Federal Communications Commission fcc 13-158 Before the Federal Communications Commission
VIII.Background A.911 Network Architecture
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VIII.BackgroundA.911 Network ArchitectureIX.The primary function of the 911 network is to route emergency calls to the geographically appropriate PSAP based on the caller’s location.1 When a caller dials 911 on a wireline telephone, the call goes to the local switch serving that caller, as is typical with any other call. The local switch then sends the call to an aggregation point called a selective router, which uses the caller’s phone number and address to determine the appropriate PSAP to which the call should be sent.2 Calls to 911 from wireless phones flow through a switch called a mobile switching center before reaching the selective router. For wireless calls, the sector of the cell tower serving the call provides the approximate location of the caller and is used to determine to which PSAP the call is sent. To complete the call, a connection is set up between the selective router and the appropriate PSAP, typically through a central office serving that PSAP. X.Once a 911 call reaches the appropriate PSAP, the PSAP queries an automatic location information (ALI) database to determine the location of the caller.3 For wireline calls, ALI is based on the address associated with the caller’s phone number. For wireless calls, providers use various technologies to determine the caller’s location. Because ALI is passed to the PSAP along a different path than the one carrying 911 calls, it is possible for a PSAP to lose ALI links without losing 911 service completely. XI.The 911 network architecture described above is evolving from a circuit-switched network to a Next Generation 911 (NG911) network based on Internet protocol (IP) technology. As the Bureau observed in the Derecho Report, NG911 networks “offer[] certain advantages over legacy technologies, including greater redundancy and reliability, the ability to provide more useful information for first responders, wider public accessibility (including to those with disabilities), and enhanced capabilities for sharing data and resources among emergency responders.”4 As described in more detail below, we intend today’s rules to apply to current 911 networks, as well as NG911 networks to the extent they provide functionally equivalent capabilities to PSAPs. Nevertheless, we undertake to review these rules in five years to make any changes that may be necessary in light of our subsequent experience and future developments with respect to the NG911 transition.5
XIII.The Commission’s mandatory Network Outage Reporting System (NORS) 8 and voluntary Disaster Information Reporting System (DIRS) 9 provide outage data that help gauge whether best practices have been implemented in certain circumstances or service areas, but the Commission has not required service providers to implement these practices. From time to time, however, the Bureau has publicly reminded 911 service providers of the importance of following industry-developed best practices in light of outage trends suggesting to the Bureau that they have not been implemented adequately.10 The Bureau also works with service providers on an informal basis to identify and resolve communications reliability issues revealed through the outage reporting process. XIV.In 2006, the Commission established the Independent Panel Reviewing the Impact of Hurricane Katrina on Communications Networks (Katrina Panel) to make recommendations to the Commission regarding ways to improve disaster preparedness, network reliability and communications among first responders.11 In 2007, acting on the findings of the Katrina Panel, the Commission adopted rules requiring certain communications providers to maintain minimum levels of backup power for central offices, cell sites, and other network assets.12 Another rule adopted in the Katrina Panel Order, requiring local exchange carriers, wireless service providers subject to 911 requirements, and interconnected VoIP service providers “to conduct an analysis of the resiliency and reliability of their 911 networks or systems and to submit a report to the Commission,”13 was implemented by the Bureau in 2009 when it requested general information from service providers about 911 architecture in the United States. As we noted in the 911 Reliability NPRM, however, these reports proved of limited use, lacking the specificity necessary to determine network reliability in individual cases.14 XV.In 2011, the Commission released a Notice of Inquiry (Reliability NOI) in PS Docket No. 11-60, which sought comment on the reliability, resiliency, and continuity of our nation’s communications networks, including broadband technologies.15 Among other topics, the NOI inquired about “the ability of communications networks to provide continuity of service during major emergencies, such as large-scale natural and man-made disasters.”16 The Commission emphasized that “[p]eople dialing 911, whether using legacy or broadband-based networks, must be able to reach emergency personnel for assistance.”17 XVI.Service providers responding to the Reliability NOI assured the Commission that they had infrastructure and plans in place to maintain continuity of communications in the event of severe weather, loss of commercial power, and other emergency conditions. The United States Telecom Association (U.S. Telecom), for example, commented that its members “have voluntarily spent hundreds of millions of dollars and countless hours preparing for disaster recovery in order to support continued quality service to their customers, even during emergencies.”18 Similarly, Verizon asserted that its “legacy voice, wireless, and broadband networks have significant redundancy and other protective measures in place to keep the networks up or to quickly restore them during disasters and severe overloads.”19 Accordingly, service providers urged the Commission to continue promoting voluntary best practices in lieu of regulatory obligations regarding circuit diversity, backup power, and other aspects of network reliability.20
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