Proposal for Wireless NSI Calls

1. Proposal for Wireless NSI Calls

2. NSI Phones –The Problem • NSI: Non Service Initialized phones • How does a phone become NSI • New but off plan or not activated • Throw away -- recovery • Given to kids for play • Available for last resort • Inactive GSM phones have one option: Dial 911

3. Some Perspective • 240 million calls to 911 each year • ⅓ wireless =  80 million (2008, FCC) • Estimate: 20 million NSI calls per year TODAY (8%) • Landline – declining; Wireless only users – increasing • 5 five years – Majority of 911 calls will be made from Wireless Phones in the U.S • 1,296 PSAPs are staffed by a single, on-duty dispatcher (NENA, 2003) • Some PSAPs: up to 80% of 9-1-1 calls are non-emergencies • Some report as little as 1% are emergency calls

4. Some Perspective • 911 calls per year? • Washington, DC receives 1.8 million, Los Angeles 5 million, Baltimore, MD 1.7 million • 5,000 per day DC & Baltimore; 14,000 per day Los Angeles • Non-Emergency: 80% • DC & Baltimore = 4,000 per day (1.4 M yr.) LA 11,000 = per day (4 M yr.) • NSI Calls = 8% • DC & Baltimore = 320 per day (116k yr.) LA 880 = per day (320k yr.)

5. FCC Notice of Inquiry • Requested by NENA and other public safety organizations • FCC responded promptly • Sought input on extent of problem of fraudulent 911 calls, resources wasted to handle, efficacy of blocking technologies, carrier liability issues and alternative solutions.

6. The Need for Immediate NSI Relief • All PSAP commenters document that the vast majority of NSI PSAP calls are inappropriate non-emergency or pranks • Diversion of PSAP resources to handle these calls • Frustration of PSAP staff in having to deal with non-emergency matters

7. The Need for Immediate ReliefCompelling & Alarming • King County Washington: • 86% of NSI calls “inappropriate” • i.e. misdials, hang-ups, harassment & non-emergency • Indiana Wireless 911 • 90% NSI “inappropriate” • 97% NSI repeat callers • State of Maryland Emergency Board • County-wide bogus NSI calls ranged up to 100% of all NSI calls (Worcester County) • Comments unanimously documented the magnitude and urgency of the problem

8. FCC and Commenters Suggested Approaches • Educational initiatives • Denial of all NSI access to PSAPs • Blocking calls at request of PSAP • Requiring all NSI phones to have a call-back feature to trace calls

9. Educational initiativesThe Good Samaritan Approach • Once consumers understand they’ll stop • 60% NSI calls & 74% abusive repeat calls made by children (presumably unsupervised) • Adults – nearly all are malevolent • Education is a long & expensive process • DTV conversion process – many months and millions of dollars • Shaming people doesn’t work and won’t reach kids, who perpetrate most bogus calls

10. Denial of all NSI access to PSAPs • They’re NSI so just deny access • After the abusive calls, the remainder were legitimate • Unconscionable to deny use of NSIs for legitimate calls for help • May not be another legitimate means of calling for help • Cannot square with the Public Interest

11. Blocking calls at request of PSAP • PSAPs still need to screen to determine repeat abusers • Requires populating information fields in phone • Prevents use of blocked phone in genuine emergency

12. Requiring Callback on All NSI Phones • Disenfranchises vast universe of older phones without this capability • Precludes use in real emergency

13. Establish a National Register of Offending Phones • PSAP must receive and analyze multiple abusive 9-1-1 phone calls

14. ARN Proposal • Advantages • Intercepts EVERY NSI call • Regardless of origin • Consistently abusive phones, AND • Repeat abusers switching equipment and locations • Quickly determine legitimacy of most calls • Promptly route call • PSAP or some other non-emergency source of information

15. ARN NSI Proposal • We can ALL make mistakes in judgment • Gives NSI chance to think it over

16. Or Avoid a Mistake http://www.911dispatch.com/911/911_misdials.html

17. ARN Proposal • And allow us to trust the real calls

18. ARN Proposal for NSI • NSI call filter to give caller a choice • 2 Models • Interactive Voice Response (IVR) – DTMF or Voice Recognition • Operator Based

20. NSI - IVR Solution • Enhanced voice recognition for caller unable to use the phone dial pad for responses • Programmed for a variety of languages other than English and Spanish • Prevalence of various languages at given locations • Numerous dialect variants, thereby increasing its efficiency.

22. ARN Proposal • NSI call filter screens ALL NSI calls • Advantages • Relieves PSAP personnel from burden and frustration of taking bogus calls • Unlike blocking, allows use of previously-flagged problem phones in subsequent true emergency • Linguistic recognition capability expands resources of a single PSAP • National, state and local database management and reporting • PSAP Controls (web based on/off, schedule, real time CDR etc.) • Tower location & antenna segment

23. RequirementsCost Support • Cost support • IVR works best and lowest cost • Call transport = a few pennies per call • Small compared to the disruption & manpower cost • USF Contribution component • Carrier allocation • State funding reimbursement

24. Liability Immunity from Civil Damages for Personal Injury and Property Damage Liability • Researched 45 state 911 statutes • Employees, vendors, agents, and authorizing government entity • U.S. Congress passed the Wireless Communications and Public Safety Act of 1999 (9-1-1 Act) • Only reaches parity of wireless to wireline in the state statutes

25. LiabilityImmunity from Civil Damages for Personal Injury and Property Damage Liability

26. Qualifications • Largest provider of unregistered roaming services in US and North America • 1,000 carrier switch sites • Largest provider of Unregistered Roaming • 23 million calls processed each month (90% NSI) • Experienced in IVR user services • Proprietary IVR system already tested and in use • Technology-agnostic – can be used with all NSI devices