The long journey begins

The world has gone digital. From coffee makers and clocks to televisions and telephones, the analog age is fading rapidly, and those who don't embrace the digital domain will find themselves lost. Nowhere is that more apparent than in the technology architecture of emergency services. The existing NG-911 system was established 40 years ago to function within a wireline telephone architecture that relied upon analog signaling and circuit-switched technology. This technology dramatically lags behind the technological advancements that define modern communications.

Indeed, the research report "Health of the U.S. 911 System," published by the 911 Industry Alliance in 2008, which examined the technological, funding and governance aspects of emergency communications, characterized the architecture used by public-safety answering points as "an analog island in a digital sea." As problematic is that a significant gap exists between what the general public assumes about 911 services and what is really possible. Today, text communications and the sharing of digital images, maps, video and the like are at the center of how we communicate. However, the overwhelming majority of current 911 networks cannot accommodate these types of data.

In response to the growing demands on the 911 network, major changes are being pursued at every level of government. In June 2008, for instance, the federal government passed the "New and Emerging Technologies 911 Improvement Act," which calls for "a national plan for migrating to a national IP-enabled emergency network." In essence, the antiquated analog, point-to-point technology will be replaced with digital broadband technology that uses packet-switching facilities to support voice, data, text, image, video and multimedia applications on a secure, robust multipurpose network. In other words, this new architecture will enable the nation's 911 public-safety emergency services infrastructure to keep pace with evolving technological advancements — and meet the public's expectations.

In order to facilitate this necessary transition to an all-IP network, the National Emergency Number Association (NENA) proposed a system design called "Next Generation 911," or NG-911, which commonly is referred to as the i3 suite of standards. NENA i3 outlines an architecture designed as an IP-based "network of networks" shared by all agencies that may be involved in an emergency. In conjunction with the proposed architecture, NENA also has issued a recommended set of technical requirements to guide the functions and interfaces between the various elements involved with an IP-based 911 emergency services architecture.

The proposed improvements to the legacy network are the most sweeping changes the 911 sector ever has seen. As such, it is important to note that the standards being created for this migration are far more significant than the standards that focused on wireless and enhanced 911 services in the early 1990s. But while the proposed i3 document addresses many significant elements of the new framework, it is equally important to take a careful and critical look at these guidelines as a whole to identify the issues that require further attention and revision.

One of the most important aspects to consider in the i3 proposed technical requirement is the Long-Term Definition (LTD) approach used to create the guidelines. The recommendations were designed to define the fully realized target architecture of the network and the necessary interfaces but comprehensively fails to address the current 911 environment. By solely focusing on the future features of the framework, the proposed i3 specifications assume an immediate migration and do not recognize the reality that i3 cannot be accomplished overnight.

For example, the standards do not consider the varying time frames of individual telecommunications service providers, independent jurisdictions and PSAPs in terms of operational changes. Thus, they do not define any protocol for a tandem operational framework for legacy and IP-based systems. For the i3 technical requirements to be truly effective, they must define a comprehensive and phased migration approach in which all aspects of change management — technology, security, PSAP operations, staffing, public education, error resolution, oversight, regulation and funding — are considered.

The proposed i3 document also does not adequately address the extremely complex and important issue of IP security. Under the draft recommendation, it is feasible that non-technical decision-makers will underestimate the vulnerability of NG-911 systems given the open and interconnected IP environment. Safeguarding this environment against intentional or unintentional impairment requires significant initial and ongoing security efforts for each device attached to the system.

With an increasing number of emergency calls made over the Internet, the i3 document needs to mandate that 911 service providers and the PSAPs they serve will install firewalls, anti-spyware programs and other similar security protections.

Additionally, the i3 recommendation should require the education of key decision-makers on the complexity of these critical security issues. A failure to do this will leave PSAPs and the entire core system vulnerable to service disruptions caused by deliberate malicious attacks.

An end-to-end IP network environment involves innumerable interconnected networks, touch points and varying levels of security management. Such complexity demands a more defined protective framework in order to guarantee uncompromised security for the 911 public-safety emergency services network as a whole, in order to serve the public.

The comprehensive cost of infrastructure, operational changes, widespread implementation oversight, security measures, increased staffing demands and essential training necessary to the IP transition is a difficult number to quantify — but no one should doubt that it will be significant. The i3 document indicates that the new framework will be better, faster and cheaper, but these are vague assumptions based on unproven theories of how the system will work and on best-case scenarios.

In reality, the proposed i3 technical requirements do not identify all of the costs, do not assign responsibility for the costs and do not discuss funding sources in any way. There are some 911 agencies ready to make the move as soon as more definitive requirements are made clear. Meanwhile, other agencies are beginning to take steps toward NG-911 readiness by upgrading equipment over time, thus spreading out the financial impact. However, the topic of funding for this migration is daunting for most decision-makers, and there is no single path to resolving it.

This intrinsic dilemma becomes even more difficult in the current and projected fiscal environment. There are significant disparities in 911 funding mechanisms and resources across the U.S., and tied to those variances are differences in legislative authority regarding what public funds can and cannot be used for 911-related expenditures. There are also unknowns when it comes to cost sharing across multiple agencies and jurisdictions. Consequently, it is short-sighted to assume that costs for migration and system maintenance can be assimilated into individual PSAP operational budgets without significantly impacting current service.

Ultimately, the move to i3 may require a change in legislation before PSAPs can spend money to utilize some of the new capabilities that NG-911 makes possible. One PSAP funding possibility is that all costs associated with upgrading to NG-911 would be recovered by the PSAP or state 911 authority by assessing users of NG-911 services via telecommunications providers. This model has been used with some success to recover costs since Phase I and Phase II wireless 911 service was deployed beginning a decade and a half ago.

The current emergency services infrastructure, which is relied upon by people in the U.S. approximately 300,000 times per day and more than 10 million times a year, has not kept pace with technological and communications advancements and needs to be overhauled. The current effort to establish guidelines and standards for NG-911 infrastructures is the most significant industry undertaking in more than 20 years.

Now is the time to pay close attention to what is — and what is not being stated — regarding the proposed i3 requirements. Much was learned in the deployment of wireless 911, and those lessons must be leveraged now. Public-safety and 911 officials have a voice in this process. That voice must be heard to prevent standards from being adopted without careful review, comment and, if necessary, challenge.

Steve Souder is director of the Fairfax County (Va.) Department of Public Safety Communications. Fairfax County's full-service, future-ready, state-of-the-art facility is the largest PSAP in the state and one of the 10 largest in the U.S. Souder can be reached at [email protected].