Fourteen entities filed comments regarding a request by the National Association of State 911 Administrators (NASNA) to initiate an FCC proceeding to address issues related to how smartphone 9-1-1 applications interface with 9-1-1 systems.BayRICS, Boston Ask for Quick Resolution to FirstNet Protest
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In its comments, the Association of Public-Safety Communications Officials (APCO) International said it is working to ensure apps are safe and effective. APCO also said apps can’t replace 9-1-1, and critical issues must be addressed before applications can augment calls to 9-1-1.
The National Emergency Number Association (NENA) said the development of 9-1-1-related smartphone apps offers an opportunity and a challenge for the public-safety communications. The association said 9-1-1-related applications should be held to the same high standards as other components of 9-1-1 systems.
Mission Critical Partners urged the FCC to initiate a proceeding to consider sensibly applying existing rules to address the reliability, security, interconnection and accuracy concerns related to applications and systems, such as 9-1-1 smartphone applications, that interconnect to the 9-1-1 system. MCP expects that a need exists for the FCC to consider the broader potential for applications enabled by the internet of things (IoT) accessing 9-1-1 systems, which may present similar challenges and concerns as presented by the smartphone 9-1-1 applications.
The Boulder (Colorado) Regional Emergency Telephone Service Authority suggested a four-part solution. The FCC should adopt solutions requiring service and device providers to publish their location application programming interfaces (APIs) so any app for 9-1-1 can access accurate data. Then, the FCC should establish a standards authority for 9-1-1-related apps. Regulations prohibiting service providers and 9-1-1 system providers from accepting data from unapproved apps should be in place. Finally, the standards authority would identify and propose regulations.
The Texas 9-1-1 Alliance, composed of 26 Texas emergency communications districts, supported NASNA and said the FCC should initiate a 9-1-1 applications proceeding. The Larimer (Colorado) Emergency Telephone Authority and the Arapahoe County (Colorado) Emergency Communications Service Authority also supported the NASNA comments and request.
“The city believes the commission should initiate a proceeding to determine whether 9-1-1 apps, in light of the problems alleged by NASNA, should be allowed to interconnect to the 9-1-1 system,” the city of New York said in its comments. “9-1-1 apps that do interconnect should be subject to rules to address the concerns raised and to require strict adherence to standards, ensuring the apps provide the seamless user experience that 9-1-1 already delivers.”
NTCA – The Rural Broadband Association said the FCC is not the appropriate venue to address NASNA’s concerns. Likewise, the App Association said the FCC’s action will potentially stunt the growth of mobile app innovation. The Federal Trade Commission (FTC) has well-established authority to address app claims impacting consumers, the App Association said.
“Although AT&T sympathizes with many of NASNA’s concerns, we also note that NASNA offers no legal basis upon which the commission could assert authority over 9-1-1 apps,” AT&T said in its comments. “To the extent that the commission moves forward with a rulemaking as requested by NASNA, it might also be a proceeding in which to consider rules appropriate for interconnected VoIP (other than Long Term Evolution) in a mobile environment, such as for over-the-top VoIP apps and Wi-Fi calling.”
All the filings are available here.
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