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Multistate 911 outage could lead to changes in emergency-calling regulations, operations
[October 31, 2014]

Multistate 911 outage could lead to changes in emergency-calling regulations, operations


(Urgent Communications Via Acquire Media NewsEdge) Last week, the FCC heard a presentation detailing the issues leading to the massive 911 outage that resulted in more than 6,600 emergency calls never reaching a public-safety answering point (PSAP) for up to six hours on April 9-10. The outage affected 81 PSAPs, including all PSAPs in the state of Washington and those in parts of six other states.



The root cause of the problem was software code at the Intrado data center in Englewood, Colo., included an “arbitrary”—according to one FCC official—counter cap for Intrado’s carrier customers. When the number of 911 calls to the data center exceeded the cap, the data center stopped routing the calls to PSAPs, leaving thousands of emergency callers unable to access help from first responders. Eventually, 911 calls to the Englewood, Colo., data center were rerouted through Intrado’s data center in Miami, but this was not done until several hours of emergency calls were unanswered.

Fortunately—and almost amazingly—no one died because of the outage, but there were some harrowing anecdotes. For instance, one woman called 911 several times in vain because her mother—recently released from the hospital after undergoing surgery—fainted several times. The woman ultimately called a hospital directly and was able to get an ambulance dispatched.


Of course, this isn’t how it is supposed to work; a call to 911 is supposed to be answered promptly, and the proper emergency resources are supposed to be dispatched quickly to the scene. FCC commissioners were outspoken in their criticism of the situation, with words like “terrifying,” “unacceptable,” “totally inadequate,” and “preventable” highlighting the discussion.

Among those that testified before the FCC was David Danner, chairman of the Washington Utilities and Transportation Commission—the regulatory body that oversees 911 service in the state—who described 911 as “literally a lifeline” that U.S. residents depend upon to work reliably in times of emergencies.

“It’s imperative that we minimize the frequency and duration of 911 outages, that we ensure that we have sufficient redundancy built into these systems, that we maintain accurate ALI databases, and that we ensure that companies provide timely communication both with state agencies and the public when 911 services go down,” Danner said.

“This outage and others shine a light on the need to continually assess—and reassess—the architecture of next-generation 911 systems, which are increasingly interstate in nature, and we must identify and address any gaps in the regulation of 911 that may result from the transition to an IP-based system. I think the best way to do that is to establish an ongoing dialog and collaboration between the FCC and the states.” While Danner’s statements about the need for 911 to be reliable certainly ring true, his description of this problem being “interstate in nature” may prove to be more significant from a regulatory perspective, because this outage—as well as similar “sunny day” 911 outages being investigated in four other states—may compel the federal government to become more involved in 911 oversight.

Multistate 911 outage could lead to changes in emergency-calling regulations, operationsHistorically, 911 regulation and operation have been focused at the state and local levels, which made sense. After all, the locations of selective routers serving a given PSAP was known and in relatively close proximity to the 911 center, and the carriers providing the connectivity were used to dealing with state commissions.

But each state and local jurisdiction has access to different resources, and politics play a large role in determining how 911 service is prioritized. As a result, while PSAPs in some states are well down the path to next-generation 911 that can support multimedia interaction with citizen, others have not yet been upgraded to support wireless 911 calls.

“We have a national system, but it is not nationwide,” George Rice said during an interview with IWCE’s Urgent Communications. “The only thing that’s national [about 911] is the number.” When IP-based connectivity was introduced into 911 systems, there were many who argued that the FCC and the federal government should have bigger roles in the regulation of 911, because IP technology is inherently interstate—key network elements can be located anywhere and function properly, if appropriate connectivity exists.

Although this made for good legal debates, there really was no compelling reason for the FCC and the federal government to be significantly more active in 911 regulation, because the states seemed to have the necessary authority to keep systems running well.

But the massive April outage underlined a problem state regulators just can’t address.

What authority does a regulator in Washington State—like Danner—have over a private third-party vendor in Colorado—like Intrado—that works for a carrier providing 911 connectivity and that controls key components of the 911 system that the regulator must ensure works reliably? “They had a state PUC commissioner speaking before a federal agency declare that this is interstate in nature—and anything interstate in nature typically falls under the domain and jurisdiction of the FCC or the federal government,” Brian Fontes, CEO of the National Emergency Number Association (NENA), said during an interview with IWCE’s Urgent Communications. “911 per se is not regulated at the federal level, but the communication links by third parties and telecommunications companies 911 service—in part—are regulated by federal agencies.

“States and their state PUCs recognize that they themselves may not have authority over a third-party vendor who operates in another state but whose system affects the service in the state of a PUC commissioner. So, there needs to be some sort of overall federal nature to all of this.” Now, the PSAPs affected in the April outage were using the legacy 911 system at the endpoints—all had Centralized Automatic Message Accounting (CAMA) trunks, according to the FCC report—but the routing functions were done over an IP system. In a next-generation 911 system, which is based on an all-IP architecture, much more than routing functions could be impacted, as a next-gene 911 system is designed to access and leverage all sorts of databases in myriad locations to provide relevant information to first responders.

Given this reality, Fontes said he believes it is time for federal government to become more involved in the regulation of 911—and in its funding mechanisms—to help ensure that the level of 911 service is available throughout the country, as opposed to having significantly different technological capabilities in various locations.

“It’s time that political leaders at the federal, state and local levels recognize that 911—and, subsequently, next-generation 911—is a critical-infrastructure element,” Fontes said. “We look at the energy grids—electric, gas, water, etc.—as all part of critical infrastructure. As such, they have federal attention, coordinated with the states. There’s funding available to ensure that it meets certain standards and requirements.

“I think that 911 should be considered as a critical infrastructure, subject to that type of funding and oversight to ensure that it is operating to certain criteria and maintained so that anyone dialing 911 from anywhere in the country can expect a certain standard quality level of accessing emergency services.” Multistate 911 outage could lead to changes in emergency-calling regulations, operationsIt will be interesting to see what actions the FCC will take in this matter. Will it make the carrier responsible for ensuring that 911 calls get to PSAPs, putting the burden of due diligence on the carriers to determine that its third-party vendors are sufficiently reliable and has architected its systems in a way that will not result in outages? “The fact that it is outsourced does not mean you get to wash your hands of it,” FCC Chairman Tom Wheeler said during a press conference after last week’s meeting. “That’s the issue that we’re going to be dealing with in the follow-on to that report.” And how much redundancy is enough? David Simpson, chief of the FCC’s public-safety and homeland-security bureau, made it clear that he does not believe that Intrado’s approach of having just two data centers—one in Englewood, Colo., and one in Miami—is appropriate. Simpson said he lived through the 1969 earthquake in San Fernando, Calif., so the notion that that a large seismic shift associated with the San Andreas Fault could create a new island is something he has considered.

“After an earthquake, you want 911 to work,” Simpson said during a press conference following last week’s meeting. “If all of the lines east of the San Andreas Fault are no longer in place, you don’t want 911 capabilities in and around the Los Angeles metropolitan area to no longer work. So, I do think we need something better than a concentration of capabilities in one or two locations around the entire United States, because they just might not be there when you lay on top of these sunny-day [issues]—stuff breaks—real-world disasters.

“Miami is kind of prone to hurricanes. Had a hurricane come at the same time [as the multi-state outage], we would not have had that failover, perhaps. So I think there needs to be more [distribution of 911 capabilities].” Even if policies regarding how various components of 911 should work, who will do the massive amount of legwork to make sure that the policies are being followed? Initially, the easiest thing to do probably is to put this burden on the carrier, but it is questionable how much assurance that provides the public calling 911. After all, both the carrier and the third-party vendor have incentives to keep costs low and hassles to a minimum, so it might be tempting to cut corners to save both sides money.

Even if everyone has the best of intentions, how many carriers have the resources to thoroughly investigate the operations of third-party company bidding to provide 911 work—and, do the third-party companies have the manpower to address all the questions asked by a litany of carriers? Multistate 911 outage could lead to changes in emergency-calling regulations, operationsInstead, it might be time to establish some sort of independent certification process that would allow a review of each third-party 911 service provider business operations and practices to ensure that the meet the requirements associated with 911. After meeting all of the requirements, the third-party vendor’s certification would be known publicly, saving individual carriers significant amounts of time in the due-diligence process.

Creating the certification criteria should be a collaborative effort of vendors, carriers, trade associations, PSAP coordinators and government. If such a certification process was established, determining what organization would actually implement it likely could be a topic of lively debate. Whoever does take on the task will need considerable resources, because it promises to be a labor-intensive process.

Conceptually, I can see such a certification process helping ensure that a third-party vendor has sufficient redundancies in place to serve 911 and that the company understands the importance of failover and backup strategies.

What concerns me is whether any kind of certification process would have prevented the massive April outage. Who’s going to look at the lines of software code to make sure this—or something else—doesn’t happen again? Or that software is written correctly, so that calls that need to be rerouted to a backup facility automatically go there, instead of waiting for hours for a manual switchover, which apparently happened in this case? And we haven't even touch upon potential cybersecurity threats to 911, which promise to be an huge issue.

Exactly how the federal government should be involved in 911 is a topic that could be—and should be—debated for some time. But it seems clear that these outages and the migration of 911 to IP-based systems point to the need for federal involvement in an arena that previously has been dominated by state and local regulation.

Such incidents also portend a change in the way that carriers and third-party 911 vendors handle emergency calls. What the FCC eventually proposes in the wake of this report likely will be only the first step, as the FCC, other federal agencies and even Congress likely will have more to say on the matter.

The ultimate results are anybody’s guess, but it is reasonable to expect that carriers and/or third-party vendors will have to invest some time and money into their 911 procedures to ensure that outages like those that happened in April do not happen in the future.

© 2014 Penton Media

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