NSI Cell Phones – Suffocating our E911 Networks

NSI Cell Phones - Suffocating our E911 Networks?

An issue today that is causing considerable concern for PSAPs, is the number of hoax and false calls from cellular devices categorized as Non-Service Initiated (NSI) cell phones.

An NSI phone is a cell phone that has no active carrier subscription, or service plan. The phone is still completely functional, but just is unable to make or receive any phone calls; with one important exception.

An FCC report and order, dating back to June 12, 1996, found at:  (https://transition.fcc.gov/Bureaus/Wireless/News_Releases/1996/nrwl6026.txt) states that within 12 months carriers must:

(T)ransmit to a Public Safety Answering Point (PSAP), 911 emergency calls from a handset that transmits a Mobile Identification Number (or its functional equivalent) (MIN), without any interception by the carrier for credit checks or other validation procedures.

During the comment phase,  directors of many 9-1-1 centers were concerned that if only calls with a valid mobile ID number were required to be sent to 9-1-1, real emergency calls would be missed.  To satisfy this, the FCC added language as follows:

(A)fter twelve months (…) transmit all 911 calls (including calls from phones that do not transmit a MIN) without any credit checks or validation.

This was done despite the FCC’s warning of possible hoaxes being perpetrated from these devices.

As cellular devices became more popular over the next five years, a growing number of  calls to 9-1-1 were being generated from these NSI cell phones, plaguing PSAPs with nonemergency call traffic. The proverbial flood gates were now open, and in response, the FCC issued a second report and order in 2002 that required carriers to transmit a special code that would indicate to the PSAP that the originating device was an NSI category device, indicating that no call back was possible.

The provision was also added so that PSAPs would be  allowed to request that the carrier block specific device numbers based on the unique identifier of 911+ the last seven digits of the cell phone ESN; something that was not completely unique, but deemed as suitable for this purpose.

NSI devices were now identifiable, however, carriers were still reluctant to block them, fearing the liability of blocking a valid 911 call attempt. They stated that specific roaming circumstances could cause a device to appear as an NSI device, and they were unsatisfied with the definition of “block”, as provided by the report and order. The carriers feared that the language blocked the person and not the specific device, although the unique identifier only related to the equipment.

During this time  statistics were also captured that provided visibility as to the size of the actual problem. For example, during a three-month period in 2006, Tennessee reported that 10,000 calls originated from NSI phones, with between 1% and 3.5% being actual emergencies. In one month’s time, Florida reported 8400 calls. Six counties in the state of Michigan, and Snohomish County, Washington also reported similar numbers. Despite real emergency calls still being in the minority, there was still enough instances to warrant further investigation into alternatives to outright blocking of all calls from NSI devices. The FCC sought comment on these alternatives, as the current plan of PSAPs requesting the blockage of specific numbers was not one that carriers were cooperating with, citing “technical and legal concerns”.


PLAN A – Add Callback Capability

This plan would entail adding the ability to be able to call back and NSI cellular device, in an attempt to confirm location and validity of a 911 call. This would remove the complete anonymity that the current NSI calls enjoyed when calling 911. In their 2002 report, the FCC reported that callback numbers were not a technologically feasible option based on the current technology.

PLAN B – Eliminate 911 Call Forwarding for NSI Devices

This plan took the stance that  NSI devices  would no longer be forwarded to 911 centers. In their 2002 report, the FCC reported that blocking NSI calls to 911 would have an impact on potentially blocking valid calls, but should be considered.

PLAN C – Require all phones to be Service Initiated

Based on the significant expense that PSAPs are incurring to deal with NSI call traffic, could that funding be redirected to those who are providing NSI devices, And enable them to provide SI devices on low-cost emergency only plans.

Oddly enough, the location accuracy dilemma was also brought up during this round of discussions; something we’re still fighting with today. It was noted that if we had better location accuracy, we would be able to identify the location of the devices generating fictitious or prank calls, and intercept them.

This brings us to today, and the current FCC Notice of Proposed Rulemaking, downloadable from:(https://apps.fcc.gov/edocs_public/attachmatch/FCC-15-43A1.pdf)

Once again, the FCC is looking to sunset the requirement to pass 911 calls from NSI devices to PSAPs – after a 6 month transition period; this time around, it may actually happen – based on the comments received recently supporting the sunset of this functionality. The comments that have been filed are available here: http://apps.fcc.gov/ecfs/proceeding/view?name=08-51

In this recent NPRM the FCC asked for the following:

“In this Notice of Proposed Rulemaking (NPRM), we seek comment on whether the obligation to transmit 911 calls from NSI devices continues to serve an important public safety objective. A primary rationale for the initial adoption of the Commission’s rule in the late 1990s was to expedite wireless calls to 911 that would otherwise have been delayed due to lengthy call validation processes for unidentified callers that were commonly used at the time. In the nearly two decades since the rule was adopted, however, the call validation methods of concern to the Commission are no longer in use. Moreover, the availability of low-cost options for wireless services has increased. These trends suggest that the NSI component of the requirement is no longer necessary to ensure that wireless callers have continued access to emergency services. Further, the inability to identify the caller creates considerable difficulty for PSAPs when a caller uses an NSI device to place fraudulent calls.  Public safety representatives have indicated that NSI devices are frequently used to make such calls, causing a significant waste of limited public safety resources. For these reasons, we propose to sunset the NSI component of the rule after a six-month transition period that will allow for public outreach and education. We also seek comment on alternative approaches to addressing the issue of fraudulent calls from NSI devices.”

Have we reached the tipping point?

Has the constant drain on public safety financial funding, coupled with the excessive workload of irrelevant calls, finally bled the system so dry to where it’s starting to impact life safety on real 911 calls?

One thing is certain, this problem is not going to go away, nor is it going to improve by itself. The saturation of cellular devices has now exceeded 100% in the United States, and currently, these cellular devices make up 80% of the traffic into 911 centers, a statistic that is valid across this country.

NSI phones have been the source of many SWATTING incidents and hoax calls, and many will argue that the sheer number of verified and Service Initialized cellular devices that are available precludes the need for E911 support on NSI devices.

Communications as we know it has  changed under our very noses, and this has put a huge economic and technology strain on our national 9-1-1 system. Without immediate and swift action, not only will 9-1-1 be quickly bankrupt, we will put at great risk the lives of our loved ones.

Bottom Line: Today’s 9-1-1 centers and the network desperately needs a technology refresh known as Next Generation 9-1-1 (NG911).  We have allowed this life safety industry to go stale, afraid to touch what was not seen as broken, while the rest of the world moved forward with new, modern communications.

As we currently rebuild this national resource with new technology, we must keep in front of our minds that what is needed is not just new, but  smart technology. Technology that will not only reduce operational costs, but provide better efficiency, as well as robust  resiliency and reliability that is on par with commercial networks deployed today and empowering our world financial centers.

Are we missing the mark?In days past, the value behind ‘Public Safety Grade’ technologies have suffered and diminished.  Where experts often require ‘Five 9’s reliability’, that in itself only allows for 5 minutes of downtime per year. Is anyone actually getting that? Is it enough? Chances are, many centers are in the 4 9’s category or even worse.

Availability (9’s) Annual Downtime Monthly Downtime Weekly Downtime
99.99%       (4) 52.56 minutes 4.38 minutes 1.01 minutes
99.999%     (5) 5.26 minutes 25.9 seconds 6.05 seconds
99.9999%   (6) 31.5 seconds 2.59 seconds 604.8 milliseconds
99.99999% (7) 3.15 seconds 262.97 milliseconds 60.48 milliseconds

“Given the critical life safety responsibility of these networks, shouldn’t we be striving for 6 or 7 nines, not just 5?

The role of the 911 technology expert, is being radically reshaped and changed. While some of the core principles remain the same, many others have not.  We need to step into the current century from a technology perspective.

To think that most 911 centers collect their location data based on basic billing address information using archaic 9600 bps modems, – all  technologies developed in the disco era –  simply scares the hell out of me!

Follow me on Twitter @Fletch911

Read my other AVAYA CONNECTED Blogs

Mark J. Fletcher, ENP is the Chief Architect for Worldwide Public Safety Solutions at Avaya. As a seasoned professional with nearly 30 years of service, he provides the strategic roadmap and direction of Next Generation Emergency Services in both the Enterprise and Government portfolios at Avaya. In 2014, Fletcher was made a member of the NENA Institute Board in the US, and co-chair of the EENA NG112 Committee in the EU, where he provides insight to State and Federal legislators globally driving forward both innovation and compliance.

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