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EAAC Working Group 1 Recommendations

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Released: December 18, 2012

Emergency Access Advisory Committee (EAAC)
Working Group 1 Recommendations on Text
Messaging to 9-1-1


Table of Contents
Executive Summary........................................................................................................................1
1
Overview ..................................................................................................................................2
2
User Needs and Constraints .....................................................................................................3
2.1
User experience...............................................................................................................5
3
Originating Devices and Network............................................................................................6
4
Transport Networks including TCC.......................................................................................10
5
PSAP end................................................................................................................................10
6
Issues ......................................................................................................................................14
6.1
National Interim Text and Vendor Proprietary Solutions.............................................14
6.2
Responsibilities and Policies.........................................................................................15
6.3
Future Considerations ...................................................................................................15
7
Actions needed to build this (what is not already in place) ...................................................15
7.1
Education and Outreach................................................................................................15
8
Conclusion..............................................................................................................................16
9
Recommendations ..................................................................................................................16
Appendix A: Glossary...................................................................................................................17
Appendix B: Use Cases for SMS-based text-to-911.....................................................................18
Revision History ...........................................................................................................................19

Executive Summary


1 Overview
The Federal Communications Commission’s (“FCC”) Emergency Access Advisory
Committee (EAAC) is pleased to offer the following recommendations to advance near-term
access to 9-1-1 for individuals with disabilities.
Established by the FCC pursuant to The Twenty-First Century Communication and
Video Accessibility Act (CVAA) of 20101 (“CVAA”), the EAAC believes that achieving equal
access to 9-1-1 emergency services by individuals with disabilities as part of the migration to the
national Internet protocol (“IP”)-enabled emergency network (“NG9-1-1”) is a matter of long-
term national policy. The EAAC recognizes that achieving the goal of an accessible NG9-1-1
system will require the collective commitment of all stakeholders, including consumers,
industry, public safety and policymakers, to address the critical issues of technical standards,
service deployment, and appropriate governance and funding.
As part of the December 2011 report to the FCC, the EAAC recommended that an
achievable interim method for text-based messaging to 9-1-1 would be necessary until NG9-1-1
is fully developed, deployed and adopted by industry, public safety and consumers.2 In
furtherance of this recommendation, the EAAC requested that all stakeholders, including
industry, consumers and public safety, the FCC and Department of Justice, work together to find
an interim solution that can be rapidly deployed to provide nationwide access to 9-1-1 services
through industry standards-based mobile text communications solution(s) to provide critical
coverage for this important constituency during the transition to NG9-1-1.
In January 2012, the EAAC designated a working group to make recommendations to
encourage the availability of pre-NG911 interim Text-to-911 (“Working Group”). In March
2012, the EAAC adopted a resolution to support “as an interim solution for text to 9-1-1, at a
minimum, SMS, and other technologies as appropriate, with a three digit short code 9-1-1.” The
Working Group has expended significant time and resources developing the following report by
learning from each other and collaborating on issues in furtherance of near-term Text-to-911.
The Working Group’s first effort was to complete a set of assumptions on which to focus
the Working Group’s efforts. These assumptions include:3
 Using any number besides 9-1-1 creates the problem that the user will probably never remember
it when they have an emergency, if they ever knew that there was a number besides 9-1-1.
 This short-term solution should not necessarily be subject to all of the requirements of either
voice 9-1-1 calls or long-term solutions so that it can be implemented in the near term and
without extensively reworking the carrier, handset, or PSAPs systems.

1 Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260, 124 Stat. 2751
(CVAA) (amending sections 3, 255, 303, 503, 330, 710, and 713 of the Communications Act, and adding sections
615c and 715-19, codified at 47 U.S.C. §§ 153, 225, 303, 330, 503, 610, 613, 615c, 616-20).
2 FCC EAAC Report and Recommendations, PS Docket No. 10-255, at 26 and 28-30 (Dec. 12, 2011) (resubmitted
in final Jan. 26, 2012) (“EAAC Recommendations for Interim Text Access and Interim Mobile Text Solution”).
3 See Presentation of EAAC Working Group 1, Text-to-911 Solutions to 911 Interim to NG911 (Sept. 14, 2012)
(outlining key assumptions about Pre-NG911 Interim Text to 911).

 The FCC should work with consumers and industry to secure any needed additional liability
protection for all entities that are implementing these new text to 9-1-1 calls.
 The EAAC believes that if the text message to 9-1-1 solution is not available to all people, with
and without disabilities, that it would be too complicated for carriers and others to qualify some
people as eligible and others as ineligible to make an SMS/text message call to 9-1-1 during
emergency situations. The liability issues from denying access to unregistered callers would
complicate the issue further.
 The EAAC directed for this subcommittee to take this topic up in 2012 and submit a separate
report on this important topic.
 From a consumer standpoint, direct access via mobile text to 9-1-1 is a critical goal.
Using these assumptions as the base of work, the Working Group designated four
subgroups to consider User Needs and Constraints, Originating Networks and Devices,
Transport Networks, and Public Safety Answering Point (“PSAP”) issues. After considering the
issues, the Working Group developed recommendations to address near-term opportunities for
Pre-NG911 Text-to-911.
As the technical, operational, and regulatory frameworks for Text-to-911 continue to
develop, the EAAC wishes to note that the adoption and application of these recommendations
will need to be determined through the appropriate rulemaking and standards development
processes. The EAAC also notes that some of the recommendations may require further research
and development of technical standards, best practices or guidelines, before they can be applied.
The EAAC recognizes that public expectations, including individuals with disabilities, for 9-1-1
emergency communications should be taken into consideration where further research and
development may be necessary.
The EAAC wishes to express its appreciation to the individual Working Group members,
EAAC members and FCC staff for the time and commitment that has gone into preparation of
this report, and for the progress that the EAAC has made since it first met on January 14, 2011.
2 User Needs and Constraints
This section responds to key questions posed by EAAC on the user experience during a text-to-
9-1-1 call, and outlines questions related to user expectations.

Which text communication methods do users want to use in the interim?

In order of importance:
1. Native SMS
2. Over-the-top SMS apps (3rd party app that goes through 3rd party service to send SMS
to another device, on tablets and computers)
3. Combinations of voice and text.
Note: There are four variations of this scenario.

a. User makes a voice call to 9-1-1 and for the duration of the call the user as
well as the PSAP intermix voice and text.
b. User makes a voice call to 9-1-1 and for the duration of the call the user uses
voice and the PSAP sends text back.
c. User makes voice call to 9-1-1 and for the duration of the call both the user
and the PSAP text only.
d. User will send text to PSAP and ask for a voice call back and then for the
duration of the call the user can text and the PSAP respond with voice.
For other possible interim solutions, beyond SMS, the EAAC survey4, question 16, on p. 23,
covers this aspect. The results are as follows:
1. SMS (45.1%)
2. Real-time text (45.7%)
3. Email (43.7%)
4. IM (31.1%)
5. Web page (30.2%)
6. Systems built into car (21.3%)

Note:

. The EAAC resolution5 supports "as an interim solution for text-to-9-1-1, at a minimum,
SMS, and other technologies, as appropriate, with a three digit short code 9-1-1." The user
preferences suggest that RTT, e-mail, and IM should be evaluated for their feasibility as
additional means to contact a PSAP, in accordance with the "other technologies, as appropriate"
part of the resolution. Due to PSAP constraints, web based access and system built into cars may
have to wait until the longer term.

Which devices do users want to use in the interim?

Ranking of devices in order of importance, also see EAAC survey Question 21:
1. Mobile phones and devices (61.8% for cell phone, 53.7% for smartphone, pager, PDA)
2. Tablets (Survey results under “Others” shows that 9 respondents mentioned iPads or
iPods)
3. Computers

Note:

This survey question shows which devices users would employ for texting 9-1-1. Both
computers and tablets support over-the-top text-to-9-1-1.

4 See EAAC, Report on Emergency Calling for Persons with Disabilities Survey Review and Analysis 2011, July
21, 2011, available at http://transition.fcc.gov/cgb/dro/EAAC/EAAC-REPORT.pdf .
5 See FCC EAAC, Resolution regarding Text Messaging to 911 (adopted March 30 2012)

Note:

Regarding point 1 above: EAAC does not have a detailed breakdown for the cell-phone
figure. It is possible that the 61.8% figure includes all three types: smartphones, feature phones
and basic phones.

Note:

Regarding point 2 above: Since the EAAC survey was conducted, the market share of
tablets has increased rapidly. The importance of tablets as number two in the above ranking is
based on the assumption that today many more people with disabilities use tablets than when the
survey was originally conducted and the adoption of tablet use among this community will
continue to grow.
2.1 User experience
The points below reflect the user expectations, as they pertain to text-to-9-1-1.6

Direct access:

The expectation is that users have direct access to 9-1-1 services. There
are no third parties sitting in the path between callers and telecommunicators.

Initiating contact with 9-1-1:

Users will expect that the primary method of initiating
contact with 9-1-1 is via sending a text message using the three-digit code 9-1-1.

Calling 9-1-1 by voice and receiving text back:

Deaf and hard of hearing users who
have some voice communication capabilities may be able to initiate a 9-1-1 voice calls. These
users may expect to call 9-1-1 by voice and request the PSAP telecommunicator to text them
back.

Not being required to register for 9-1-1 services:

Users cannot be expected to plan
ahead for emergencies. The expectation is that they will not be required to register prior to using
text-to-9-1-1 services. Education may be necessary to help a user appreciate that they will need
to be a subscriber to the relevant text service by which they are attempting to use 9-1-1 services.

Bounce-Back message:

Users will expect to receive information on the success or
failure of a text-to-9-1-1 message. If PSAPs in an area do not support text-to-9-1-1 yet, the user
will expect to receive an automated text response immediately that states that text-to-9-1-1 is not
available and that a voice call should be made to 9-1-1. Note: It is important that the content of
this message be accessible to people with widely varying reading abilities, and as such needs to
be crafted carefully to consider the unique needs of people with disabilities.

Technical note:

The nature of SMS may limit the technical feasibility of the user
expectations with respect to bounce-back messages. It may not be possible to determine success
or failure of SMS message delivery, but rather only the availability of text-to-9-1-1 services.
Likewise, the store-and-forward nature may cause delivery to happen as soon as technically
feasible, rather than immediately.

6 Although the EAAC recognizes that each point describes user expectations for interim Text to 911 services, the
availability of each point will be subject to technical and economic feasibility. Where such features are not
technically or economically feasible to implement for interim Text to 911 services, the unavailability of such
features should be communicated to the end user through public education, as appropriate.

Roaming:

Users will expect the text-to-9-1-1 service to work nearly everywhere within
USA. Users are likely to get confused if there are technical limitations pertaining to roaming
between carriers within USA.

Note:

To the extent that text-to-9-1-1 during roaming within USA cannot be solved via
technical means, it is important that users, as stated in the previous paragraph, that they are
informed about success and failures of a text-to-9-1-1 message. The expectation is that if a
failure occurs due to roaming, or for some other technical reason, the user is informed via an
automated text response immediately. Like in the previous note, the contents of this message
would need to be crafted carefully.

Note:

Failures because of roaming when US users are in other countries and when
phones with foreign subscriptions are used in USA may be easier to understand and accept even
if they will also cause dissatisfaction. They could also point to a solution (e.g. if the user it told
the problem its because the are texting on a phone from outside the country, they may know to
seek out a phone for that country to report their emergency).

Technical note:

As above, the nature of SMS may limit the technical feasibility of the
user expectations with respect to bounce-back messages during domestic and foreign roaming.

Feedback on progress:

Users expect to receive responses to SMS within a certain
amount of time. If a response is delayed, they may become anxious and assume that contacting
9-1-1 has failed. The expectation is that, even if it takes time to process a text message to 9-1-1,
users are kept abreast of what is happening via appropriate text responses.

Technical note:

There are different causes for why SMS responses may be delayed, and
these need to be assessed on a case-by-case basis. For any such cause, the responsibility must be
determined, and the technical feasibility of an SMS response informing the user of the delay
must be evaluated. For example, delays that happen due to internal processes in the PSAP
cannot be handled in the same way as delays that happen due to the technology used for setting
up a session between the TCC and the PSAP (e. g. a TTY call); and these in turn are different
from delays caused by the store-and-forward nature of SMS.
3 Originating Devices and Network
This section responds to the key questions posed by the EAAC regarding the role of originating
networks and devices in Text Messaging to 9-1-1, at a minimum, via short message service
(“SMS”) while also considering the key assumptions outlined by Working Group 1.7 The EAAC
recommends that the FCC recognize the capabilities and limitations of wireless service provider
SMS offered to wireless subscribers as an emergency communications service; lead consumers,
industry and public safety in managing stakeholder expectations; and ensure adequate liability
protections are available to support the provisioning of Text messaging-to-9-1-1 service
accordingly.

7 See FCC EAAC, Resolution regarding Text Messaging to 911 (adopted March 30 2012); Presentation of EAAC
Working Group 1, Text-to-911 Solutions to 911 Interim to NG911 (September 14, 2012) (“EAAC WG1
Presentation”).

Which networks should support 9-1-1 mobile text?

Utilizing the existing standards-based SMS network architectures and capabilities currently
offered by wireless service providers to wireless subscribers, with minimal modifications or
alterations, would be the most technically and economically feasible way to ensure rapid
deployment of SMS-based text messaging to 9-1-1 (“SMS-to-911”).
Significant modifications or alterations to the existing wireless service provider SMS network
standards and architecture would create technical and economic feasibility issues because such
changes require development of new chipsets and firmware for mobile devices and equipment,
and revision of existing network standards and elements in the core wireless networks.
Modifications efforts would take many years and delay implementation of SMS-to-911 by
which time messaging capabilities for Next Generation 9-1-1 (“NG911”) could have already
been developed and deployed.
While SMS-to-911 services can lay a foundation for consumer education and network and PSAP
capabilities that may carry forward into NG911 deployment, a near term deployment of SMS-to-
911 services should not divert industry, public safety, and government resources from further
developing and deploying NG911. All stakeholders should be encouraged to continue standards
development for an NG911 environment to support necessary emergency communications
capabilities on future services, networks and equipment.

What are the originating network issues around other text formats (e.g. Over-the-Top or
Proprietary Solutions)?

Consistent with Section 2 of the CVAA, originating network service providers and equipment
manufacturers can only support emergency communications over the services and equipment
offered directly to wireless subscribers.8 While wireless mobile devices may support Over-The-
Top (“OTT”) and other third party proprietary IP-based text applications that offer “SMS”-like
messaging services, third party OTT and other SMS-like messaging service providers should be
responsible for compliance with a standards-based approach to offer Text Messaging to 9-1-1
services. By complying with standards based approach, third party provided OTT and other
SMS-like messaging services should independently support Text Messaging to 9-1-1
capabilities.

What are the originating network issues around SMS?

The technical and operational issues surrounding the use of SMS as an emergency
communications service are well documented.9 Consistent with these issues, utilizing

8 Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260, 124 Stat. 2751,
Section 2(a)-(b) (2010) (as codified in various sections of 47 U.S.C.) (“CVAA”); see also, Implementation of
Sections 716 and 717 of the Communications Act of 1934
, Report & Order and Further Notice of Proposed
Rulemaking
, FCC 11-151 ¶ 45 (rel. October 7, 2011).
9 Facilitating the Deployment of Text-to-911 and Other Next Generation Applications, Framework for Next
Generation 911 Deployment
, Notice of Proposed Rulemaking, FCC 11-134 ¶ 53 (Sept. 22, 2011); see also, Text
Messages in a PSAP Environment
, APCO Emerging Technologies (rel July 30, 2012) available at
http://psc.apcointl.org/wp-content/uploads/APCO-Emerging-Tech-Text-to-911-Final1.pdf and Texting to 9-1-1:

standards-based SMS network architectures and capabilities currently offered by wireless
service providers to subscribers on their home networks (i.e. not roaming on another wireless
carrier network), with minimal modifications or alterations, would be the most technically and
economically feasible way to ensure rapid deployment of SMS-to-911. Any solution that
requires significant modifications to existing wireless network architectures and standards will
delay deployment of SMS-to-911 and consume resources needed for NG911 deployment.
In order to encourage the timely deployment of text messaging to 9-1-1 services, the EAAC has
assumed that a text-messaging to 9-1-1 solution should not be subject to all of the requirements
of either voice 9-1-1 calls or long-term solutions (i.e. NG9-1-1) so that it can be implemented in
the near term and without extensively reworking carrier, handset, or PSAPs systems.10 Given
this assumption, the following issues should be recognized as necessary to support the near-term
deployment of SMS-to-911:11

Wireless Subscribers with SMS Capable Handsets:

Under existing wireless network
architectures and standards for SMS, wireless carrier SMS text message services are
subscription-based and only service-initialized SMS-capable mobile devices have SMS text
message functionality.
For this reason, wireless subscribers must have an active text message service plan. In addition,
support of SMS-to-911 on non-service initialized (“NSI”) mobile devices is not feasible
because, at a minimum, support for NSI mobile devices would require new standards and
significant modifications to handsets already available to end users and the wireless originator
network radio and core infrastructure.
Therefore, requiring an “all 911 calls” feature for SMS-to-911 service would create lengthy
delays in its implementation. In addition, an “all 911 calls” feature for SMS-to-911 and non-
service initialized mobile devices would impose significant technical and operational burdens on
PSAPs.12

Home Network v. Roaming:

Just as SMS text messaging services are unique to each
wireless service provider, each implementation of SMS-to-911 will be unique to a wireless
service provider’s capabilities. In inter-carrier domestic or international roaming situations,
SMS-to-911 cannot, at this point, be supported because addressing the “Text Originator
Information” and “Home Network Control” issues would require significant modifications to the
wireless originator network and core infrastructure that will ultimately delay the deployment of
SMS-to-911 services. Roaming capabilities should be addressed in NG911 multimedia
emergency services.
Text Originator Information: SMS text messages that are sent between wireless service
provider roaming partner networks (i.e. inter-carrier roaming) do not always pass

Examining the Design and Limitations of SMS, 4G Americas (October 2010) available at
http://www.4gamericas.org/documents/SMS%20to%20911%20White%20Paper%20Final%20October%202010.pdf
10 Supra n.1, EAAC WG1 Presentation, Slide 3.
11 The EAAC believes specific technical issues should be addressed through the FCC’s open proceeding on NG911
and text to 911.
12 See e.g. Petition for a Notice of Inquiry Regarding 911 Call-Forwarding Requirements and Carriers’ Blocking
Options for Non-Initialized Phones
, Notice of Inquiry, FCC 08-95 (Rel. April 11, 2008).

through “Text Originator Information”, including location information. An SMS cannot
be routed to the appropriate PSAP without text originator information.
Home Network Control: SMS text messages are under home operator control which
means that SMS messages are routed to a wireless subscriber’s home network for
processing regardless of the network and location from which the SMS message
originated. In an international roaming situation, home network operator control is
problematic because the home operator network is outside the U.S. and is not capable of
routing a SMS to the appropriate U.S.-based PSAP.

Intermixed Voice and SMS:

Many users would benefit from a possibility to have SMS
intermixed with a voice call. The current wireless carrier network architectures route voice calls
and SMS separately. The voice call path to the PSAP is already implemented. It would therefore
be a significant modification to restructure these connections to allow integration with the SMS
path to handle the two paths as one call with one PSAP operator. It is therefore most realistic to
not implement this integration until in NG9-1-1.

Bounce-Back Notifications of SMS-to-911 Availability:

A wireless subscriber should
receive an automatic reply to their SMS-to-911 message if SMS-to-911 services are not
supported by the appropriate PSAP or the wireless network over which the subscriber originates
an SMS-to-911 message.
Given the issues to generally support SMS-to-911 in a roaming situation, the feasibility of a
bounce back message an inter-carrier domestic or international roaming scenario requires further
study by an appropriate standards body, such as the ATIS-TIA Joint SMS standard body.

Non-Proprietary Solutions:

In order to ensure the timely and consistent deployment of
SMS based Text to 911, industry and public safety cannot be expected to support diverse and
proprietary Text to 911 solutions. The joint ATIS-TIA industry standards for wireless carrier
native SMS-to-911 is one non-proprietary solution that can encourage the timely deployment of
Text to 9-1-1, support a flexible and interoperable environment for multiple wireless carrier and
public safety network configurations, and define capabilities necessary to support SMS-to-911,
including standardized interfaces from the originating network to the PSAP, obtaining coarse
location for routing, handling bounce-back messages, and managing the text message dialog
between the originator and PSAP. Once finalized, the joint ATIS-TIA SMS-to-911 industry
standard will be an open standard available for any entity to adopt such as Over-The-Top
providers.

Do phones or networks or both block three digit 9-1-1 SMS addresses? (if phones - how
many phones?)

SMS-to-911 should be supported by a 3-digit SMS-capable wireless handset, including feature
phones and smartphones. Using any number besides 9-1-1 creates the problem that the wireless
subscriber will have difficulty remembering it when they have an emergency.
However, some legacy devices may not support the ability to send to a 3-digit SMS code.
Originating networks and devices should be permitted to implement a longer SMS code overlay
that has the same functionality as the 3 digit code. Both the 3-digit and longer codes could be
implemented by providers that may have devices that will not support 3-digit short codes.

Options for location provision.

The joint ATIS-TIA industry standards for wireless carrier native SMS to 9-1-1 is one solution
that can encourage the rapid deployment of Text to 9-1-1, support a flexible and interoperable
environment for multiple wireless carrier and public safety network configurations, and define
capabilities necessary to support SMS to 9-1-1, including standardized interfaces from the
originating network to the PSAP, obtaining coarse location for routing, handling bounce-back
messages, and managing the text message dialog between the originator and PSAP. Once
finalized, the joint ATIS-TIA SMS-to-911 industry standard will be an open standard available
for any entity to adopt

Managing Public Expectations is Critical during Interim Text-to-911 Availability

The FCC should take a lead role and work with consumers, public safety, the wireless industry
and other stakeholders to develop a public education program that appropriately explains the
capabilities and limitations of SMS-based Text to 9-1-1 service. As part of managing public
expectations, a text originator should receive a response notifying the originator if Text to 9-1-1
service is not available.
4 Transport Networks including TCC
5 PSAP end
There are a number of administrative and operational considerations for the PSAP text delivery
and response end of the Interim Text process. Impacts and issues requiring careful planning and
implementation relate to overall Interim Text solution characteristics and to local 9-1-1
Authority and PSAP processes and procedures.

Text Control and Delivery:

Several optional methods have recently been described for delivering SMS to a 9-1-1 Center:
 Delivery to the PSAP call handling equipment via Automatic Call Distribution system (where
installed) is preferable.
 Delivery to a standalone web based interface is workable as a temporary step, however taking
calls for an extended period of time outside of the normal call handling system will present
challenges & risks. Maximum integration with existing PSAP call handling and logging systems
is desirable.
 Delivery via gateway at a local, multi-PSAP IP network where available (could include early
NG9-1-1 systems).
 Delivery via SMS conversion to TTY Baudot.

Operational Considerations:

 National level solutions should not rely on the delivery of SMS calls to PSAPs via 10 digit
telephone lines.
 National level solutions should not require a voice call to be placed to 9-1-1 before SMS is
engaged (make a voice dial then switch to text. This is used in some local solution but it is not
feasible for national use).
 Delivery to the PSAP should be in the manner that the PSAP or multi-PSAP 9-1-1 Authority
designates and is part of a standards process (e.g. each carrier cannot have a different solution at
each PSAP, which would force the PSAP to support multiple different solutions).
 The national level Interim Text to 9-1-1 solution must assure that the process for gathering
information from 9-1-1 Authorities as to their operational readiness and delivery preferences is
not cumbersome. A process must be identified by which a single point of contact is established to
gather this information from 9-1-1 Authorities. This could be the TCC vendor, or a Public Safety
organization that already has national PSAP data. Consideration should be given to leveraging
the existing processes for wireless routing spreadsheets that PSAPs must currently use.
 A continuous connection between the text caller and the destination PSAP during an active text
call should be maintained for a period of time defined by the PSAP unless the PSAP ends the
connection. However, the connection between the text caller and a specific PSAP call taker may
not be able to be maintained throughout the conversation.
 To the extent technically feasible (realizing SMS is a store and forward system), the interim text
to 9-1-1 solution should assure that text messages are delivered to the PSAP in chronological
order.
 If the TCC does not see a reply from the PSAP or its equipment for an SMS to 9-1-1 message
within configurable amount of seconds of TCC release toward the PSAP, a notification should be
sent to the text caller that their text has been sent to the 9-1-1 center and a reply is pending.
(Reply wording to be defined)
 The interim text to 9-1-1 solution should provide an automatic message to any texter who
attempts to text 9-1-1 in an area that does not support receiving 9-1-1 SMS messages. The
message should be standardized between carriers in as much as possible and should clearly
advise the caller that they must use an alternate method such as a voice call, relay, or TTY call to
reach 9-1-1.
 The message transport system should provide a message to a text caller indicating that a
communication path has been terminated by a PSAP.
9-1-1 Authority Actions:
 All 9-1-1 authorities and PSAPs should proactively assess the proposed delivery interface
options for interim text to 9-1-1 and whether or not they are prepared to handle text messages.
PSAPs who determine they are not in a position to handle text messages by the designated
deployment timeframe of the national level interim solution are encouraged to make alternate
arrangements for a designated PSAP to handle their text messages, and to proactively research
what it would take to accept these messages in the near future.
 PSAPs should be responsible for designating whether or not they wish to receive text messages
and, if so, their preference for delivery method according to the accepted standard. 9-1-1

Authorities or PSAPs should formally request SMS to 9-1-1 delivery to their PSAP(s) and
identity the desired delivery method(s).
 The PSAP should also designate the minimum period of time that the TCC should maintain text
interaction during periods of inactivity between a caller and the receiving PSAP. The minimum
period of time for inactivity will eventually need to be standardized on a national level. This
standardization will be determined by stakeholders from both public safety and the private sector
and should be based upon testing with consumers and operational experience.
 9-1-1 Authorities or PSAPs should be responsible for keeping their text delivery preferences up
to date with the service provider, TCC vendor, or other central point for interim SMS to 9-1-1
services. PSAPs should assess requirements for logging of text messages and assure that the
delineation of responsibility for this functionality is clearly defined.
 PSAPs that are handling multiple calls during busy times may decide to terminate a text
connection to assure that their telecommunicator are able to handle other incoming emergency
calls in a timely manner. The decision as to how long a PSAP telecommunicator stays “ready” to
accept text from a specific caller should be based on local policy.
 The method by which a PSAP is/is not able to handle delivery of other services such as medical
pre-arrival instructions must be implementation specific and based on local policy.

FCC Considerations:

 The FCC should facilitate (to the extent possible) a method to channel PSAP text readiness and
delivery preferences through a single point of contact process.
 The FCC should facilitate public education (directly and/or through Public Safety organizations)
on the national level interim solution. Consumers must be made aware that proprietary text
systems may not be compatible with the national level interim solution. Focused education
should be provided for the deaf, hard of hearing and speech disabled community of users to
assure they understand the capabilities of the interim solution and to assure they understand that
TTY will continue to be supported for those that rely on it.
 The FCC should work with appropriate industry representatives to identify and maintain a public
list of any wireless handsets that will not support SMS to 9-1-1 text capabilities or identify
feasible alternative technology solutions, such as a four digit code. The FCC should work with
appropriate industry representatives to allow a solution via educational or technical means.
 The FCC should characterize what the expectation is of the many proprietary systems that have
been purchased/implemented in different areas to handle text to 9-1-1. PSAPs may choose to
implement other text systems as long as it does not preclude their ability to support the national
level SMS interim solution. Educational efforts will be complicated by the use of multiple
solutions.
 Other than deployment or maintenance testing, text to 9-1-1 test messages should not be required
and should not traverse the network to the PSAP call takers. If it is deemed necessary to provide
the ability for the general public to “test” text to 9-1-1 capabilities, an alternate method must be
applied to handle this text to 9-1-1 verification process. Further investigation of the options is
required.

What are the secondary deployment priorities for national level SMS to 9-1-1?

 An open standardized interface between the TCC and legacy E9-1-1 PSAP call handling
software. In a pre-NG9-1-1 system the call handling software is often referred to as CPE
(Customer Premise Equipment)
 The capability to open an audio path with the caller’s device would greatly improve the PSAPs
ability to determine the nature of the incident being reported. Further study of the technical
feasibility of this feature is required.
 A method by which to incorporate 9-1-1 text calls into a PSAP’s call handling analysis system
(typically a management information system –MIS) so they can effectively analyze any impact to
the quality of the service they provide.
 An E9-1-1 class of service that will allow PSAPs to differentiate an SMS message from other
voice or TTY calls. This may be possible for only some interface methods.
 The capability for Intra-PSAP transfers (i.e. transfer between telecommunicators or to a
supervisor in the same PSAP (or 9-1-1 system) is required to assure effective operations.
Presumably a function of the Public Safety equipment or delivery network.
 Ability to transfer text calls to other text capable PSAPs or other text capable systems outside the
9-1-1 service system. Presumably a function of the Public Safety equipment or delivery network.
 Ability of the text call-handling application to handle multiple texts dialogs simultaneously.

If implementation at legacy PSAPs is voluntary, should a time limit be imposed wherein a
legacy PSAP or designated authority is mandated to accept text calls other than current
TTY Baudot?

While a time limit should not be imposed prior to initial implementation, there should be a
deadline for a PSAP to designate an answering point. Within 6 months of interim text to 9-1-1
solution, a time line for PSAP acceptance should be established, based upon initial
implementation experiences. The following are PSAP operational considerations that should be
incorporated into the ongoing dialogue of interim text deployment:
 While it is a fact that TTY is mandated for all PSAPs, it is not accessible to the general public.
The impact of interim text, even when converted to TTY, cannot be equivalently
compared. Appropriate solutions should be pursued for national deployment; consideration of
time mandates is not appropriate at this early stage of development. There are several operational
impacts that must be taken into account before solutions are actively pursued:
 The text solutions based on SMS do not support voice in the same call as SMS. There are users
who wish to use a combination of voice and text when communicating with a PSAP (i.e. voice in
one direction and text in the other). . The industry should research if this technology can be
made available for deployment within interim solutions. The PSAP call handling interface should
have the capability to indicate when it is possible to use voice in parallel with interim text calls,
when it is not possible , and when voice is possible but with functional limitations. Further
discussion should take place to identify specific requirements for these capabilities.
 Small PSAPs with 1-2 individuals on duty, who must answer incoming calls as well as dispatch
and manage radio traffic will be increasingly challenged to multitask and manage incoming 9-1-1
text calls. Simultaneously “talking and typing” has become a common multitasking skill for

many PSAP personnel. Text calls however will require multitasking at a different level. A
telecommunicator who must track unit status by typing information into a CAD system will not
be able to simultaneously “type” responses to a caller via text. If a national level interim text
solution is backed by the FCC, these PSAPs will need time to identify and implement
procedures.
 Some PSAPs may consider using a regional approach whereby a single PSAP handles text
calls for a group of other PSAPs. This type of mutual aid scenario will take time to analyze
and implement.
 Not all PSAPs have TTY built into their call handling systems or CAD, many still use legacy
standalone TTY devices. This does not lend itself to a productive way to implement text for
the general public.
 Some PSAPs do not have computerized call handling systems or CAD. Telecommunicators
in these cases use hand written processes to create incidents and track emergency responders
in the field.
 Once national level interim text is adopted and a number of PSAPs start making the
transition to use it, we should review what can be done to encourage adoption by the PSAPs
that will initially not be able to opt in. The interim solution will be around for many years so
we need to do everything we can to further its use.

Are there limitations that will be encountered in an interim text solution that will impact
the level of service that is typically provided during a voice based 9-1-1 call?

 Services typically provided by secondary PSAPs or other dispatch centers may not be available
during an interim solution via text if the secondary PSAP does not support text. Primary and
secondary PSAP interaction via voice communication may be required. (Primary PSAP would
respond to texter).
 Services provided by other partner agencies such as transportation agencies, poison control and
language services may not be available if those entities cannot support a text conversation or if
the PSAP is unable to create a multiparty communication with them.
 Emergency Medical Dispatch (EMD) instructions as provided for voice calls may not be initially
available or may not be able to be provided in a timely manner to text based callers. It is
understood that EMD is not uniformly available to TTY callers. The FCC must be cognizant of
the fact that the general public may expect this level of service to be provided if they text an
emergency to 9-1-1.
6 Issues
6.1 National Interim Text and Vendor Proprietary Solutions
More than a dozen proprietary text solutions, often involving additional multimedia data
features, have appeared during the 2011-2012 timeframe, been marketed to PSAPs and
Counties, and implemented in localized areas around the USA. Other than those that utilize a

silent 9-1-1 voice call to establish initial connection to a PSAP, these solutions often have no
interaction with the E9-1-1 systems, rather using Internet or other separate networking and
proprietary software and often separate hardware at the PSAP to accomplish their user to PSAP
interaction.
With the coming presence of a national SMS interim text solution, and without any other
actions, users would be confronted with a situation where their local PSAP or County may (or
may not) have implemented one of several proprietary solutions, quite possibly applicable only
within their jurisdiction. When the mobile user moves out of the area where they know a
specific proprietary solution is available, they would not know if, or which, proprietary solution
is applicable at their new, current location. However, the national SMS solution is likely to be
available to them there.
The user will likely try their usual “at home” method, then find that it doesn’t work and be
forced to manually start a new emergency communication sequence, losing valuable time in an
emergency situation. It may be possible to integrate some proprietary solutions into the national
TCC routing and delivery process, but that will require more investigation and the determination
of whether the solution providers are willing to take that approach. There may also be other
options, which again will require more investigation.
The FCC should work with public safety, DOJ and hearing and speech disability community to
work with commercial vendors to ensure their software solutions meet expectations for
emergency services. A combination of Public Safety, FCC, DOJ, and hearing and speech
disability groups could likely use “directive influence” in negotiating with vendors for any
changes to their software solutions.
Without such an approach nationally, text users will increasingly continue to be uncertain as to
what works where, with an attendant risk of delayed emergency contact and response.
6.2 Responsibilities and Policies
6.3 Future Considerations
7 Actions needed to build this (what is not already in place)
7.1 Education and Outreach

8 Conclusion
9 Recommendations

Appendix A: Glossary


Appendix B: Use Cases for SMS-based text-to-911


Revision History

Date

Version

Description

10/26/12
0.01
Initial document skeleton built on the report outline which was extracted from the web
page as of 26 October 2012 12:57 PM Pacific.
11/15/12
0.02
Incorporated the following contributions:
- Document titled “121113 EAAC SG1 Sec 4 Originating Network Devices
(DRAFT)” from Matt Gerst.
- Document titled “PSAP Capabilities section 5 draft 111112” from Roger Hixson.
- Document titled “SC1 Report 6.1 draft 111112” from Roger Hixson.
11/18/12
0.03
This version was created by Gunnar Hellstrom to incorporate his content for Chapter 4
Transport. This version was sent by Gunnar to only a limited set of individuals.
The next version created by the Editor will be given version number 0.04 in order
to avoid confusion of multiple different versions numbered 0.03.
11/28/12
0.04
Incorporated the following:
- Section 4 Transport from version 0.03
- Revisions from the EAAC1 conference call on November 28th 2012
- Section 2 User Needs and Constraints distributed by Christian Vogler via email
on November 28th 2012.
12/3/12
0.05
This version incorporates the results of the EAAC subgroup 1 conference call on
Monday, December 3rd 2012. The subgroup review on December 3rd was based
upon a marked up version from Gunnar Hellstrom and Matt Gerst called “EAAC
WG1 Text to 9-1-1 Recommendations ver 0.04 gh2 mg” which was emailed by
Matt Gerst on Monday December 3rd 2012 at 10:46 AM Pacific.
This version also incorporates Christian Vogler’s contribution to section 7.1 which is
titled “SG1-7.1” which Christian emailed on Monday December 3rd 2012 at 7:50
AM Pacific.
The following Editor’s Assignments were also completed:
- Created a new Section 6.3 Future Considerations using two topics and associated
bullet items from Section 5 PSAP end
- Moved the last bullet of Section 5 PSAP end to the end of Section 7.1 Education
and Outreach.
12/5/12
0.06
This version incorporates the results of the EAAC subgroup 1 conference call on
Wednesday, December 5th 2012 and also includes the following contributions:
- Use case contribution from Christian Vogler sent via email on Wednesday
December 5th 2012 at 7:56 AM Pacific
- Overview section from Matt Gerst sent via email on Wednesday December 5th
2012 at 7:32 AM Pacific
12/12/12
0.07
This version incorporates the results of the EAAC subgroup 1 conference calls on
December 11th and 12th 2012 and also includes comments and proposed
modifications that were distributed via email.

Date

Version

Description

12/13/17
0.08
This version incorporates the results of the EAAC subgroup 1 conference call on
December 13th 2012 and is the draft version of the report to be presented to the
EAAC on Friday December 14th 2012. Sections 1, 2, 5, and 6.1 were updated on
today’s conference call and will be included. The content of the following
sections has been deleted since the open issues have not been resolved for
inclusion in version:
- Section 4 Transport including TCC
- Section 6.3 Future Considerations
- Section 7.1 Education and Outreach
- Appendix A Glossary
- Appendix B: Use Cases for SMS-based text-to-911

Document Outline


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