Kari’s Law

ISPs should be aware of two new laws that went into effect in January. The first is Kari’s law. This law requires that all phone systems sold, leased or installed after February 16, 2020 must be pre-configured so that a user can directly dial 911 with no other dialing steps required. This law is aimed to bring the 911 system into buildings served by PBXs, keysystems, Centrex, and cloud-based VoIP. The intent is to improve 911 for places like hotels, universities, hospitals, and businesses. This law puts the responsibility to comply not only on phone system manufacturers, but also on anybody who installs, manages, or operates a voice system.

The law also creates new requirements on existing phone systems that went into effect on January 6. Phone systems must be configured so that any call placed to 911 will immediately notify a ‘central location’ that a call has been placed to 911. This must be implemented immediately for any existing phone system that can provide the notification without needing a software or hardware upgrade. The FCC believes that a large percentage of phone systems are capable of making such notifications, so those notifications must be activated. It’s worth noting that there is no exemption for small businesses – anybody operating a private phone system is expected to comply with the law. Interestingly, the law applies to outward-calling locations like an outbound call center that can’t receive calls.

The FCC leaves a lot of interpretive room in defining a ‘central location’ for delivering the notification. Their goal is that a notification of a call to 911 must be sent to a location where there is a high likelihood that somebody will see it. The FCC wants 911 centers to be able to contact somebody at a business to gain entrance and to hopefully locate the person that made the 911 call.

Notifications can be in any format including emails, text messages, pop-up notifications, alarms, etc. The new rules also require some ancillary information to be included in the notification, where technically feasible. This includes information like a callback number and as much information as possible about the location of the 911 caller (room number, the wing of building, etc).

To the extent possible this also applies to ‘mobile’ devices that are controlled by a phone system. This might include cordless phones used inside of a business or desksets that can be moved anywhere within the business. Companies are not expected to track commercial cellphones that aren’t on their system or the location of devices that are carried off-site.

The second law that went into effect in January is Ray Baum’s Act. One of the many provisions of this law requires that 911 centers be provided with ‘dispatchable location’ information. In plain English, that means that first responders want to know ‘the right door to kick down’ when responding to a 911 call. This goes into effect concurrently with Kari’s law and means that businesses must provide more information to 911 centers about how to respond to call made from their location.

This new law is also aimed at the same kind of buildings as Kari’s law – places like hotels or a business where a 911 responder doesn’t know how to locate the person that called 911. At a minimum, every call to 911 must convey a validated 911 street address. That’s routine information for calls made from single-family homes, but not necessarily so for a complex business like a hospital or business high-rise complex. If a validated 911 address can be conveyed today it must be done so. Businesses are given one year to implement this change and are expected to coordinate with 911 centers if they want to provide complicated information on room number, building layouts, etc.

The law also requires better reporting for mobile devices that are controlled by a phone system. The rules expect the notification to 911 to include the best information possible about the location of a caller with a mobile device such as a cordless phone. This could be as detailed as a room number or something less accurate such as the location of the nearest WiFi hotspot. Companies have two years to implement this change.

The changes that come from the Roy Baum Act are intended to be coordinated with the nearest 911 PSAP so that they understand the nature and quality of the location data when they get a call. Businesses are expected to notify, and test as needed, to make sure that PSAPs know how to locate callers at a business. The FCC has the ability to fine parties that don’t comply with the law, and so expect a few test cases within the next year when businesses fail to implement the new rules or else fail to convey information to their 911 center.

The Huge CenturyLink Outage

At the end of December CenturyLink had a widespread network outage that lasted over two days. The outage disrupted voice and broadband service across the company’s wide service territory.

Probably the most alarming aspect pf the outage is that it knocked out the 911 systems in parts of fourteen states. It was reported that calls to 911 might get a busy signal or a recording saying that “all circuits are busy’. In other cases, 911 calls were routed to the wrong 911 center. Some jurisdictions responded to the 911 problems by sending out emergency text messages to citizens providing alternate telephone numbers to dial during an emergency. The 911 service outages prompted FCC Chairman Ajit Pai to call CenturyLink and to open a formal investigation into the outage.

I talked last week to a resident of a small town in Montana who said that the outage was locally devasting. Credit cards wouldn’t work for most of the businesses in town including at gas stations. Businesses that rely on software in the cloud for daily operations like hotels were unable to function. Bank ATMs weren’t working. Customers with CenturyLink landlines had spotty service and mostly could not make or receive phone calls. Worse yet, cellular service in the area largely died, meaning that CenturyLink must have been supplying the broadband circuits supporting the cellular towers.

CenturyLink reported that the outage was caused by a faulty networking management card in a Colorado data center that was “propagating invalid frame packets across devices”. It took the company a long time to isolate the problem, and the final fix involved rebooting much of the network electronics.

Every engineer I’ve spoken to about this says that in today’s world it’s hard to believe that it would take 2 days to isolate and fix a network problem caused by a faulty card. Most network companies operate a system of alarms that instantly notify them when any device or card is having problems. Further, complex networks today are generally supplied with significant redundancy that allows the isolation of troubled components of a network in order to stop the kind of cascading outage that occurred in this case. The engineers all said that it’s almost inconceivable to have a single component like a card in a modern network that could cause such a huge problem. While network centralization can save money, few companies route their whole network through choke points – there are a dozen different strategies to create redundancy and protect against this kind of outage.

Obviously none of us knows any of the facts beyond the short notifications issued by CenturyLink at the end of the outage, so we can only speculate about what happened. Hopefully the FCC enquiry will uncover the facts – and it’s important that they do so, because it’s always possible that the cause of the outage is something that others in the industry need to be concerned about.

I’m only speculating, but my guess is that we are going to find that the company has not implemented best network practices in the legacy telco network. We know that CenturyLink and the other big telcos have been ignoring the legacy networks for decades. We see this all of the time when looking at the conditions of the last mile network, and we’ve always figured that the telcos were also not making the needed investments at the network core.

If this outage was caused by outdated technology and legacy network practices then such outages are likely to recur. Interestingly, CenturyLink also operates one of the more robust enterprise cloud services in the country. That business got a huge shot in the arm through the merger with Level 3, with new management saying that all of their future focus is going to be on the enterprise side of the house. I have to think that this outage didn’t much touch that network, just more likely the legacy network.

One thing for sure is that this outage is making CenturyLink customers look for an alternative. A decade ago the local government in Cook County, Minnesota – the northern-most county in the state – was so frustrated by continued prolonged CenturyLink network outages that they finally built their own fiber-to-the-home network and found alternate routing into and out of the County. I talked to one service provider in Montana who said they’ve been inundated after this recent outage by businesses looking for an alternate to CenturyLink.

We have become so reliant on the Internet that major outages are unacceptable. Much of what we do everyday relies on the cloud. The fact that this outage extended to cellular outages, a crash of 911 systems and the failure of credit card processing demonstrates how pervasive the network is in the background of our daily lives. It’s frightening to think that there are legacy telco networks that have been poorly maintained that can still cause these kinds of widespread problems.

I’m not sure what the fix is for this problem. The FCC supposedly washed their hands of the responsibility for broadband networks – so they might not be willing to tackle any meaningful solutions to prevent future network crashes. Ultimately the fix might the one found by Cook County, Minnesota – communities finding their own network solutions that bypass the legacy networks.

The FCC Looks at 911

The FCC recently released its tenth annual report to Congress reporting on the collection and distribution of 911 fees nationwide. The report includes a number of interesting statistics, a few which will be listed below.

But first I’d like to look backwards a bit because we now take 911 for granted, but it hasn’t always been so. 911 has been implemented during my adult lifetime. The idea for having an emergency phone number was first introduced in 1967 by Lyndon Johnson’s Commission on Law Enforcement. AT&T selected the 9-1-1 digits the following year. An independent telco, the Alabama Telephone Company leaped on the concept and introduced 911 in Haleyville, Alabama in 1968 – but it then took decades for the implementation nationwide since this was deemed a local issue to be implemented by local governments. I recall the introduction of 911 in the DC suburbs in the mid-70s, accompanied by a flurry of radio, newspaper and TV ads to inform the public of the new safety service. There were major metropolitan areas like the Chicago suburbs that didn’t get 911 until the early 1980s.

911 service has been enhanced over the years. For example, by 2015 96% of homes in the US were covered by E-911 (enhanced) where the 911 operator knows the caller’s location according to the phone number for landlines or by using triangulation of cell sites for mobile phones. Currently 911 systems are upgrading to NG911 (next generation) that ties 911 systems into broadband to be able to relay text messages, photos and videos as part of the 911 process.

Some of the interesting statistics from the FCC report:

  • In 2017 almost $3 billion was collected in 911 fees to fund local 911 efforts. The total cost to provide 911 was reported at $4.8 billion, with 911 services in many states also funded partially by tax revenues.
  • States collect 911 fees in different ways. This includes flat rates per telephone or cellular lines, percentage of telecommunications bills, and flat rate per subscriber. Fees vary widely and range from $0.20 per residential landline in Arizona to $3.34 in West Virginia per cell phone. There are states that charge eve more for business landlines.
  • Most states use the 911 fees to fund the 911 service, but six states – Montana, New Jersey, New York, Rhode Island and West Virginia use some of their 911 fee to fund non-safety purposes or even just to go into the general funds of the state. In total $284 million was diverted from collected 911 fees.
  • Thirty-five states, Puerto Rico and the District of Columbia have begun the process of upgrading to NG911.
  • Sixteen states have deployed statewide Emergency Services IP Networks (ESInets) for exclusive use of public safety agencies.
  • Thirty states, Guam, Puerto Rico and the US Virgin Islands have not taken any steps for cybersecurity for 911 centers (PSAPs).
  • There are 5,232 PSAPs in the country. These range from tiny centers in sheriff stations in rural counties to massive 911 centers in major metropolitan areas. For example, Washington DC has one PSAP while there are 586 in Texas.
  • 1,381 PSAPs now had the ability to communicate with the public by text message. Another 1,103 PSAPs will be implementing that capability in 2018.
  • There were over 39,000 operators employed to take 911 calls in 2017.
  • Only 44 states reported 911 call volumes and in those states there were over 211 million calls to 911. Over 70% of calls now come from cellular phones.

I know it’s easy to hate regulation, but without it we wouldn’t have a 911 system that works so well. People in most of the country feel a lot safer knowing they can dial 911 and get help when needed.

A Regulatory Level Playing Field?

European_UnionThere is an interesting discussion worth noting occurring in Europe right now – regulators there are asking if regulations that apply to traditional telecom providers ought not to also apply to companies offering similar services on the web. This discussion is the culmination of many years of lobbying by telecom companies asking for a ‘level playing field’. The executive branch of the European Union is expected this week to propose that online services be subject to the same regulation as companies that offers similar telecom services.

What might that mean for web companies? It might mean that if Skype or Google Voice allows people to make ‘telephone calls’ that these providers might have to provide their customers access to dialing 911. It might require that any online service that gives their customers a telephone number might have to allow customers to keep that number for other purposes (number portability). It might even mean that web companies might be subject to some of the provisions of net neutrality.

It’s easy to think that voice-related regulation of telecom companies is largely a thing of the past. Telecoms in the US have asking in a number of states to be deregulated for voice purposes – a trend that has accelerated since the FCC declared that landline voice is no longer a dominant service.

And certainly the days are gone when the FCC and the state Commissions regulated the price of every telecom product and set a lot of the rules about how a telecom company had to interact with customers. The most draconian aspects of telecom regulation have been relaxed, and in many cases are gone completely.

Yet there are still a lot of rules that apply to telecom companies both here and in Europe. There are rules about 911 and safety issues. There are the CALEA rules that require telecoms to comply with law enforcement surveillance of customers. There are privacy rules, and truth-in-billing rules and numerous other rules that telecoms are still expected to comply with, even as they are free to sell or bundle their products in any way they want.

The European Union is asking some good questions – and if this is adopted these same questions are going to get asked here in the US as well. Why, if Skype sells themselves as an alternative for service should they not have to provide the ability for a customer to dial 911? Why shouldn’t any web-based voice provider not have to comply with the same requirements for privacy, law enforcement or number portability as a landline or cellular telco?

Of course, given a choice the telcos would probably rather that these remaining regulations not apply to them. There is certainly a big push from the big US telcos to get out from all voice regulations. But there are at least some aspects of telecom regulation that are not likely to go away. It’s been proven many times how 911 saves lives. And there is a general belief among regulators that privacy and billing rules protect citizens from telco abuses. And law enforcement is unlikely to bend on the requirement that a telco of any sort help them implement a wire-tap order from a judge.

It’s interesting to me that the regulations here and in Europe are so similar. But I guess that a lot of regulation is the result of trying to address the same issues. For example, if customers have a right to privacy, then there are only so many ways this can be applied to a telephone customer.

The bottom line is that if this is implemented in Europe, and if the web-based companies are able to comply with these regulations, then I think we can expect that same concept to find it’s ways here in a few years. At the end of the day regulators like to regulate and there are a whole lot of voice-like services today on the web that are not subject to some of the basic things that are regulated for every other provider.

The Next Generation of 911

EMRI’ve started noticing news articles talking about the next generation of 911 (NG911), so it seems the public is starting to be aware that there is a big change coming in the way that 911 works. We are in the process nationwide of migrating from the traditional 911 to a fully IP-based system that will include a lot of new features. When fully implemented, NG911 will allow interactive text messaging and for smart call routing using caller location that will consider factors such as the workload at the closest 911 center, current network conditions, and the type of call. The NG911 system will enable a data stream between callers and the 911 center so that there can be an exchange of pictures, videos (including support for American Sign Language), and other kinds of data that will enhance the ability of a 911 center to do their job such as building plans or medical information.

NG911 will be implemented in phases and many places are already experimenting with some of the new features like text messaging. But other parts of the final IP-based 911 are still under development.

NG911 is going to replace today’s circuit-switched 911 networks that carries only voice and a very limited amount of data. Today each carrier that handles voice calls must provide dedicated voice circuits between them and the various 911 centers that fall within their service area. For landlines the 911 center that any given customer contacts is predetermined based upon their telephone number.

But the number-based 911 has been having problems with some kinds of calls. There are numerous examples of where 911 was unable to locate mobile callers since they tried to use triangulation to find the location of a caller to 911. And for a number of years it’s been possible to move a VoIP phone to anywhere that has a data connection and the current 911 systems have way to identify or know the location of such callers. And identifying callers is going to get harder as we start seeing huge volumes of WiFi-based VoIP from cellphones as cellular carriers dump voice traffic onto the landline data network in the same manner they have with other data. The promise is that NG911 will be able to handle the various flavors of VoIP.

There are a lot of new standards being developed to define the operating parameters of NG911. The standards are being driven though NENA, the National Emergency Number Association. Many of these standards are now in place, but standards keep evolving as vendors try different market solutions. A lot of the new NG911 is going to be driven by the creation and use of a number of new database systems. These systems will be used to manage functions like call validation, smart routing control, and the processing of new NENA-approved call records.

The new IP-based 911 networks are being referred to as ESInets (Emergency Service IP Networks). There are managed private networks that will be used to support not only 911 but also other types of public safety communications.

The overall goal is to do a much better job responding to emergencies. Today there are far too many examples of calls to 911 that never get answered, calls that are sent to the wrong 911 center, or calls where the 911 operators can’t determine the location of the caller. Further, the new system will allow for the public to summon 911 in new ways other than through voice calls. There will be a two-way process for sending pictures and videos to the 911 center or floor plans and medical advice back to callers. When fully implemented this should be a big leap forward resulting in reduced costs due to more efficient use of our emergency resources as well as more lives saved.

FCC Establishes Guidelines for Back-up Power for Voice

FCC_New_LogoIn perhaps one of the oddest rulings I have ever seen out of the FCC, they just ordered a very specific set of rules about providing back-up power for telephone lines that are not powered by copper.

I see this as odd for two reasons. First, this is fifteen years too late. There are tens of millions of customers that are served without backup power today. Customers that get phone service from cable companies, fiber networks, and other VoIP systems don’t have backup power unless the provider has gone out of their way to provide it.

Second, this is obviously the FCC’s way of making it harder for the large telcos to knock people off of copper networks. But in doing so the FCC is punishing the rest of the industry by adding new rules and new costs . .

These new rules seem like a solution without a problem. Why do I say that? We no longer have a world full of the old Western Electric telephones that are powered by the copper network. A phone that has any features, which most modern phones do, must be plugged into home power to work. Further, there have been tens of millions of customers who have elected to take phone service from cable companies and fiber providers, which do not provide backup. And there has not been a huge outcry from these many customers over the last ten years about lack of power backup. The main reason for that is probably that the vast majority of homes have a cellphone today and don’t rely on their home telephone as a lifeline.

Here is what the FCC ordered:

  • The ruling only covers residential fixed voice services that do not provide line power (which is done by telephone copper). This does not apply to business customers.
  • This must be implemented within 120 days by large companies and within 300 days by companies with less than 100,000 domestic retail subscriber lines.
  • The back-up power must include power for all provider-furnished equipment and anything else at the customer location that must be powered to provide 911 service.
  • From the effective date, companies must describe to each new customer, plus to every existing customer annually the following:
    • The solutions offered by the company to provide 8 hours of backup for phone service, including the cost and availability;
    • Description of how the customer’s service would be affected by loss of power;
    • Description of how to maintain the provided backup solution and the warranties provided by the company;
    • How the customer can test the backup system;
  • Within three years of the effective date of the order a provider must provide a back-up solution that is good for 24-hours and follow the above rules.

This just seems like something that should have been addressed in 2000 and that it is far too late to be putting rules in place for this now. This merely adds regulatory cost to every provider without any real benefit to customers. In a lot of networks, if the neighborhood loses power so does the service provider. If such a network is down then no amount of power at the home is going to provide voice service. And there are networks that are going to require a very expensive solution for providing 24-hour back-up if it is even reasonably affordable at all.

The order doesn’t say the back-up solution has to be affordable, and the cynical me says that this is an opportunity for the phone companies to also go into the solar power business. Perhaps the solution they should offer for providing 911 backup is to sell a home a $20,000 solar power system. I know the FCC wouldn’t see the humor in that, but this order is so far out in left field that I have a hard time taking it seriously.

An All-IP Telephone Network?

IPThe FCC posed a very interesting question to the industry. They asked if VoIP should become the only way of delivering voice service. This infers having an all-IP network that is extended out to every customer. The FCC asked this question as part of the IP trials that a few telcos are currently undertaking to see what an IP world looks like. While IP undoubtedly makes for the most efficient telco network, I think there many practical reasons why this can’t be implemented everywhere.

We can start with the FCC’s own estimate that there are something like 14 million rural homes without a broadband alternative. These are people who live in rural areas and are almost universally on old and sometimes very poor copper. These are people who can’t get DSL or cable modem and for whom VoIP would not work. There are also a ton of people in the country who are on marginal DSL service who also will have a hard time getting working VoIP. Most such people are also rural, but there are older urban networks with bad copper that also suffer from problems related to the condition of the copper.

But aside from the rural issue, it’s an interesting question. Cable companies already all use VoIP for voice, as do fiber overbuilds. Urban telcos could also give everybody VoIP, but it would mean providing a DSL connection to everybody on copper. This would cause all sorts of network problems. We found out years ago that you can’t put too many DSL lines into the same large copper sheathe or you create interference problems, and universal VoIP would put DSL on just about every copper pair. I also can’t think of any financial benefit to the telco for spending the money to put voice on DSL if that is all a line is going to be used for.

All of these issues make it hard to imagine mandatory VoIP at the customer end of the network. I’ve always envisioned that the IP transition would mean an all-IP network between carriers, which would create the most efficient network. But forcing VoIP where it won’t work right sounds both expensive and impractical. And it would likely boot millions from access to the voice network.

But there are other parts of an all-IP network that could be interesting. For instance, if the whole network was IP from end-to-end you could do away with telephone numbers. In an all-IP network each customer would be associated with an IP address, and so keeping telephone numbers would be forcing a historical structure onto an all-IP network. While we all would probably still have phone numbers, it would be just as easy to just pick somebody out of a computer menu by name and connect with them without going through the fiction that a number is required.

There are a few situations where going all-digital is a bit of a concern. Take 911. The current 911 network is comprised of a redundant pair of special access circuits between each carrier and each local 911 center. This network layout was created to greatly increase the likelihood that a 911 call can be completed. But in an all-IP world 911 traffic would probably be routed with everything else, which is not an issue of itself. But we know that Internet pipes go down all of the time. So anytime there was an Internet outage in a town or a region, 911 would go down with the Internet.

Of course, the FCC didn’t suggest this in a vacuum. They are being prodded in the whole IP-transition by both AT&T and Verizon who would like to get out of maintaining rural copper lines. AT&T has said many times that they want to cut down millions of rural lines and convert them to cellular. And so any pretense that the carriers are interested in creating a rural all-IP network is a fiction, because these large carriers don’t want to own or operate a rural landline connection of any kind. As we recently saw with a large sale of Verizon FiOS lines to Frontier I’m not sure that the two big telcos want to maintain any landline connections at all. These telcos are now mostly cellular companies who are finding landlines to be a nuisance.

FCC Looking at Backup Power for CPE

Fuld-modell-frankfurtThe FCC is currently deliberating whether they should require battery or other power back-up for all voice providers. They asked this question late last year in a Notice for Proposed Rulemaking (NPRM) in Docket 14-185 and recently numerous comments have been filed, mostly against the idea.

This would affect both cable TV companies and fiber providers since those technologies don’t provide power to telephone sets during a power outage. Customers still on copper have their phones powered from the copper (assuming they have a handset that can work that way), but the FCC sees the trend towards phasing out copper and so they ask the question: should all voice providers be required to provide up to eight hours of backup so that customers can call 911 or call for repairs?

The FCC also asks dozens of other questions. For instance, they ask if there should be an option for customers to replace batteries or other back-up power. They ask if something universal like 9 volt batteries might be made the default backup standard.

One can tell by the questions asked in the NPRM that the FCC really likes the idea of requiring battery backup. I put this idea into the category of ‘regulators love to regulate’ and one can see the FCC wanting taking a bow by providing a ‘needed’ service to millions of people.

But one has to ask: how valuable would this really be for the general public? As you might expect, both cable companies and fiber providers both responded negatively to the idea. They made several major valid points against the idea:

  • Most Handsets Don’t Use Network Power. We all remember the days of the wonderful Bell telephones that all were powered from the copper network. If you had a problem with your phone, one of the first things you always tried was to carry your phone outside and plug it into the NID to see if your problem was inside or outside of the house. I remember once when I had an inside wiring issue that I spent several days squatting on my carport steps to carry on with my work. And those phones were indestructible; my mother still has her original black Bell telephone and it works great. But today you have to go out of your way to buy a plain phone that is network powered. If you get a phone with a portable handset or with any built-in features it’s going to need home power to work. So the question becomes: how many homes actually have phones that would work even there was some sort of backup during an outage?
  • Cell Phone Usage. Landline penetration has fallen significantly in the country. At peak it was at 98% yet today the nationwide penetration is under 60%, with the penetration rate in some major cities far below that. But as landlines have dropped, cellphone usage has exploded and there are now more cellphones in the US than there are adults. As many filers pointed out, when power is out to a home people will make emergency calls from their cellphones. And for the 40% or so of homes that only use cellphones, it’s their only way to make such calls anyway.
  • High Cost of Maintaining Batteries. I have clients that operate FTTP networks and who originally supplied batteries for all of their customers. This turned into a very expensive maintenance nightmare. In a FTTP system these batteries were inside the ONT (the electronics box on the side of the home). This means that the ONT had to be opened by a company technician to replace the batteries, meaning a truck roll, and meaning that a customer can’t replace their own batteries. When batteries go bad they must be replaced or they leak and damage the electronics, and these companies found themselves committing major resources to replacing batteries while they also realized that due to the above issues most of their customers didn’t care about having the backup.
  • What Do You Back-up? There are numerous different ways these days to provision broadband to people (and consequently voice). Some of these options don’t have a practical battery backup available. For example, a cable modem costs a lot more if it includes a power backup, particularly one that is supposed to last for 8 hours. I can’t imagine that there is any practical way to provide backup power other than to supply an off-the-shelf UPS for ISPs who deliver broadband with unlicensed wireless networks. And today, even the FTTP business is changing and ONTs are becoming tiny devices that are plugged into an inside-the-house outlet. Also, who is responsible for providing the backup when a customer buys third party voice from somebody like Vonage that is provisioned over their broadband product?
  • This Adds to the Cost of Deploying Fiber. Building new fiber to premises is already expensive and such a requirement would probably add another $100 per household to the cost of deploying fiber, without even considering the ongoing maintenance costs.
  • Today Most of the Alternatives Proposed by the FCC Don’t Exist. Nobody has ever bothered to create standard battery backup units for a number of network components in coaxial networks. Cable companies have been delivering voice for many years and have had very few requests or demand for providing backup. There certainly are not any backup products that would rely on something standard like 9 volt batteries. And in many networks, such a product would not be able to provide 8 hours of backup. For example, a cable modem would drain even a commercial UPS in a few hours (I know, I have mine set up that way).

I am certainly hopeful that the FCC heeds the many negative comments about the idea and doesn’t create a new requirement for which I think there is very little public demand. Sometimes the best regulation is doing nothing, and this is clearly one such case.

It’s Not Your Father’s 911

Mashpee_Mass__Ambulance_363_-_2007_Ford_E-450_HortonSince its inception in the late 60’s and wide-spread deployment in the 80’s we have all come to take 911 for granted. No matter where you are in the US, if you dial 911 you expect to be connected to an emergency center for police and fire service.

All telephone providers in the US are required by FCC rules to connect a caller to the proper 911 center based upon their location. These 911 centers are referred to as Public Safety Answering Points (PSAPs). The PSAPs are operated by counties, cities or regionally. PSAPs vary in sophistication from large 911 centers in major cities that have hundreds of operators, to small rural 911 systems where the calls get routed to the local sheriff’s office and involve almost no technology.

I have recently seen two different sets of headlines that put 911 back in the news. The first was about the emergence of text-to-911, where texting to 911 will connect you to the closest PSAP. This grew out of the movement to create next generation 911, which has the goal of allowing voice, text or video emergency calls from any communications device using IP. Historically 911 has been limited to voice calls made from landline or cellphones, except for calls made by deaf and hearing-impaired people using teletypes and other similar devices.

In 2013 the largest wireless carriers began testing text 911 with some large urban PSAPs. People can text 911 and be connected to their PSAP, which will then respond to them via text. The genesis of this upgrade is to provide 911 from anywhere for the hearing-impaired, who can only now do this using special devices. But texting to 911 would be available to anybody

The FCC issued a policy statement in January of this year that said that every wireless carrier should provide text-to-911 service, although it is not yet mandatory. The FCC also mandated that the wireless carriers send back a ‘bounce-back’ message to the sender if they are unable to complete the call to a PSAP. Without that return message a person would assume that the text message successfully got to 911. Both the FCC and the PSAPs encourage people to make the call by voice whenever possible and only use text when there is no other alternative.

There was also some recent more disturbing news about 911. The FCC recently released data that showed that in 2013 that 90% of the 911 calls in Washington DC originated from wireless devices did not deliver the precise location data of the caller. This is a bit chilling for several reasons. First, a large percentage of the population now only uses cell phones, and so this is their only way to call 911. And secondly, not everybody knows their address when they call. If the caller is a child or a tourist they might not have any idea of their location. And sometimes callers who are in danger call 911 and can’t speak and rely on 911 knowing where they are at

Mobile 911 makes a determination of a callers location using triangulation. This means that the 911 PSAP is able to ping back to the cell phone and see the location of several nearby cell towers. By looking at the relative strengths of those ping-backs they were historically able to pinpoint a caller within 50 – 100 feet, often closer.

But this system was established when there was only a handful of cell towers in the world, and so it became fairly easy to locate a caller. But today there is a proliferation of cellular transmitting devices in the network, particularly in urban areas. The cell phone companies are reported to be installing millions of mini-cell sites this year – sites which act as cell towers, but for a much smaller area like part of a stadium, a busy street or on a commuter bridge. Additionally, anybody is able to buy a cell phone booster. These are essentially cellular repeaters with a short range and are used to bring strong outside signals to the inside of a building.

But to a PSAP all of these devices look like enough like cell towers to cause confusion in the triangulation algorithms. And so, where mobile 911 was once fairly accurate, it is now a jumbled mess in urban areas where there is a proliferation of transmitting devices. I am sure there is a technological solution to this, but it is going to take the cell phone carriers start over to find a way to locate a cell phone in an urban environment.

While the headlines of 9 out of 10 being inaccurate sounds scary, the reality is that the lack of precise data didn’t affect most of these calls. Otherwise we’d be seeing a lot of shocking headlines. Remember that in most cases that the 911 PSAP speaks to the caller who can verify their location. And even when the mobile 911 system in not entirely accurate it probably gets close enough to be effective most of the time. But I remember the headlines in the early 80s when several people having heart attacks died because they called 911 from a payphone and didn’t know their location. I hope this latest report prompts the FCC and the cell companies to find a solution before we go back to those headlines again.