'' In the EAAC's survey, in which respondents 
were primarily drawn from people with disabilities, 48.1% of 
respondents stated that they would prefer to use text messaging to 
contact 911.
    37. Developing text-to-911 capability in the short term could also 
provide benefits by making 911 accessible to consumers in the so-called 
``silent call'' scenario (i.e., in situations where the caller needs to 
contact the PSAP silently or surreptitiously because placing a voice 
call could put the caller in danger). Commonly cited examples of

[[Page 63263]]

the silent call scenario include burglaries, home invasions, 
kidnappings, and hostage situations where a crime is in progress and 
the caller does not want to attract the perpetrator's attention.
    38. Toward that end, we seek more information on the benefits and 
associated costs of facilitating short-term text-to-911 solutions that 
can quickly improve the accessibility of the 911 system. To what extent 
can such short-term solutions assist individuals with hearing or speech 
disabilities? How frequently do people in emergencies encounter a 
silent call scenario where inability to send a text message to 911 
could compromise the caller's safety? Can SMS provide significant 
accessibility benefits in these situations even if it does not offer 
real-time connectivity or enable the caller to send photos or videos, 
unlike some longer-term solutions under development? How, if at all, 
will receipt of texts allow PSAPs to better communicate information 
about an emergency situation to first responders on the ground? What, 
if any, costs will PSAPs incur to implement short-term text-to-911 
solutions? Are there capacity limits on PSAPs' ability to accept texts 
to 911? With respect to interim text-to-911 solutions based on software 
applications, these may only be available on some mobile devices and 
may require additional steps by the user, both to install the 
application and to send the 911 text message. Is this a worthwhile 
trade-off to allow for earlier access to such capabilities than might 
otherwise be available if we were to wait for device replacement and 
fully-integrated NG911 services?
    39. Consumer expectations. Another potential benefit of 
implementing text-to-911 in the short term is that it could help meet 
rapidly changing consumer expectations regarding the desired 
capabilities of the 911 system. According to the Pew Center, more than 
7 out of 10 cell phone users send or receive text messages. With the 
increased use of text messaging, consumers could expect that their use 
of SMS extends to 911. We seek comment on whether promoting or 
requiring short-term text-to-911 solutions accurately reflects current 
and evolving consumer expectations and the needs of PSAPs and first 
responders. Does the rapid growth in the popularity of SMS messaging 
generate consumer expectations that SMS will support 911 texting? We 
seek information regarding how many people have attempted to text to 
911 during emergencies but failed. Have there been instances where the 
ability to send a text message to 911 could have made a significant 
difference in the ability of first responders to assist the caller or 
the speed of the response? We also seek information that quantifies the 
impact that incorrect consumer expectations about the ability to text 
to 911 may have on the health and safety of the public.
    40. Improved information for PSAPs. As we have noted above, in 
addition to improving communications between consumers and PSAPs, NG911 
has the potential to enhance the ability of PSAPs and first responders 
to assess and respond to emergencies in real-time based on the texts, 
photos, and videos that consumers send to them, combined with 
information gathered and correlated from other sources. In this regard, 
what benefits, if any, could the short-term deployment of text-to-911 
(which would not include the capability to transmit photos or video) 
provide PSAPs and first responders? For example, could texts to 911 
provide additional information to assess the nature and severity of an 
emergency, help apprehend criminal suspects, speed emergency response, 
reduce the need to dispatch multiple types of emergency response (e.g., 
sending police, fire, and emergency medical personnel to a scene 
because the nature of the emergency is undetermined), or make it easier 
to screen potentially fraudulent or malicious calls? How do such 
benefits compare to the cost of short-term deployment of text-to-911? 
Would short-term implementation of text-to-911 increase the volume of 
911 traffic or the time and resources required for PSAPs to process 
information as compared to handling voice calls? If so, are PSAPs 
equipped to handle such increases? If not, what do PSAPs need to do to 
prepare and what resources do they require?
    41. Improved reliability and resiliency. In large-scale disasters, 
circuit-switched landline and mobile networks may become overloaded, 
making it more difficult to place a 911 voice call. As landline and 
mobile networks migrate from circuit-switched to IP-based packet-
switched technology, the risk of overload or congestion may dissipate, 
but in the interim, enabling SMS and IP-based text messages to 911 
could be beneficial because text consumes far less bandwidth than voice 
and may use different spectrum resources or traffic channels. Thus, 
people in disaster areas may still be able to send text messages to 911 
even if they cannot place a voice call. Similarly, with improved 
technology, PSAPs may be able to filter text messages by incident, so 
that they spend less time with voice callers who report the same 
incident. We seek comment on the prospective impact of text messaging 
on PSAP operations and emergency response during large-scale disasters, 
with particular emphasis on experiences of overload-induced 911 
failures. For example, there have been news reports that cell phone 
service, including the ability to reach 911, was impaired immediately 
after the August 23, 2011 East Coast earthquake, while SMS and email 
did not experience service disruptions.
2. Ongoing Text-to-911 Trials
    42. To date, there have been only a small number of SMS-to-911 
trials in the United States, although a number of jurisdictions are 
reportedly considering trials or near-term implementations. In 2009, 
Intrado and i wireless, a T-Mobile affiliate, initiated an SMS-to-911 
trial in Black Hawk County, Iowa. In this trial, only Black Hawk County 
residents who subscribed to i wireless were able to make use of the 
text-to-911 service. Text messages sent in the trial did not carry 
location information, so users were prompted to enter their zip codes 
before the text message was forwarded to the PSAP. Despite the limited 
nature of the trial, county representatives have credited text-to-911 
with positive outcomes in several emergency situations. On the other 
hand, AT&T contends that publicity about the Black Hawk County trial 
resulted in confusion that ``spread throughout the country'' regarding 
where text-to-911 was available.
    43. In August 2010, the Marion County, Florida, Sheriff's Office 
developed an in-house text message to 911 system. Named ``ADD IT NOW,'' 
the program enables the Sheriff's Office Communications Center to 
receive urgent text messages on a dedicated screen that uses a yellow 
indicator light to signal incoming texts. The Sheriff's Office has 
advertised the availability of the number and has encouraged local 
citizens to add the number to their phone directories. The Sheriff's 
Office reports that the system cost $1,000 to develop and costs 
approximately $50 per month to maintain. The system does not convey 
location information.
    44. On August 3, 2011, the City of Durham, North Carolina, 
announced an SMS-to-911 trial in partnership with Intrado and Verizon 
Wireless. According to Durham, the trial is specifically designed for 
two types of emergency scenarios: emergency help requests from people 
with disabilities and from people not wanting someone to hear them make 
a 911 call. When receiving a text, the Durham PSAP will not be able to 
automatically determine

[[Page 63264]]

the caller's location. To ensure that consumers are aware of this 
limitation, the city is making efforts to educate the public that they 
must include location information when sending an SMS-to-911. Durham 
has scheduled the trial to conclude on January 31, 2012, and will 
restrict the trial to Verizon Wireless customers in areas served by the 
Durham PSAP.
    45. In June 2011, Cassidian Communications announced the successful 
completion of a ``simulation'' SMS-to-911 trial in Harris County, 
Texas, involving the Greater Harris County backup PSAP. According to 
Cassidian, ``[t]he testing during the trial utilized automatic location 
identification (ALI) capabilities allowing for the call takers to 
identify the location of the caller * * * Many operational 
implementation and procedure related elements remain to be discussed 
and ultimately implemented * * * It is anticipated that the technology 
will be available to the deaf and hard of hearing population in the GHC 
9-1-1 territory within a year [after June 20, 2011] and subsequently 
will be offered to the rest of the population.'' Unlike the Black Hawk 
County and Durham trials, this trial did not involve members of the 
public.
    46. Several European countries, including Estonia, Iceland, 
Luxembourg, Sweden, and the United Kingdom offer emergency SMS services 
or are planning to offer such services in the near future. In all of 
these countries, the SMS message does not automatically include 
location information, which the sender of the SMS message is expected 
to provide manually. The Swedish SMS system, however, is capable of 
determining cell-tower location. In all of these countries, the SMS 
service is primarily directed towards people with disabilities and 
requires users to register in advance of using the service. 
Additionally, after the SMS PSAP receives and processes a text message, 
it forwards the necessary information to the appropriate voice PSAP. We 
seek comment on the above-described text-to-911 trials and on text-to-
911 services offered in these countries. What are the advantages and 
disadvantages of the various approaches to text-to-911? What lessons 
could the United States draw from the international examples?
    47. Standards. We seek comment on any standards-development 
activities by industry or standards-setting bodies that may play a role 
in the short-term deployment of text-to-911 services based on SMS or 
software applications. We also seek comment on whether there are any 
additional text-to-911 trials or standards efforts that have been 
conducted thus far or that are contemplated in the near future. We 
request that commenters provide the Commission with any relevant data 
that has been gathered from these trials and standards-setting efforts, 
including the number of individuals who sent text messages to 911 
during the trials, whether PSAPs could locate those callers, and the 
effectiveness of texting as a means of communicating with PSAPs.
3. Approaches Based on SMS and Existing Infrastructure
    48. In the Notice of Inquiry, the Commission sought comment on a 
number of issues related to SMS-to-911. The Notice of Inquiry 
recognized that SMS is not a synchronous messaging service and 
therefore does not provide a means for the sender to know whether and 
when his or her message has reached its destination. It also noted that 
because each SMS message is independent of its predecessors and 
successors, messages within the same logical conversation may not be 
routed to the same destination or in the proper sequence. Further, the 
Notice of Inquiry referenced concerns about whether the recipient of an 
SMS message could reliably and accurately determine the sender's 
geographic location.
    49. Comments. Wireless providers and some industry standards bodies 
are generally opposed to adopting or requiring SMS-to-911 as an interim 
solution. Many wireless providers argue that SMS is unreliable and 
should not be used for emergency communications. AT&T contends that 
``SMS suffers from significant limitations that make it both dangerous 
and infeasible to rely on for emergency communications,'' because there 
is no guarantee of delivery for SMS messages and no acknowledgment 
provided to the sender. AT&T characterizes SMS as ``a best-effort, 
store-and-forward service [making] it unreliable and prone to 
unacceptable delays for purposes of emergency communications.'' T-
Mobile and Verizon similarly argue that SMS lacks important 
functionalities and reliability that are needed for a viable emergency 
communications service. Verizon argues that the interests of PSAPs, 
consumers, and service providers ``would be better served by focusing 
on incorporating RTT and more advanced messaging technologies into IP-
based platforms and into the wireless industry's deployment of 4G LTE 
technology.'' ATIS notes that current SMS standards do not support 
automated routing to the PSAP or automated location information, which 
are critical to emergency communications. Further, ATIS argues that 
because of ``the higher probability of SMS-to-911 message failure, 
liability protection for SMS-to-911 services must be far stronger than 
that currently provided for voice calls.''
    50. Public safety commenters express similar concerns about SMS-to-
911. NENA states that ``[t]oday, SMS lacks many of the characteristics 
needed to support quality emergency communications.'' NENA therefore 
``does not advocate the use of SMS as a means to access 9-1-1 
systems.'' APCO notes that ``there are a number of Quality of Service 
concerns with the use of SMS to 911.'' Wichita-Wilbarger states that 
``SMS messaging is distinctly unsuitable for communications with 
emergency services [because] SMS messaging does not allow for real-time 
communication [which] raises the possibility of miscommunication with 
the PSAP.''
    51. However, some 911 technology and software providers support the 
use of SMS as an interim solution for emergency communications and 
contend that there are ways to overcome some of its technical 
limitations. TCS states that ``based on existing public expectations 
both from current SMS users and members of specialized communities, it 
is generally accepted that the introduction of SMS to 911 is 
inevitable.'' TCS also notes that ``SMS to 9-1-1 communication can be 
controlled so that a Dispatcher receives information that is timely, 
dependable, and adequate enough to make a professional dispatch 
decision.'' Moreover, TCS states that it has ``demonstrated in its 
laboratory and in limited field experiments that SMS emergency service 
can be provided reliably and in the near term.'' TSAG maintains that 
``under certain emergency settings, SMS messaging represents an 
important (at times only) alternative to voice communications [and] 
public expectations suggest NG911 systems be configured to accept and 
manage SMS based emergency communications, notwithstanding the 
technical and operational `challenges'.'' Intrado maintains that ``SMS 
is a viable, reliable, interim solution for situations in which those 
who are in emergencies are not in a position to place a voice call to 
9-1-1.'' The ATIS INES Incubator is considering several interim 
solutions for text-to-911 and divides these solutions into two groups, 
``consumer to PSAP'' and ``consumer to relay services to PSAP.'' Among 
the ``consumer to PSAP'' solutions that the ATIS INES Incubator is 
considering are: emergency voice call then SMS, emergency voice then 
web chat, instant messaging, RTT direct to PSAP, RTT converted to TTY,

[[Page 63265]]

TTY emulation, video ASL, and SMS direct to PSAP. Among the ``consumer 
to relay services to PSAP'' solutions that the ATIS INES Incubator is 
considering are: IP relay service, video relay service, national SMS 
relay, national RTT relay, and home PSAP relay.
    52. L.R. Kimball (Kimball) ``supports the development of a SMS to 
911 solution'' and believes that many of the limitations cited by other 
parties can be resolved by ``[s]electing a different point of 
interconnection between the SMS system and 911.'' According to Kimball, 
such limitations are the ``consequence of the selected point-of-
interconnection (POI) between the SMS system and 911, namely, at the 
store-and-forward service,'' however, selecting a different POI ``may 
permit many of these problems to be resolved and, if implemented 
properly, should not seriously or significantly impact the operation of 
the existing SMS system.'' Specifically, Kimball argues that ``a store-
and-forward function need not exist between the SMS originator and [a] 
PSAP, provided a suitable POI can be found ahead of the store-and-
forward function.'' Further, according to Kimball, specific elements of 
the telephone industry standard Signaling System 7 (SS7) network can 
provide ``an effective and convenient POI for interconnecting SMS 
systems with a new 911-specific SMS service'' and many mobile telephone 
switches allow for the design of ``several possible mechanisms that can 
be used to separate SMS to 911 messages from normal SMS processing.'' 
Consequently, Kimball contends that ``with SMS to 911 messages 
separated from the SMS system, it becomes possible to implement a 
dedicated SMS to 911 [Signaling Control Point (SCP)] [that] can address 
most, or even all, of the technical objections to a SMS to 911 service 
and can do so without impacting the SMS store-and-forward functions 
that are in widespread use today.'' An SMS to 911 SCP can perform 
functions such as ``gateway and protocol conversion functions from SS7 
to NG911, including signaling and media conversion''; ``assigning a 
`session identifier,' so that successive SMS messages (from the same 
phone) reach the same dispatcher via the NG911 network''; ``providing 
acknowledgement or negative delivery text messages back to the 
originator of the emergency text message''; and ``querying the wireless 
carrier's position determining system in an attempt to locate the 
originator's location.''
    53. Discussion. The record indicates that SMS-to-911 has a number 
of technical limitations that affect its ability to support reliable 
emergency communications. SMS is essentially a store-and-forward 
messaging service that is not designed to provide immediate or reliable 
message delivery; does not support two-way real-time communication; 
does not provide the sender's location information; and does not 
support the delivery of other media such as photos, video, and data. 
All of these factors appear to make SMS inappropriate as a long-term 
text-to-911 solution and warrant caution in encouraging it as a short-
term solution. At the same time, SMS-to-911 offers certain significant 
potential benefits as an interim solution. It can be deployed 
relatively quickly, consumers have already embraced the technology, and 
the vast majority of wireless providers and mobile devices support SMS. 
Moreover, the trials in other countries that we described above 
indicate that SMS can supplement voice-based 911 services. In addition, 
some commenters have suggested that it is possible to overcome or 
mitigate some of the technical limitations of SMS at a reasonable cost 
to providers, PSAPs, and consumers.
    54. Balancing these considerations, we believe that PSAPs, 
providers, and vendors should have the option to implement SMS-to-911 
as a short-term alternative. We seek comment on this view and on 
whether the benefits of leveraging SMS-to-911 on an interim basis 
outweigh the limitations of SMS. We also encourage SMS-to-911 trials by 
interested parties to develop improved information about the strengths 
and limitations of this approach, and we request that participants in 
ongoing and future trials (existing and future) submit their trial data 
and findings in this proceeding.
    55. We also seek comment on the feasibility of overcoming or 
mitigating SMS technical limitations at a reasonable cost to providers, 
PSAPs, and consumers. Specifically, we seek comment on Kimball's 
proposal regarding selecting a different point of interconnection 
between the SMS system and 911. How technically feasible is this 
solution, and on what percentage of mobile switching infrastructure 
could it work? Kimball notes that ``there is no business or regulatory 
driver to implement a SMS to 911 interconnection [and] implementation 
and maintenance would be an additional cost to providers and there is 
no process in place to recoup those expenditures.'' We seek comment on 
the costs of implementation of this proposal, including ongoing 
maintenance and operation costs. We also seek comment on any activities 
by standards-setting bodies that may play a role in the short-term 
deployment of SMS-based text-to-911 services. Intrado argues that any 
text-to-911 ``solution should use the digits 9-1-1.'' We seek comment 
on whether a national short code for SMS-to-911 should be designated by 
the Commission, a standards-setting body, or some other entity. If so, 
how should this short code be designated and implemented?
    56. Further, one limitation that most commenters recognized is the 
inability of SMS to provide accurate location information for routing 
or PSAP dispatch purposes. To overcome this limitation, would it be 
technologically feasible for the recipient of an emergency SMS, such as 
the ALI database provider, to query for the location using the phone 
number provided, assuming that it can identify the originating 
provider? Have such techniques been tested experimentally? If this is 
feasible, could such a query work for all SMS messages or would it only 
be available for certain classes of messages (e.g., only for messages 
sent while the user is not roaming or for domestic customers)? Are 
there other limitations? If there are such limitations, is there data 
to quantify the fraction of SMS messages or users likely to be 
affected, extrapolating from non-emergency use of SMS? What costs would 
be associated with such a solution? How much time would separately 
checking the ALI database to determine the location of an individual 
texting to 911 add to response time?
4. Approaches Based on Software Applications
    57. As noted above, many consumers are acquiring more advanced 
mobile devices (e.g., 3G and 4G handsets) that enable them to install 
applications on their phones, including applications to send text 
messages without using SMS or MMS, sometimes referred to as ``over the 
top.'' We seek comment on the feasibility of using general texting or 
911-specific applications to support a transitional non-voice NG911 
system that would allow consumers to send text and other non-voice 
media to PSAPs. Such a system would consist of two components: (1) One 
or more databases that describe where text-to-911 capabilities are 
available and how to reach the appropriate PSAP; and (2) one or more 
software applications for smartphone operating systems. Providers and 
third parties, including but not limited to systems vendors that 
currently provide services and equipment to PSAPs, could develop such 
applications. The application

[[Page 63266]]

would obtain location information, including cell tower identity, from 
smartphone operating systems and would rely on standard IP connectivity 
to deliver a message to the right destination based on a location 
database. The database would map approximate location data to a PSAP or 
ESInet IP address or indicate that text service is not available for 
that location.
    58. This system architecture has several potential benefits, 
including the fact that it could be rolled out in a relatively short 
period of time and that it would not require any major provider network 
or mobile handset upgrades. We seek comment on the costs and timeframe 
for deploying such a system. How would such a system be structured to 
reduce the time to deployment, minimize the effort required by 
providers, and maximize the operational reliability of the system? We 
also seek comment on whether it would be possible for this system to 
support other media besides text, including voice, video, images, and 
data. Could the system be made compliant to existing and emerging 
standards? Would PSAPs need to have access to broadband IP connectivity 
or should the system allow for translation of text messages (e.g., to 
TTY-based messaging)? Would PSAPs need to install any additional 
software or hardware? If so, what specific costs would be associated 
with such installation? Is it possible for an application to 
automatically detect whether a PSAP is capable of receiving only text 
or also other advanced media types, such as images? How would an entity 
or entities be selected to build and maintain the national database(s) 
of where text-to-911 applications work and what costs are associated 
with creating and maintaining a database? Who should bear those costs? 
What entities would provide the smartphone application? Should there be 
a process whereby applications are certified in some way? If so, what 
entity should perform this certification?
    59. Under this system, only users of smartphones would be able to 
install the applications that would enable them to send text messages 
to 911. How, if at all, should the Commission address this issue? Could 
the system outlined above be adapted to handle SMS messages a