For most people these days, getting in touch with friends or family might mean sending an email or Facebook message or making a Skype call. But in an emergency, many people still have only one choice: to pick up a phone and call 9-1-1. With its recently released Notice of Inquiry about “Next Generation” (NG) 911, the FCC is looking for ways to bring the 911 system into the 21st century, specifically by enabling connectivity between Internet-based services and the emergency calling infrastructure.
We’re pleased to see the FCC promoting an effective and technologically advanced emergency communications infrastructure. However, as we noted in comments submitted to the Commission yesterday, there are a number of aspects of the transition to NG911 that require special care. First, the FCC should avoid actions that would discourage developers and providers of new IP-based services from seeking to connect those services into the NG911 system. By setting very high or rigid requirements for services to be able to communicate into the NG911 system, the Commission might inadvertently reduce the ability of future technology users to connect to the emergency system. If the NG911 system has such specific requirements that only a few “new” services can comply, then in 10 or 15 years we may find ourselves right back where we are today – with an outdated emergency system that has been left behind by advancing technology.
Second, the Commission should be concerned about innovation and deployment of non-emergency technology, and thus should seek to avoid imposing emergency-focused mandates that have the result of hindering the development of valuable non-emergency technology. Requiring every single Internet-connected device to be able to interface with the 911 system, for example, would very likely have the result of discouraging the creation of some new, innovative communications devices in the first place. The Commission should be sensitive to not chill the development of such devices.
Finally, it is vital that the Commission be cautious to ensure that users maintain control over their private information, and that the NG911 system (and technology deployed to support the system) not be allowed to reduce user control over information about themselves or their location. The NG911 system presents promising opportunities to have relevant medical information shared with emergency responders and geographic location information has always been central to the 911 system. The transition to an IP-based communications infrastructure should provide emergency callers with more control over this information, not less.
In a separate set of comments submitted with two fellow current and former chairs of the Internet Engineering Task Force (IETF) GEOPRIV and ECRIT working groups, I and my co-authors emphasized the value and broad applicability of IETF standards that have been developed for the specific purposes of enabling IP-based emergency services. The ECRIT working group has developed a general architecture for enabling IP applications to discover and connect to emergency services. The GEOPRIV working group has developed protocols that allow IP networks to inform end devices about their geolocation in a privacy protective manner. By leveraging these existing standards, NG911 systems can ensure that they will be widely available to Internet-connected devices and applications of all kinds.
In his addendum to the NOI, FCC Chairman Julius Genachowski noted that with modern phones, “you can pretty much text anyone except a 9-1-1 call center.” We are hopeful that by supporting privacy-protective emergency services based on open technical standards, without mandating stringent requirements or highly specific approaches, the FCC will help us all see the day when we can reach an emergency responder via email, Facebook, Skype, or whatever the next great communications invention might be.