Memorial Day, celebrated each year on the last Monday of May, is to remember and honor those who have died while serving their country in the armed services. They gave the ultimate sacrifice for our country and our freedom.
THANK YOU. . .
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Changing the Game
Changing the Game:
While the age-old adage “Don’t fix it if it’s not broken” still holds true, there are times when change is required to move the yardstick ahead. When reviewing 9-1-1 emergency services for commercial enterprise networks, the same holds true. With everything we must understand in the network, E9-1-1 is just one more thing we don’t have time to learn, and IT administrators often tend to believe that what sounds logical and appears to be the most obvious. This is often erroneously considered to be the accepted and safest path, despite the availability of alternative, more cost effective options.
By nature, we are creatures of habit, but we do retain a creative streak. We innovate, we invent, and we remain on a constant quest to improve the things we build, making our lives easier, as well as more efficient. At times, we experience exceptional moments of clarity, sporadic visions of innovation, and the much more rare epiphany that often brings forward the greatest innovations.
A classic TV commercial from the 1970’s can quickly sum this up; “SMACK! I could have had a V8!”
Whether you liked that product or not, I would venture a guess that we all have referenced that “Meme” for the various epiphanies that we have experienced throughout life. If nurtured, and brought through the appropriate workflows, these ideas can become the ones that bring forth the game-changing innovations.
I had ‘the epiphany’ to just keep it simple and down to the basics
In a recent interview for an AVAYA CONNECTED blog article, I commented on an incident that has stayed top of mind with me the past 24 months; that of course is Kari’s Law. I reflected on when I was crafting the requirements for this legislation, I had ‘the epiphany’ to just keep it simple, and down to the basics. After all, maybe the complexity behind the current MLTS Model Legislation was the reason that very little progress was being made, almost to the point where growth had stagnated.
An industry workgroup under NENA had drafted Model Legislation a decade earlier, but despite those great efforts, minimal legislative progress had been made. Why have these efforts stagnated? It is likely that, as engineers, we dove so deep into the technical side of the problem providing solutions to the location issues, we neglected the basic premise of 9-1-1: ACCESS TO THE 9-1-1 PSAP. After all, if 9-1-1 is not reachable, the rest of the solution becomes irrelevant.
Of course, all aspects of 9-1-1 are necessary with some of them being quite complex. With the industry just becoming comfortable with VoIP, and understanding the mobility it afforded telephony users as well as the impact on E9-1-1 services. Administrators had done a decent job managing expectations and deploying networks that were safe, and many solutions flourished selling services to update the ANI/ALI Public Safety Database providing details to the PSAP dispatcher.
“[But] everyone else does it another way”
I am regularly asked why so many people fight the requirements for deploying enterprise E9-1-1 solutions.? My response is that this is essentially due to the perception that solutions are costly and difficult to manage; a fact that is untrue, as the basic functionality required is included in the core functionality of most MLTS PBX systems, including Avaya. While in some cases, these features may not be sufficient to solve a few of the most complex problems. Even the most complex campus deployments and larger systems still require a core solution, and when properly utilized the right implementation can significantly reduce the price of external solutions; or even minimizing the overall need for them. Because E9-1-1 is a bit of a ‘black art’, and not well understood, it is often off-loaded to external applications, where the Enterprise looses control over what is happening. Typically, I stay clear from this architecture, but while at a recent user event in Detroit, I was challenged by the fact that “everyone else does it the other way” so that MUST be the best way.
If this premise were true, then all innovation would ultimately stagnate, and nothing would ever change. If the Wright brothers never tried at Kitty Hawk, we would have remained Earthbound, if innovators and inventors like Bell and Edison, didn’t push their limits, or if evolution stopped with the initial deployment, think of the great things we would be missing today. These accomplishments mainly apply to technology related concepts. Token Ring introduced us to shared media and the concept of a network. Ethernet expanded that into ‘networking networks’ and the notion of the ‘Internet’, arguably one of the most significant points on the modern network timeline, was born and evolved into the digital fabric it is today linking humanity at a global level. I am sure the manufacturers of Coaxial cable wondered how they could maintain their segment of the business.
For years, we have been led to believe that the existing legacy ANI/ALI databases are the only way to convey information to the PSAP for commercial enterprise networks. In reality, very little information can be conveyed in this way, and the information is of little value to the dispatch of services. Situational Awareness is my new Best Practice for E9-1-1 in the Enterprise; and putting that information in the hands of the people that need it, and the devices they need it on.
As conditions change and additional information is available, we need to utilize that context, and make it available to those responding that can use the information. While understanding the origination point of the emergency is important, let not forget that in many instances it is the information that surrounds the situation that becomes the most relevant. For example in a fire, a heat map supplied by the Building Management System can provide important information for 1st responders, that are enroute to the scene.
Our E911 networks can no longer be based on ‘best effort routing’ logic
We must change the baseline of how we make decisions, and the information we rely on. No longer will the archaic standards from our past support the new and innovative modalities that are commonplace in commercial networks today. We can no longer apply ‘best effort routing’ logic that does not take into consideration priority traffic and a shortest path routing schemas. When networks were originally built, they mostly just carried email, and web browser traffic. Based on that, these constructs may have been deemed sufficient. But today, traffic is multimodal, it needs to remain secure, and it needs to have some core level of assuredness when it comes to service delivery. And when that is said and done, we need to deliver it to the right people.
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 directs the strategic roadmap for 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, in 2014 – 2015 he served as co-chair of the EENA NG112 Committee in the European Union, providing valuable insight to State and Federal legislators globally driving forward both innovation and compliance.
FCC NewsBytes 11/28
LISTEN TO THE PODCAST HERE:
REMINDER OF VIDEO PROGRAMMING DISTRIBUTORS’ OBLIGATIONS TO MAKE TELEVISED EMERGENCY INFORMATION ACCESSIBLE FOR PEOPLE WITH DISABILITIES; COMPLIANCE DEADLINE ANNOUNCED FOR NEW PROVISIONS
By this Notice, the Federal Communications Commission (FCC or Commission) announces that, beginning on November 30, 2015, in accordance with section 79.2(b)(2)(ii) of the Commission’s rules,[1] video programming distributors (VPDs)[2] must ensure that their televised emergency information is conveyed aurally through the use of a secondary audio stream,[3] when such information is conveyed visually during programming other than newscasts.
Section 202 of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA) directed the Commission to promulgate rules requiring video programming providers, video programming distributors, and program owners to convey emergency information in a manner accessible to individuals who are blind or visually impaired.[4] On April 9, 2013, the Commission released the Accessible Emergency Information Order implementing this mandate.[5]
Specifically, when emergency information[6] is being provided in the video portion of programming that is not a regularly scheduled newscast or a newscast that interrupts regular programming (e.g., the programmer provides the emergency information through “crawling” or “scrolling” text during regular programming), the information must be accompanied by an aural tone and provided aurally on the secondary audio stream.[7] The aural tone will alert consumers who are blind or visually impaired to the presence of an emergency situation, and give them an opportunity to switch to the secondary audio stream.[8] The information imparted over the secondary audio channel must be preceded by the aural tone, and must be conveyed in full at least twice.[9] VPDs must also ensure that that their video programming apparatus be capable of delivering such emergency information in an accessible manner to individuals who are blind or visually impaired.[10]
In addition, on May 28, 2015, the Commission released a Report and Order requiring multichannel video programming distributors (MVPDs) to pass through the secondary audio stream containing audible emergency information when it is provided on linear programming accessed on second screen devices (e.g., tablets, smartphones, laptops and similar devices) over the MVPD’s network as part of their MVPD services.[11] Linear programming is generally video programming that is prescheduled by the video programming provider. This requirement must be implemented no later than July 10, 2017.[12] In this order, the Commission also required apparatus manufacturers to provide a mechanism that is simple and easy to use, such as one that is reasonably comparable to a button, key, or icon, for activating the secondary audio stream to access audible emergency information by December 20, 2016.[13]
We also remind VPDs of their existing obligation to ensure that emergency information be provided in a manner that is accessible to persons who are deaf or hard of hearing. Commission rules require that emergency information provided in the audio portion of the programming be made accessible using closed captioning or other methods of visual presentation, including open captioning, crawls or scrolls that appear on the screen.[14] Emergency information provided by these means may not block any closed captioning, and closed captioning may not block any emergency information provided by crawls, scrolls, or other visual means.[15] The “pass through” obligation, generally requiring VPDs to ensure that viewers receive closed captions intact under section 79.1,[16] also applies to emergency information encompassed by section 79.2.[17]
As we have previously noted,[18] the need to comply with section 79.2 is not always limited to the immediate geographic areas affected by the emergency because critical details about the emergency and how to respond – for example, relocation information – may need to reach individuals outside that immediate geographic area, and, therefore, fall within the rule’s mandate.[19] Accordingly, compliance with section 79.2 may include providing information to areas outlying an area immediately impacted by a large-scale disaster, such as that which occurred in February 2014, when a severe winter storm in the Midwest and eastern parts of the United States caused electrical outages for nearly 1 million customers across a wide region. In addition, we note that there are times when the airing of emergency information pertaining to a matter of national importance will also be of local concern, and, therefore, should be made accessible. Various emergencies over the past year, ranging from the January 2015 North American blizzard (unofficially known as “Winter Storm Juno”), the October 2015 North American Storm Complex, the July 2015 Alaskan earthquakes, wildfires in the western states, and a spate of destructive tornadoes in the Midwest underscore the vital nature of compliance with this rule.
Fact sheets summarizing the closed captioning and access to emergency information rules are available at the FCC’s Web site at http://www.fcc.gov/guides/closed-captioning, and http://www.fcc.gov/guides/emergency-video-programming-accessibility-persons-hearing-and-visual-disabilities.
To request this Public Notice or any other materials in accessible formats for people with disabilities (Braille, large print, electronic files, audio format), send an e-mail to fcc504@fcc.gov or call the Consumer and Governmental Affairs Bureau at 202-418-0530 (voice) or 202-418-0432 (TTY).
Consumer and Governmental Affairs Bureau Contact: Eliot Greenwald, 202-418-2235, e-mail eliot.greenwald@fcc.gov.
-FCC-
[1] 47 C.F.R. § 79.2(b)(2)(ii). See Accessible Emergency Information, and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010; Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010, MB Docket Nos. 12-107 & 11-43, Report and Order and Further Notice of Proposed Rulemaking, 28 FCC Rcd 4871 (2013) (Accessible Emergency Information Order). Compliance with the Commission’s new rules was required beginning on May 26, 2015. 47 C.F.R. §§ 79.2(b)(2)(ii), 79.105(a), 79.106(a). However, on May 26, 2015, the Commission’s Media Bureau granted waivers of the emergency information rule: (1) for certain hybrid (digital/analog) cable systems, conditioned on providing free equipment to analog customers who are blind or visually impaired to enable access to the digital secondary audio stream; (2) for certain analog-only cable systems until June 12, 2018; (3) for broadcasters until November 30, 2015; (4) for visual but non-textual emergency information, such as maps or other graphic displays, for a period of 18 months; and (5) for school closing information, while the Commission reconsiders this requirement. See Accessible Emergency Information, and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010; Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010, MB Docket Nos. 12-107 & 11-43, Memorandum Opinion and Order, 30 FCC Rcd 5012 ¶ 1, 5021 ¶ 16 (MB 2015).
[2] See 47 C.F.R. § 79.1(a)(11) (defining “video programming distributor”).
[3] A secondary audio stream is an audio channel, other than the main program audio channel, that is typically used for foreign language audio and video description. Video description, which is also referred to as audio description, is defined as “[t]he insertion of audio narrated descriptions of a television program’s key visual elements into natural pauses between the program’s dialogue.” 47 C.F.R. § 79.3(a)(3).
[4] Pub. L. No. 111-260, 124 Stat. 2751 (2010) (as codified in various sections of 47 U.S.C.). See also Amendment of Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-265, 124 Stat. 2795 (2010) (making technical corrections to the CVAA).
[5] Accessible Emergency Information Order, 28 FCC Rcd at 4872 ¶ 1; see also 47 U.S.C. § 613(g)(2).
[6] The CVAA directed the Commission to apply the definition of “emergency information” found in the Commission’s rules. 47 U.S.C. § 613(g)(1). “Emergency information” is defined in these rules as “[i]nformation, about a current emergency, that is intended to further the protection of life, health, safety, and property, i.e., critical details regarding the emergency and how to respond to the emergency. Examples of the types of emergencies covered include tornadoes, hurricanes, floods, tidal waves, earthquakes, icing conditions, heavy snows, widespread fires, discharge of toxic gases, widespread power failures, industrial explosions, civil disorders, school closings and changes in school bus schedules resulting from such conditions, and warnings and watches of impending changes in weather.” 47 C.F.R. § 79.2(a)(2). “Critical details include, but are not limited to, specific details regarding the areas that will be affected by the emergency, evacuation orders, detailed descriptions of areas to be evacuated, specific evacuation routes, approved shelters or the way to take shelter in one’s home, instructions on how to secure personal property, road closures, and how to obtain relief assistance.” Note to 47 C.F.R. § 79.2(a)(2).
[7] See 47 C.F.R. § 79.2(b)(2)(ii).
[8] Accessible Emergency Information Order, 28 FCC Rcd at 4881 ¶ 12, 4892 ¶ 25.
[9] 47 C.F.R. § 79.2(b)(2)(ii); Accessible Emergency Information Order, 28 FCC Rcd at 4881 ¶ 12.
[10] Accessible Emergency Information Order, 28 FCC Rcd at 4913-16 ¶¶ 60-62. See also 47 U.S.C. § 303(u); 47 C.F.R. §§ 79.105, 79.106.
[11] See Accessible Emergency Information, and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010, MB Docket No. 12-107, Second Report and Order and Second Further Notice of Proposed Rulemaking, 30 FCC Rcd 5186, 5191-95 ¶¶ 9-15 (2015) (Accessible Emergency Information Second Report and Order); see also 47 C.F.R. § 79.2(b)(6).
[12] 47 C.F.R. § 79.2(b)(6); Accessible Emergency Information Second Report and Order, 30 FCC Rcd at 5197-98 ¶¶ 19-21.
[13] Accessible Emergency Information Second Report and Order, 30 FCC Rcd at 5198-206 ¶¶ 22-36; see also 47 C.F.R. § 79.105(d).
[14] See 47 C.F.R. § 79.2(b)(1); Clarification of Obligation of Video Programming Distributors to Make Emergency Information Accessible to Persons With Hearing Disabilities Using Closed Captioning, Public Notice, 21 FCC Rcd 15084, 15086 (2006) (December 2006 PN).
[15] See 47 C.F.R. § 79.2(b)(4).
[16] 47 C.F.R. § 79.1(c).
[17] See Closed Captioning and Video Description of Video Programming; Implementation of Section 305 of the Telecommunications Act of 1996; Accessibility of Emergency Programming, Second Report and Order, 15 FCC Rcd 6615, 6622, ¶ 13, n.48 (2000) (2000 Order). VPDs are required to pass through any captions that they receive from the originating source and are responsible for maintaining their equipment in working order to ensure the accurate transmission of the closed captions. Id.
[18] See e.g., Reminder Regarding Video Programming Distributors’ Obligation to Make Emergency Information Accessible to Persons Who are Deaf, Hard of Hearing, Blind, or Visually Impaired, Public Notice, 29 FCC Rcd 15096 (2014).
[19] See 47 C.F.R. § 79.2 Note to paragraph (a)(2): “Critical details include, but are not limited to, specific details regarding the areas that will be affected by the emergency, evacuation orders, detailed descriptions of areas to be evacuated, specific evacuation routes, approved shelters or the way to take shelter in one’s home, instructions on how to secure personal property, road closures, and how to obtain relief assistance.”
FCC NewsBytes 11/27
LISTEN TO THE AUDIO PODCAST VERSION HERE
Download the document HERE: – DA-15-1367A1.pdf
DA 15-1367 – Released: November 25, 2015
WIRELINE COMPETITION BUREAU APPROVES TRANSITION OVERSIGHT PLAN FOR NEXT LNPA; ANNOUNCES FIRST TRANSITION OUTREACH WEBCAST
WC Docket No. 07-149
WC Docket No. 09-109
CC Docket No. 95-116
On August 31, 2015, the North American Portability Management LLC (NAPM LLC) filed a revised Transition Oversight Plan (Transition Plan or TOP) to help guide the process of transitioning to the next Local Number Portability Administrator (LNPA). On October 29, 2015, the NAPM LLC filed an updated Transition Outreach and Education Plan (TOEP), which is appended to the Transition Plan as Attachment 5. By this Public Notice, and as fully discussed below, the Wireline Competition Bureau (Bureau) approves the revised Transition Plan and announces the first transition outreach webcast.
On March 26, 2015, the Commission adopted an Order accepting a recommendation from the North American Numbering Council, in coordination with the NAPM LLC, to select Telcordia d/b/a iconectiv (Telcordia) as the next LNPA. The Commission conditionally accepted that recommendation subject to certain conditions and subject to its approval of the contract between the NAPM LLC and Telcordia.[1] One condition required by the Commission is that the NAPM LLC file a Transition Plan for approval by the Bureau.[2]
On April 27, 2015, the NAPM LLC filed an initial Transition Plan,[3] on which the Bureau sought comment.[4] Twelve parties filed comments or replies addressing the initial TOP. [5] The commenters asked that the transition process be open and transparent, with Commission oversight, and that the process include all stakeholders, specifically small carriers, consumers, and state regulators. In addition, the commenters asked that the transition process include adequate testing, cost controls, and benchmarks/penalties.
On August 31, 2015, the NAPM LLC refiled its Transition Plan,[6] amending it in response to comments filed and including a new TOEP.[7] According to the NAPM LLC, the revised TOP “describes the oversight structure and methodology, risk management, timelines, performance benchmarks and incentives, dispute resolution, testing, stakeholder outreach and education, and steps to ensure security and reliability.”[8] Later, on October 29, 2015, the NAPM LLC filed an updated TOEP[9] and the NAPM LLC is working with the Transition Oversight Manager to implement that plan. As stated in the Updated TOEP, its objectives are to provide transparency in the LNPA transition, provide an open forum to gather and understand the concerns of interested parties, and incorporate that feedback into the Transition Plan.[10] The Updated TOEP lists as its audiences the following interested parties: large and small service providers, service bureaus and providers of telecommunications-related services, law enforcement agencies, telemarketers, regulators, trade associations, vendors, and consumer groups.[11]
In addition, the Updated TOEP sets forth the various communication and outreach channels to be used by the Transition Oversight Manager, such as webcasts, emails, and surveys, and sets forth the frequency of outreach, the key activities, how these items will be publicized, and the next steps in the transition process.[12] The Transition Oversight Manager has scheduled the first in a series of LNPA transition outreach webcasts to keep interested parties informed about the upcoming LNPA transition, in accordance with the Updated TOEP. The first transition outreach webcast is scheduled for December 9, 2015, from 3:00-4:00 pm, Eastern Standard Time. Interested parties may register for the webcast by visiting: https://event.webcasts.com/starthere.jsp?ei=1084375.
The Bureau has reviewed the NAPM LLC’s revised Transition Plan, as well as the Updated TOEP. Based on that review, we conclude that those plans outline reasonable steps that the NAPM LLC will take in the transition to a new LNPA, including the involvement of interested stakeholders in that transition. We therefore approve the re-filed August 31 Transition Oversight Plan, including the updated October 29 Transition Outreach and Education Plan. The NAPM LLC notes that it will update the TOP, as appropriate, and will publish any updates on the public portion of the NAPM LLC’s website as changes to the TOP are made.[13] The Bureau requires that the NAPM LLC file any such updates in the above-referenced dockets.
Ex Parte Presentations. This proceeding shall continue to be treated as a “permit-but-disclose” proceeding in accordance with the Commission’s ex parte rules and other relevant Bureau guidance. In a Public Notice released on August 18, 2015, the Bureau modified the applicability of the Commission’s ex parte rules to this proceeding in certain respects.[14] As further explained in that Public Notice, the Bureau determined that “the critical public safety and national security issues and the importance of a seamless and timely transition” justified modifications to the ex parte rule treatment of communications and meetings related to certain issues being addressed in this proceeding, including “the transition of the LNPA and related stakeholder outreach, education, and database testing” issues.[15] Consequently, parties should consult the LNPA Ex Parte Status PN to determine if planned ex parte presentations are subject to the modified procedures discussed therein, or the Commission’s standard ex parte rules. Parties should be aware that, to the extent that they make presentations to (i) Commission decision makers, (ii) the NAPM LLC, or (iii) the Transition Oversight Manager, beyond the subjects specified in the LNPA Ex Parte Status PN, the Commission’s filing requirements for “permit-but-disclose” proceedings under section 1.1206 of the Commission’s rules apply.
Persons making ex parte presentations must file a copy of any written presentation or a memorandum summarizing any oral presentation within two business days after the presentation (unless a different deadline applicable to the Sunshine period applies). Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation must (1) list all persons attending or otherwise participating in the meeting at which the ex parte presentation was made, and (2) summarize all data presented and arguments made during the presentation. If the presentation consisted in whole or in part of the presentation of data or arguments already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or other filings (specifying the relevant page and/or paragraph numbers where such data or arguments can be found) in lieu of summarizing them in the memorandum. Documents shown or given to Commission staff during ex parte meetings are deemed to be written ex parte presentations and must be filed consistent with rule 1.1206(b). In proceedings governed by rule 1.49(f) or for which the Commission has made available a method of electronic filing, written ex parte presentations and memoranda summarizing oral ex parte presentations, and all attachments thereto, must be filed through the electronic comment filing system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, searchable .pdf). Participants in this proceeding should familiarize themselves with the Commission’s ex parte rules.
For further information, contact Michelle Sclater or Marilyn Jones, Competition Policy Division, Wireline Competition Bureau at (202) 418-0388 (Michelle) or Michelle.Sclater@fcc.gov, or (202) 418-2357 (Marilyn) or Marilyn.Jones@fcc.gov.
– FCC –
[1] Telcordia Technologies, Inc. Petition to Reform Amendment 57 and to Order a Competitive Bidding Process for Number Portability Administration et al., WC Docket No. 07-149 et al., Order, 30 FCC Rcd 3082 (2015).
[2] Id. at paras. 158-59.
[3] Letter from Todd D. Daubert, Counsel to the NAPM LLC, to Marlene H. Dortch, Secretary, FCC, WC Docket Nos. 07-149 and 09-109, CC Docket No. 95-116, Attach. (filed Apr. 27, 2015).
[4] Wireline Competition Bureau Seeks Comment on the North American Portability Management LLC’s Transition Oversight Plan for Local Number Portability Administrator Contract, WC Docket Nos. 07-149 and 09-109, CC Docket No. 95-116, Public Notice, 30 FCC Rcd 4646 (Wireline Comp. Bur. 2015).
[5] The following parties filed comments and/or reply comments on the initial TOP: Nebraska Public Service Commission (Comments); NTCA—The Rural Broadband Association (Comments); John Staurulakis, Inc. (Comments); LNP Alliance (Comments and Reply); Competitive Carriers Association (CCA) (Comments); COMPTEL (Reply); NARUC (Reply); Telcordia Technologies, Inc. d/b/a iconectiv (Reply); Syniverse Technology (Reply); CCA, Open Technology Institute at New America, and Public Knowledge (Joint Reply); ITTA—The Voice of Mid-Size Communications Carriers (Reply); and Neustar, Inc. (Reply).
[6] Letter from Todd D. Daubert, Counsel to the NAPM LLC, to Marlene H. Dortch, Secretary, FCC, WC Docket Nos. 07-149 and 09-109, CC Docket No. 95-116 (filed Aug. 31, 2015) (Updated TOP).
[7] Updated TOP, Attach. 5.
[8] Updated TOP at 1.
[9] Letter from Todd D. Daubert, Counsel to the NAPM LLC, to Marlene H. Dortch, Secretary, FCC, WC Docket Nos. 07-149 and 09-109, CC Docket No. 95-116 (filed Oct. 29, 2015) (Updated TOEP).
[10] Id. at 2.
[11] Id. at 3.
[12] Id. at 4-6, 8.
[13] NAPM LLC, LNPA Transition Reference Documents, https://www.napmllc.org/pages/npacrfp/npacRFP_RefDocs.aspx (last visited Nov. 25, 2015).
[14] Notice Concerning Ex Parte Status of Communications with Respect to the Local Number Portability Administrator Selection Proceeding, WC Docket Nos. 07-149 and 09-109, CC Docket No. 95-116, Public Notice, 30 FCC Rcd 8425 (Wireline Comp. Bur. 2015) (LNPA Ex Parte Status PN).
[15] Id. at 8426.
The Night Shift Before Christmas
Listen to the Podcast on SoundCloud
Each year for the past few years I have been taking this poem written by Mike Perkins of Application Data Systems, Inc. and posting it.
This year I decided to record an audio version of this and post for all of my friends in Public Safety to share. These folks put everyone else first, and save thousands of lives every day. Thank you for all you do. Have a great holiday season.
‘Twas the night before Christmas, as she sat all alone,
In a room made secure, full of consoles and phones.
I had come down the chimney with presents to give
And to see just which hero in this center did live.
I looked all around and what did I see?
No tinsel, no presents, just a very small tree.
No stockings by a fire, just switchboards & mics,
And a few small photos of her kids riding bikes.
Amongst medals, and badges, awards of all kinds
A sobering thought crept into my mind,
For this room was different, so busy and bright:
T’was the 911 office, and a dispatcher on “nights.”
I’d heard stories about them and wanted to know more,
So I walked down the hall, and pushed on the door.
And there she sat with keyboards and mouse,
Waiting to set tones on a well roasting house.
Her face O’ so gentle, her room was abuzz,
It occurred to me then that she needed a hug.
Was this the hero of whom I’d read?
Sitting at a console making her bread?
Though my stress was high, hers seemed to be zero
And I soon understood this was more than a hero
For I realized the families that I saw just that night
Owed their lives to this servant who was willing to fight
Soon ‘round the world, the children would play,
And grownups would celebrate a new Christmas day.
They all enjoyed freedom each day of the year,
Because of dispatchers like her standing so near
I couldn’t help wonder how many there were
On a cold Christmas Eve working hard like her.
Just the very thought brought a tear to my eye,
I eased up beside her my heart full of pride.
The dispatcher said, as she saw my tears falling,
“Santa don’t worry, this life is my calling;
I am the watcher: a lone, steady voice,
Getting help to the helpless: my job and my choice.
With a wink and a smile she answered a call,
An elderly man who’d been hurt in a fall.
I watched her intently, so alert, and so quick,
And I saw a slight shiver as she made a mouse click.
So I took off my jacket, thick, fluffy and red,
And I covered her shoulders, her neck, and her head.
I put on her sweater, which was smaller and tight,
The two of us there must’ve been quite a sight!
Though her sweater hardly fit me, my heart swelled with pride,
And for a fleeting moment I felt a kinship inside.
I didn’t want to leave her on that cold dark night,
This guardian of honor so ready to fight.
But she kissed my cheek, and in a voice so pure,
Said, “Carry on Santa. Christmas Day is secure.”
One look at my watch, and I knew she was right.
Merry Christmas my friend, as you watch through the night.
This poem was written by Mike Perkins of Application Data Systems Inc. as a salute to 9-1-1 dispatchers nationwide. It was adapted from “Soldiers Night Before Christmas.”
We would like to salute the unsung heroes who simply say “not on my watch,” the Dispatchers of America. You listen to the callers who may be having the worst day of their lives. You listen to Law Enforcement who has to sort out the un-sortable. You help Firemen find the unseen voice. You help EMS get to a family member who is very ill. Without you we cannot imagine what would happen.
THANK YOU AND MERRY CHRISTMAS!
911 Awareness Means Tragedy Averted
This story just never seems to end. . .
It’s said that “lightning never strikes twice.” This is, of course, a statistical assumption and is often disputed by scientists, who note that large attractors of an electrical discharge, such as the Empire State Building in New York City, are actually struck hundreds of times per year. This is due to an outside influence skewing the law of averages.
The same is true with E911. Outside influences can mathematically skew the statistics, and, in this case, the No. 1 influencer is awareness. Take the tragic murder of Kari Hunt in Dec. 2013.
While visiting her estranged husband in a Marshall, Texas hotel room for visitation with their children, Kari was attacked and brutally stabbed dozens of times, while her 9-year-old daughter desperately tried to call 911. Her daughter couldn’t get through because the type of phone line she was using first required the caller to dial a number to reach an outside line.
As a result of the tragedy, Kari’s father, Hank, became an advocate for better, safer technology. Over months of work evangelizing Kari’s Law, which requires direct 911 dialing from multiline telephone systems where, in the past, you would have had to dial another number first to get an outside line, Hank has become educated and aware to a level well above the general public.
Awareness, has likely prevented lightning from striking, again.
How you ask? Hank oversees facilities maintenance at a nursing home in Texas. After Kari’s death, he checked the MLTS PBX that provided service to the staff and residents, and − sure enough − it also didn’t allow calls to 911 directly. A quick service call to his local vendor, and the problem was corrected. After learning why the change needed to be made, the local vendor tore up the bill for the service call too.
Recently, that system was upgraded to a new system, and as the resident 911 expert, Hank wanted to make sure there was direct access to 911 still. He called the local police on their administrative lines and got permission to test 911. He then picked up a phone, dialed 911 and, to his delight it, was greeted with “911, what is the address of your emergency?”
This is where most people, including telephone installers, would have said “This is just a test. Thank you very much,” and hung up. Test complete. All okay, right?
Wrong! Hank knew there may be other issues, particularly with the Automatic Location Information (ALI) that provides 911 call takers with location information.
He asked the call taker what they saw for his address and then found out something that terrified him. The call taker had no idea where he was located!
Wait a second . . . just who IS this, and where are you?
Hank queried the call taker further, and it became clear that the person was not local to the area. In fact, the call taker was not even in the United States! The person who answered his call was located at what is known as an Emergency Call Routing Center (ECRC), operated by a company called Northern 911, located in Canada.
He immediately called his telephone vendor and advised them of the issue. They made a change and told him to test again. When he did, the call went to the county 911 center and not the local police department where 911 should have been answered. Hank called again for service and was told, this time around, he would have to call the 911 folks to fix the routing issue. You can imagine his response to that, and to make a long story short, the calls are now routed correctly.
What is going on here? We need to take a few steps back.
What is going on? Why does it seem like 911 is broken all of a sudden? Why are Texas calls going to Canada? Who is responsible for fixing this? In fact, it appears that this is not an isolated incident. It may actually be a systemic problem.
Lisa Hoffman, ENP, just recently posted a guest blog on this very issue after a 911 call on behalf of a high school student who had collapsed was routed of California to an ECRC in Canada. Dispatch was delayed by the confusion, and the student died.
So why does this happen? Certain conditions, like incorrectly provisioned VoIP systems or PBX lines, block the system from processing the calls. In that case, the 911 calls can’t be correctly routed and are sent to an ECRC.
Does this mean E911 is broken?
Fortunately for all of us, no it doesn’t. The issues that arise causing this ECRC routing to happen are typically due to the improper use of services, or caused by those using these services, originally designed to be failsafe backups, as a primary resource for calls, making the wrong assumption that they should just get the call to the ECRC, and let them sort it all out. Not a good idea, and it is fraught with delays and, yes, an additional expense of hundreds of dollars.
The good news is that everyone can be an advocate to fix this, just like Hank. While we wait for more widespread adoption of E911 and NG911 technologies, I urge you to become more knowledgeable and spread awareness about 9-1-1 safety in your organization. Ask your vendor to perform a 9-1-1 check up on your telephone system. Many will do this for free for their customers. Also, when you test, make sure that you schedule ahead of time with the emergency center, and make sure that when you call, you not only reach 911, but also reach theright 911 center. Ultimately, the more awareness we raise, the less often lightning will strike for this particular reason.
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.
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”.
THE PLAN
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!
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.
