klowden_1226156306.ppt

www.americanroaming.com

Proposal for Wireless NSI Calls


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


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


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.)


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.


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


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


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


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


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


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


Requiring Callback on All NSI Phones

• Disenfranchises vast universe of older phones without this capability

• Precludes use in real emergency


Establish a National Register of Offending Phones

• PSAP must receive and analyze multiple abusive 9-1-1 phone calls


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


ARN NSI Proposal

– We can ALL make mistakes in judgment

– Gives NSI chance to think it over


Or Avoid a Mistake

http://www.911dispatch.com/911/911_misdials.html


ARN Proposal

– And allow us to trust the real calls


ARN Proposal for NSI• NSI call filter to give caller a choice• 2 Models

– Interactive Voice Response (IVR) – DTMF or Voice Recognition

– Operator Based


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.


Public Safety Answering

Points

Non Service Initiated (NSI) Phone

Send to PSAP Decision

(1) EMERGENCY

(2) Non-Emergency Call

911StoredData

To ARN Calling

Platform

911 + 7 digits & identifier sent from Carrier

No Response

PSAP

PSAP

PSAP

PSAP

PSAP

Operator Intercepts the call and asked questions to determine whether or not this is a true Emergency or “Other” call and then the call is passed to the appropriate destination for processing.


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


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


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


LiabilityImmunity from Civil Damages for Personal Injury

and Property Damage Liability

States Are The Most Likely Prospects

ArizonaArkansasColoradoDelawareGeorgiaHawaii

IllinoisIndiana

LouisianaMichiganNebraska

New Jersey

New MexicoOregon

Rhode IslandSouth CarolinaSouth Dakota

Wyoming

Language Of Their Statutes Is Less Clear

KansasMississippi

New HampshireTennessee

TexasVermont


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

klowden_1226156306.ppt

Technology

bogus nsi calls

wirelessnsi calls

legitimate calls

millionnsi calls

nsi phones

emergency calls inaccessible

psaps blocking calls

problem nsi