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911 Access

Call 911: emergency service industry trailing behind the IP transition

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Because emergency service is the most critical consumer protection issue in the IP Transition, it is important that individual and enterprise end users also be engaged in the IP Transition.

The telecom industry is buzzing about the FCC’s “IP transition.” As the government contemplates the best way to overhaul an outdated regulatory model for new communications services, it is imperative that the emergency services segment of the industry do the same. Because emergency service is the most critical consumer protection issue in the IP Transition, it is important that individual and enterprise end users also be engaged in the IP Transition.

When we evaluate the evolution of the communications industry’s shift toward the ubiquitous adoption of Internet Protocol (IP) technologies, it quickly becomes apparent how far behind 911 services are relative to the rest of the telecom industry. The oft-cited problem that text and other IP-enabled data services are not able to interact with the emergency services network clearly demonstrates this disconnect.

The industry’s 911 infrastructure has grown up around assumptions premised upon a fixed-line TDM-based phone. That model is no longer sustainable. 911 callers are now predominately using mobile services that rely upon CMRS (Commercial Mobile Radio Services) or IP-enabled networks and devices. As we consider the next steps required to update 911 infrastructure, we must be keenly aware of how IP technology has already triggered major changes to the PSTN. Regulators should think about 911 reforms in terms of a clear path toward a successful overhaul of the system that includes near-term needs along the way. Driving the ubiquitous adoption of NG 911 networks is the ultimate target. To forge this path, however, clear and courageous leadership will be required.

Addressing Text to 911 for OTT providers

Realizing the promise of NG911, with which public safety agencies gain access to a variety of IP-based data sets to assist with emergency response, starts with solving how people can use text to access 911 services via IP-based communications as provided by the emerging array of Over-the-Top (OTT) texting providers. Implementing the ability to deliver IP-enabled OTT 911 texts to the correct public safety answering point (PSAP) would be a watershed achievement that creates the base from which other NG911 capabilities will flow. (Though PSAP readiness to handle this traffic clearly is lacking today.)

To support OTT text-to-911, some suggest that OTT text providers default to an underlying Commercial Mobile Radio Service (CMRS) carrier’s text-to-911 capabilities. Limitations to such an approach include a dependence upon the availability of a CMRS network as more and more end users roam and adopt WiFi-only services, as well as end-user confusion. Placing an additional burden on the current capabilities of existing CMRS carriers while limiting the range of communications devices that can support text-to-911 for OTT applications is less likely to prod the industry toward NG911 than an approach that embraces IP-enabled OTT services and IP technologies more fully.

The transition to an NG911 infrastructure will be anything but simple, but certain developments are in fact beginning to show promise. For example, in the OTT text-to-911 space, by combining available data networks with application-derived location capture, a higher quality and more progressive solution becomes possible. Capturing location capabilities from IP-enabled commercial services yields a text-to-911 method that is more robust and technologically sound. It will also reduce requirements on end users and devices supporting OTT texting. Because this method doesn’t require dependence upon CMRS services or the CMRS carrier’s location determination equipment, it can avoid the challenges associated with roaming.

Another critical benefit is that development efforts for OTT application providers should also be in-line with development required to support NG 911. Finally, an IP-based OTT solution provides the most flexibility within the marketplace by offering availability across the broadest range of underlying communications devices.


As people increasingly rely on their IP-enabled communications services as a lifeline in emergencies, it is the entire industry’s responsibility to ensure that widespread technological developments also include progressive and innovative 911 solutions. The limitations inherent in the existing infrastructure create difficult complexities that have caused the 911 community to fall behind the consumer marketplace.

We must work aggressively to close this gap as quickly as possible. Continuity along the way is critical, but we must avoid fearfully clinging to the past if we are to achieve the promise of advancing emergency services for the future. Now is the time to begin the process toward a far more robust emergency response system that will be there to help end users in need for decades to come.