roundtable: Re: Action Alert-911 Access

roundtable: Re: Action Alert/911 Access

Re: Action Alert/911 Access

Doug Reuben (dreuben@interpage.net)
Sun, 8 Jan 1995 05:17:14 -0500 (EST) 

Message-Id: <m0rQugV-000MwOC@interpage.net>
From: dreuben@interpage.net (Doug Reuben)
Subject: Re: Action Alert/911 Access
To: roundtable@cni.org
Date: Sun, 8 Jan 1995 05:17:14 -0500 (EST)


Recently,  Jim Conran <jconran@watson.policy.net> wrote:
>  
> The Federal Communications Commission (FCC) issued a Notice of Proposed
> Rulemaking (Notice)(Docket Number 94-102) on October 19, 1994 in the
> Matter of Revising the FCC Rules to ensure Compatibility with Enhanced 911
> Systems. [...] The proposed rulemaking requires wireless carriers to
> provide this service only to "service initialized" users or users that
> purchase their cellular phones from a wireless service provider. 


This is an innane idea, probably suggested by some of the more stingy
cellular companies who want to squeeze every dime of airtime out of
customers that they can. They basically don't want people getting a phone
on their commission, dropping service after the minimum service period,
and as a result gaining an essentially free (or close to it) phone which
they can always call emergency services with "just in case" and not have
to ever pay a monthly charge. 

This ruling is also contradictory (I suspect) with the FCCs "roaming
operator" regs. which seem to require carriers to allow non-validated
roamers to place credit card or calling card calls while roaming on a
system. Typically, this is encountered when a roamer enters a non-home
service area where there is no service on the same "side" (A/B) as the
roamer's home serive provider, and thus he/she is forced to switch to 
the other side to place calls through the roaming operator. Since all 
calls are placed and paid for by use of a credit card or calling card, 
there is no need to validate a given user. (I've used the roaming 
operator on phones with totally invalid ESN/MIN combos, such as a MIN 
with 312-000-1212, and it worked fine.)

Does this new FCC proposal take this into consideration at all?

> This proposed arcane requirement is quite contradictory to the FCC's
> ultimate objective of providing "broad accessibility" to 911 services.
> Cellular users will have the expectation that when they use their phone to
> contact 911 during an emergency, they will have immediate contact with the
> operator.  Consumers will not think to question the reliability of their
> cellular phone or the wireless service providers, instead public
> confidence on the 911 emergency system will be jeopardize. 

Indeed...one of the main reasons I tell people NOT to lock out the 
"other side" from their phones is that if they ARE in a dead spot with, 
for example,the "A" carrier, the phone will seek the "B" carrier while 
the "A" carrier signal is too weak, and thus a call to 911 will then go 
through.  If a phone IS locked to one's preferred "side", and they 
encounter a dead spot, it will at best take them some time to switch 
sides (if they know how to do so), and at worst be tragic if they are 
unable to report an emergency in time.

> The Alliance for Public Access to 911 (Alliance) believes that in order
> for the FCC's proposed rulemaking on the "broad availability of 911 and
> enhanced 911 services" to be fully recognized, the FCC must require all
> cellular switches to accept all 911 calls.  

Hmmm..."require" all "switches"? Don't you mean "carriers". The switches 
can accept anything, including state police numbers, non-emergency 
numbers for disabled motorists (#77 in MD for example), etc. I think the 
regulations should:

A) Mandate that ALL carriers allow access to 911/*911/etc. services and 
that they can NOT block access to these services for non-validated phones.
They may, however, block access to phones on the STOLEN ESN list (not 
just ESN deny, you can get ESN deny for a lot of reasons other than true 
fraud, and you don't want to prevent people who are erroneously 
placed on the "denied" list [it happens a lot!] from making 911 calls 
while they wait for their carrier to fix the "deny" situation.)

B) Allow local authorities (state DPUCs, etc.) to mandate further codes
which as in "A", state that cellcos MUST allow free and unrestricted 911
access, and which manadate that they are not allowed to block such calls,
except for STOLEN ESN phones. This would allow MD to keep #77, Mass to
keep *MSP, etc. 

(You don't want to create a market for stolen phones: If 911 would work 
even from stolen phones where the actual physical equipment were stolen, 
people would have a reason to take them. By preventing 911 on stolen 
phones, you prevent this from ever becoming a problem, even if it would 
only be a limited problem anyhow.)

> In addition, the FCC should
> require all cellular phones to be equipped to access the strongest
> cellular base station signal when 911 is called.

Just 911? There are a lot of codes which shoulds be allowed, and in some
cases 911 won't even work. How will this work in Canada? Won't the CRTC
have to go along with this change in the AMPS format treats 911 calls? 
I don't think it's a good idea to mess with the AMPS protocol after the 
fact. Cell phones (well, the switches) normally seek the strongest 
signal path when available, so the only important thing here is to make 
switching from A to B easy (ie, have simple codes or mechanisms by which 
a customer can override the "A" only or "B" only settings.)

What you MAY want to do is have the FCC require that user equipment
manufacturers ALLOW 911 calls to go through from a given phone even if 
the SID for a given roaming system is blocked. Frequently, the "A" 
carrier in a given market will block the "B" carrier in the same market 
by blocking out the "B" carrier's SID code when the phone is being 
programmed. So, if a given user encountered a dead spot on the "A" side 
and tried to use the "B" side to place a call, the call would be denied 
by the PHONE, not the switch. As a result, no call is even SENT to the 
switch, and the cell customer is stuck without a way out unless he/she 
knows how to reprogram the phone on the spot (not likely for most 
customers.)

> Finally, the FCC should
> make the 911 provision an issue as it currently reconsiders cellular
> license renewal applications.  The issue of safety and security for all
> Americans is too important an issue to be compromised. 

Indeed...As it is they "overlook" a great deal too many things when 
reconsidering a cellular license; universal 911 access should NOT be 
one of them.

-Doug

Doug Reuben             dreuben@interpage.net             (203) 499 - 5221

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