Public Knowledge Notes Privacy Issues as FCC Considers New 911 Rules
Public Knowledge urged the FCC to safeguard consumers' privacy as it considers rules for next-generation 911, the group said this week in comments on a Further NPRM that commissioners approved in March. Most comments called for the FCC to move with caution as it considers updated rules (see 2508050042).
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Public Knowledge supports the FCC’s goals of making NG911 “more reliable and useful for consumers who require emergency services in critical times of need,” said a filing in docket 21-479. “However, these services do not come without risks.” The group “urges the Commission to prioritize the protection of consumer information and related sensitive data that is transmitted through the use of NG911 services as it considers enhancing NG911 networks.” It added that as the use of NG911 increases, “the risks of the misuse and exposure of sensitive consumer information grow in tandem.”
Companies that provide 911 services also advised the FCC to take its time to get the rules right. Intrado said it’s “premature to promulgate the full breadth of the Commission’s proposals as rules at this early stage of implementing the recently adopted NG911 Transition Order.” Questions remain “about how commonly accepted standards will be interpreted and applied and what this means for service functions and configurations,” Intrado said.
Comtech Telecommunications said the FCC should “carefully refresh the record” before adopting new or revised rules. The company noted that NG911 has changed considerably since the agency first adopted rules in 2013 and last sought comment in 2018. “Ultimately, any rules adopted by the Commission should be based on current technical realities, stakeholder experience and deployment data.”
The Alarm Industry Communications Committee said the FCC shouldn’t permit direct transmission of automated alerts from a variety of networked devices to public safety answering points without screening. It cited alarm systems, security cameras and mobile applications. “These types of messages are vulnerable to false alarms, system malfunctions, repetitive signaling, and spoofing, and may continue transmitting until manually terminated by the user,” the committee said. “This dynamic would re-create the massive problem caused by ‘auto-dialer’ technology decades ago, when phones were capable of automatically dialing 911.”
Groups representing deaf and hard-of-hearing people emphasized the importance of direct video calling as an option for those who rely on American Sign Language (see 2507290041). It's key “to incorporate this access now, while the transition to Internet protocol services is taking place, rather than later, when retrofitting the nation’s NG911 system will be expensive, burdensome and less effective,” said a filing by Communication Service for the Deaf, Deaf Equality, TDIforAccess, the Hearing Loss Association of America, the National Association of the Deaf and others.
The Alliance for Telecommunications Industry Solutions agreed with other industry commenters that the FCC should limit the definition of "covered service provider" to entities that have a direct relationship with 911 authorities. ATIS also cautioned the agency against ruling that rich communications services (RCS) should be considered a “commonly accepted standard” under the rules. The group doesn’t “believe that RCS is currently a commonly accepted standard because RCS has not been widely or consistently implemented in the U.S. and is not currently considered as part of ATIS’ or [the National Emergency Number Association’s] NG911 standards.” It also argued that there has been little interoperability testing for RCS so far (see 2506170071).