Posted by Barlow Keener

On July 23, 2008, a new 911 statute was entered into law.  The “New and Emerging Technologies (NET) 911 Improvement Act of 2008” (the NET 911 Act) requires the FCC to enact rules implementing the Act’s provisions within 90 days of the effective date of the legislation, or October 21, 2008.  The legislation was designed to “promote and enhance public safety by facilitating the rapid deployment of IP enabled 911 and E911 services, encourage the Nation’s transition to a national IP-enabled emergency network, and improve 911 and enhanced 911 (E911) access to those with disabilities.”  The FCC had already required IP-enabled voice service providers to deliver 911 service.  The purpose of the legislation went beyond the FCC’s earlier decision and made 911 and E911 services available to VoIP providers on the same terms that the 911 services are available to CMRS wireless providers.

In the August 25, 2008 Notice of Proposed Rulemaking, the FCC raised questions regarding T-Mobile’s fixed mobile convergence (FMC) WiFi Hotspot “@Home” service.   FMC has been bandied about as the “future” of telecommunications since PCS service was first introduced in the early 1990’s allowing a cell phone to “roam” from the macro-antenna to an antenna inside a customer’s building, directly connecting the user to a PBX, for example, rather than using the cellular network.   Nothing much came of the grand FMC vision, until recently when T-Mobile began offering UMA (”unlicensed mobile access”) technology and Sprint started delivering its Airave femtocell service.  

T-Mobile’s @Home service works like this: some T-Mobile cell phones provide dual-mode GSM/WiFi capability to “roam” from the T-Mobile network and onto a WiFi router using the Internet.   For 911 calls on  a WiFi router, T-Mobile uses either the traditional CRMS network or provides the location of its own WiFi HotSpot WiFi device.  If the T-Mobile phone is roaming outside the T-Mobile footprint or its partners’ footprint, then T-Mobile may not be able provide an accurate location to the 911 system.   T-Mobile has, by any standard, more WiFi experience than any WiFi provider as everyone who has ever used a laptop in a Starbucks is aware.

As early as 2005, T-Mobile asked  the FCC for a clarification of the FCC’s 911 location rules to allow T-Mobile to provide “network-derived location information.”   In July 2008, T-Mobile reported  to the FCC that T-Mobile handled 86,640 911 calls from its dual-mode Hotspot Calling service handsets, and routed 86,521, or 99.9%, of those calls using the CMRS 911 network.  T-Mobile routed 119 of the 911 calls using WiFI and a combination of user provided information and the known location of the WiFi device.   Eight of the calls were “routed to call center for completion.”  T-Mobile requested that the FCC not require it to use the same 911 infrastructure mandated for interconnected VoIP providers as the T-Mobile CRMS 911 system is sufficiently effective.  T-Mobile has encouraged the FCC not to use the 2008 Net 911 Act to lock into one particular autolocation solution for mobile VoIP  calls.   This suggestion makes good sense as CMRS providers deploy a proven 911 service and, on the other hand, interconnected mobile or nomadic VoIP service have numerous technical hurdles to overcome.

For the first time, the Commission appears to be moving into some of the 911 issues related to the rollout of femtocells.  The most interesting aspect of femtocell deployment is that femtocells may be moved by customers from one location to another.  While carriers may “lock” femtocells using GPS or IP addresses, there is no requirement to lock the femtocells.   It is feasible to see femtocells moved into areas not served by providers - like vacation homes in Vermont or Montana.   If the femtocell is not locked and GSM is used, the location of the cell phone will be difficult to obtain.   If the femtocell is locked then the user will not be able to make a 911 call which, of course, is not a result the FCC or carrier is looking for.   We should expect to see 911 femtocell location issues addressed in the FCC’s implementation of the 2008 NET 911 docket.   Femtocell calls, unlike the typical CMRS calls, are delivered over the Internet.   However, is a wireless call delivered over a femtocell a CMRS call or an “interconnected VoIP call”?  This is an issue that the FCC might end up addressing in the 2008 Net 911 Act rule making proceeding.

Technorati Tags: Femtocell,FCC,911,Wireless,VoIP

Take a look at this Motorola Youtube video below to see how femtocells are going to move cell phones onto the Internet.