Multistate 911 outage could lead to changes in emergency-calling regulations, operations

Historically, 911 regulation and operation have been focused at the state and local levels, which made sense. After all, the locations of selective routers serving a given PSAP was known and in relatively close proximity to the 911 center, and the carriers providing the connectivity were used to dealing with state commissions.

But each state and local jurisdiction has access to different resources, and politics play a large role in determining how 911 service is prioritized. As a result, while PSAPs in some states are well down the path to next-generation 911 that can support multimedia interaction with citizen, others have not yet been upgraded to support wireless 911 calls.

“We have a national system, but it is not nationwide,” George Rice said during an interview with IWCE’s Urgent Communications. “The only thing that’s national [about 911] is the number.”

When IP-based connectivity was introduced into 911 systems, there were many who argued that the FCC and the federal government should have bigger roles in the regulation of 911, because IP technology is inherently interstate—key network elements can be located anywhere and function properly, if appropriate connectivity exists.

Although this made for good legal debates, there really was no compelling reason for the FCC and the federal government to be significantly more active in 911 regulation, because the states seemed to have the necessary authority to keep systems running well.

But the massive April outage underlined a problem state regulators just can’t address.

What authority does a regulator in Washington State—like Danner—have over a private third-party vendor in Colorado—like Intrado—that works for a carrier providing 911 connectivity and that controls key components of the 911 system that the regulator must ensure works reliably?

“They had a state PUC commissioner speaking before a federal agency declare that this is interstate in nature—and anything interstate in nature typically falls under the domain and jurisdiction of the FCC or the federal government,” Brian Fontes, CEO of the National Emergency Number Association (NENA), said during an interview with IWCE’s Urgent Communications. “911 per se is not regulated at the federal level, but the communication links by third parties and telecommunications companies 911 service—in part—are regulated by federal agencies.

“States and their state PUCs recognize that they themselves may not have authority over a third-party vendor who operates in another state but whose system affects the service in the state of a PUC commissioner. So, there needs to be some sort of overall federal nature to all of this.”

Now, the PSAPs affected in the April outage were using the legacy 911 system at the endpoints—all had Centralized Automatic Message Accounting (CAMA) trunks, according to the FCC report—but the routing functions were done over an IP system. In a next-generation 911 system, which is based on an all-IP architecture, much more than routing functions could be impacted, as a next-gene 911 system is designed to access and leverage all sorts of databases in myriad locations to provide relevant information to first responders.

Given this reality, Fontes said he believes it is time for federal government to become more involved in the regulation of 911—and in its funding mechanisms—to help ensure that the level of 911 service is available throughout the country, as opposed to having significantly different technological capabilities in various locations.

“It’s time that political leaders at the federal, state and local levels recognize that 911—and, subsequently, next-generation 911—is a critical-infrastructure element,” Fontes said. “We look at the energy grids—electric, gas, water, etc.—as all part of critical infrastructure. As such, they have federal attention, coordinated with the states. There’s funding available to ensure that it meets certain standards and requirements.

“I think that 911 should be considered as a critical infrastructure, subject to that type of funding and oversight to ensure that it is operating to certain criteria and maintained so that anyone dialing 911 from anywhere in the country can expect a certain standard quality level of accessing emergency services.”