Public Safety, Carriers Comment on NSI 9-1-1 Call-Forwarding Rules
Monday, June 15, 2015 | Comments

The FCC has received about 40 comments in its proceeding regarding the usefulness of 9-1-1 call forwarding for non-service-initialized (NSI) phones. The commission has proposed to sunset the rule after a six-month transition period for public outreach and education.

The rule, established nearly 10 years ago, required carriers to forward 9-1-1 calls from all wireless phones without requiring user or call validation. The commission maintained the rules despite growing concerns about accidental and fraudulent 9-1-1 calls placed on NSI phones until 2013. At that time, the National Emergency Number Association (NENA) filed an ex parte filing, reversing its long-held opinion that the rules should be retained and said a consensus view had emerged that requiring 9-1-1 call forwarding from NSI devices does more harm than good.

As a result, the commission re-opened the proceeding, and earlier this year sought comments about whether calls made to 9-1-1 from NSI phones create a burden for public-safety answering points (PSAPs).

NSI calls arrive at PSAPs without identifying information and are sometimes accidental or fraudulent, which can tie up PSAP resources. The commission also asked for comments on whether confusion will result if the NSI rule is discontinued or from the growth of new technologies, such as VoIP and text to 9-1-1, that don’t support NSI 9-1-1 call forwarding.

The comments so far have been mixed, with public safety largely coming down on the side of discontinuing the rules, while the carrier community and citizens mostly favor maintaining the rules. Many comments urged the commission to consider technology alternatives that would associate identifying information with NSI devices and would allow selective blocking or some other method to mitigate nuisance calls to 9-1-1 from NSI devices.

“While the FCC, over the years, has taken positive steps to help reduce non-emergency calls placed by NSI handsets, abusive calls remain such a continuing and severe problem that the harm outweighs remaining benefits of the present rule,” said the Association of Public-Safety Communications Officials (APCO) International. “The NSI rule has lost its original positive impact for the general public and turned into an abusive tool that adversely impacts PSAPs and can lead to delays in emergency response. Thus, a certain and uniform cut-off date of the NSI rule is in order.

“It is important, following the public education period, to cease as much as possible the abusive NSI-based 9-1-1 calls plaguing PSAPs across the country. Therefore, it is insufficient to just sunset the rule — the FCC should require carriers to stop forwarding 9-1-1 calls from NSI devices. Otherwise, PSAPs would continue to be subject to harassing, non-emergency calls for years on end. Further, permitting carriers to continue to forward NSI 9-1-1 calls would re-create confusion experienced both by the general public and PSAPs, and reverse the gains of the six-month public education effort.”

The commission sought data from PSAPs about how often fraudulent calls from NSI devices occur, as well as the percentage of fraudulent calls coming from particular NSI devices or subsets of users.

The city of Philadelphia said 18.69 percent of calls its PSAP received in 2014 and 16.9 percent of calls in the first quarter of 2015 were from NSI devices. The city said 105,515 NSI devices were used to place calls to Philadelphia’s 9-1-1 center in 2014. The city performed an analysis on repeat calls in excess of 500 per month and found 21 separate phones were responsible for 67,222 calls. One specific NSI phone made 23,047 calls to 9-1-1, which means one phone accounted for 34.28 percent of NSI calls to the PSAP. Between Jan. 1, 2015, and March 14, 2015, the city said it had one repetitive caller who placed 2,709 calls to 9-1-1 from an NSI device.

“The public has come to rely on the fact that NSI devices are capable of calling 9-1-1 and the city does receive legitimate 9-1-1 calls from NSI devices; however, the city does support the commission’s proposal to eliminate the NSI call-forwarding requirement,” said the city of Philadelphia. “The city feels the decreasing cost of service-initialized devices eliminates the need for the NSI rule.

“The NSI component of the rule provides a six-month transition period allowing for public outreach and education. The city feels it is better to have a uniform deadline rather than a phase-out approach. If the NSI call-forwarding requirement is not adopted, the city of Philadelphia is in support of the option to allow providers to block harassing 9-1-1 calls from NSI devices as well as identifying further call-back capabilities for NSI devices.”

The Texas 9-1-1 Alliance, the Texas Commission on State Emergency Communications and the Municipal Emergency Communication Districts Association filed a combined comment that said between 8 and 18 percent of all 9-1-1 calls in Texas come from NSI devices. “Based on the limited CAD event data that the Texas 9-1-1 entities were able to gather to date, the number of legitimate NSI 9-1-1 calls appears to be perhaps in the 3 percent range,” said the Texas agencies.

Boulder Regional Emergency Telephone Service Authority (BRETSA) in Colorado said the number of legitimate 9-1-1 NSI calls has declined significantly, and many dispatchers it polled could not remember the last time they received a legitimate NSI 9-1-1 call.

“Non-legitimate 9-1-1 calls, including stupid 9-1-1 calls, malicious or fraudulent 9-1-1 calls tie up PSAP lines and dispatchers, and delay or prevent receipt, handling and dispatch of legitimate 9-1-1 calls,” said BRETSA. “Several years ago, Denver-area news media reported that police in one jurisdiction were going door-to-door to locate a child who called 9-1-1 on an NSI phone reporting that his mother needed help. They never located the child or his mother. Thus, NSI 9-1-1 calls can even waste first responder resources.”

BRETSA proposed a technology solution that would identify NSI devices along with their location and provide some identifying information about the phone’s previous subscriber. The group also encouraged the commission to find ways to deter nonlegitimate 9-1-1 calls via prepaid, VoIP and text-to-9-1-1 services.

Sprint and Verizon as well as the Competitive Carriers Association and CTIA acknowledged the problem of fraudulent 9-1-1 calls from NSI devices but urged the commission not to sunset the NSI 9-1-1 rules. A primary concern of the carrier community is that, in some cases, service-initialized phones will appear as NSI devices. This may happen when a device is roaming or when the system or devices are being rebooted. As a result, if calls that appear to be from NSI devices are blocked, some legitimate calls from service-initialized phones will also be blocked.

“While CTIA appreciates concerns about fraudulent 9-1-1 calls, CTIA encourages PSAPs to combat fraudulent 9-1-1 calls from NSI handsets through call-blocking within their own networks or customer-premises equipment (CPE),” said CTIA’s comment. “In contrast, a sunset approach would generate uncertainty and confusion for wireless callers, including subscribers whose handsets temporarily register as NSI in certain circumstances. Ultimately, a sunset would not achieve the commission’s goals of eliminating fraudulent calls to 9-1-1 from NSI handsets while ensuring access to 9-1-1 from all service-initialized handsets. For these reasons, CTIA continues to support the ‘all calls’ rule.”

About a dozen citizens submitted comments urging the FCC not to sunset NSI call-forwarding rules because of the impact it would have on elderly citizens who may only carry an NSI device for 9-1-1 purposes, as well as at-risk groups, such as domestic violence victims, who may rely on such devices in an emergency. The National Network to End Domestic Violence (NNEDV) echoed those comments, saying NSI devices are often a lifeline for domestic violence victims.

TeleCommunication Systems (TCS) submitted comments including data it gathered from calls routed by its 9-1-1 system to PSAPs. The company said up to 20 percent of calls each year are placed from NSI devices and as many as 35 percent of those calls are considered unwanted calls. Further, TCS’ analysis found most of the unwanted calls came from a small number of NSI wireless phones.

“Based upon this statistical analysis, TCS concludes that there is a cost and resource impact on public-safety emergency response associated with these millions of unwanted NSI wireless 9-1-1 calls,” said TCS. “Thus, it is appropriate that the FCC examine the problem and recommend a solution. Should the FCC wish to address this cost and resource impact at a national level by sunsetting current rules and requiring all future NSI wireless 9-1-1 calls to be discontinued, solutions can be implemented to ensure that no NSI wireless 9-1-l calls route to PSAPs.”

TCS recommended the commission allow at least one year to implement such a program primarily for consumer education and the need to handle a large number of legitimate NSI wireless 9-1-1 calls via other methods.

“Should the FCC see the value of continuing the NSI rules, it would be possible to establish a nationwide NSI wireless 9-1-1 call blocking mechanism that each PSAP could request based upon local need and resource savings,” said TCS. “Such a mechanism would best be funded by the local public-safety jurisdictions, addressing the liability protections that might be required should NSI wireless 9-1-1 call blocking result in the blocking of a legitimate wireless 9-1-1 call. Using this approach, the deleterious effects of NSI wireless 9-1-1 calls could be mitigated while keeping the intended value of the NSI wireless program.”

The NSI proceeding number is 08-51. Initial comments were due June 5. Reply comments are due July 6.

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