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Number Portability: What if 9-1-1 Can’t Find You?
Author: Graham Campbell
Copyright: 9-1-1 Magazine, Feature Content,
The Federal Communications Commission (FCC) has for years consistently supported critical public safety and national security capabilities that help keep Americans safe – but that could soon change. A proposal before the agency could degrade crucial public safety and national security functions, including 9-1-1’s ability to locate distressed callers, a crucial system for law enforcement to track suspected terrorists and other criminals, and back-up capabilities for phone service after a disaster.
The importance of the Automatic Location Information (ALI) databases that 9-1-1 Public Safety Answering Points (PSAPs) use to quickly identify the addresses or mobile locations and call-back numbers of incoming calls is never lost on a caller in distress in need of desperate emergency assistance. In the United States, when 9-1-1 is dialed from any phone – wire line, voice over Internet protocol (VoIP), or wireless – that call is routed to a PSAP, which house 9-1-1 call takers as well as the dispatcher who assigns emergency resources. Emergency calls from landline phones are routed based on their physical address, while wireless callers are routed to the PSAP corresponding to the cellular tower receiving the call or the caller’s location.
With more than 70 percent of 9-1-1 calls now coming from wireless phones, Americans rely on emergency locating services as a critical necessity. But with the ever-increasing volume of wireless phones and the mobile telecommunications market that offers consumers highly competitive incentives for their patronage, comes an increased propensity to change carriers. When this happens, the consumers’ phone numbers are moved – or ported – from the old to the new carrier.
But that is not where the 9-1-1-related story ends. This may also occur when a wireline consumer moves their family and their home telephone number from one neighborhood to another or changes to a bundled VoIP system, which is being offered more and more by cable companies. When that number is moved, it is of paramount importance that the change in technology from wireline to VoIP is updated in the ALI database to ensure that in the event of an emergency, a 9-1-1 dispatcher has all the available information at their fingertips. Currently, ALI data is checked and updated against porting records of the the Local Number Portability Administrator (LNPA) thousands of times every single day by the 9-1-1 provider. . This ensures that emergency dispatch centers can locate Americans when they call for help - even if their number has been ported from one carrier to another. Our nation’s 9-1-1 services are the foundation of America’s public safety system and must be accurate and reliable one hundred percent of the time.
However, the FCC is considering a plan that would install a new LNPA that would not be mandated to allow for the updating of 9-1-1 databases as does the current LNPA. Why is this important? Next year, unless the FCC changes course, 9-1-1 call centers may not be able to ensure the accuracy of caller information, making it potentially more difficult for First Responders to locate distressed callers. Without proper location information, a dispatcher must manually request the caller’s location and phone number, if a caller cannot speak or does not know their location, 9-1-1 must rely on other tools, like customer information and billing address to try and find the person in distress.
The National Emergency Number Association (NENA), which represents 9-1-1 providers, weighed in with the FCC to express concerns. NENA noted, “Any transition to a new LNPA must not be allowed to adversely affect 9-1-1 data management. To the extent that candidates for LNPA have not been asked to demonstrate their ability to maintain the number portability services currently relied on by 9-1-1 providers, the FCC should consider amending the Request for Proposals.”
There is a growing list of respected law enforcement, homeland security, and public safety experts who are raising concerns that the plan before the FCC that could degrade crucial public safety and national security functions. The Maryland State Emergency Management Agency said that “the [LPNA] provides three very important services that enhance public safety: the Local Number Portability Enhanced Analytical Platform (LEAP), data validation for 9-1-1 call centers, and porting of telephone numbers from damaged switches to operational ones post-disaster. After July 15, the LNPA will no longer be required to maintain these critical features, which is deeply concerning to our organization.”
But not requiring ALI database services is not the only public safety concern raised by the FCC’s plan, its RFP also fails to ensure that law enforcement agencies can continue to track and investigate suspected terrorists and criminals. Currently, law enforcement is able to track, conduct surveillance, and apprehend suspects. Such tactics are important in pursuing terrorists, drug cartels, white-collar criminals, and other organized-crime operations. But the subpoenas and warrants issued to carriers by law enforcement officials to obtain this information apply only to that specific carrier. Therefore, if a suspect has moved his number from one carrier to another to avoid detection of criminal activity, law enforcement must have the capability to follow him from carrier to carrier.
The LNPA currently provides a service called the Local number portability Enhanced Analytical Platform – known as LEAP. LEAP enables local and federal law enforcement agencies to track a suspect’s phone number, even if the number changes carriers, allowing them to send a subpoena or warrant to the correct carrier or carriers. Law enforcement agencies query LEAP more than four million times a year, including the New York City Police Department, which runs more than 30,000 queries annually.
But this valuable law enforcement tool is in danger because current FCC procurement requirements for the LNPA would make LEAP optional, and the most prominent law enforcement agencies in the U.S. – including the Federal Bureau of Investigation, the Drug Enforcement Agency, and the U.S. Secret Service have spoken out about the harmful effects this disruption could have in bringing criminals to justice and/or preventing acts of terror, saying that law enforcement agencies “rely on the important and highly sensitive services LEAP provides to assist virtually all of the significant criminal and national security investigations.” The New York City Police Department (NYPD) also weighed in with a recent letter to the FCC, and cautioned, “Without this automated process, many of the NYPD’s criminal and counterterrorism investigations will suffer due to the time sensitive nature of these investigations.”
Post-Disaster Phone Service
The deficiencies in the FCC’s plan do not end with not requiring 9-1-1 ALI database services or LEAP capabilities. The FCC plan also fails to include any requirement that would ensure LNPA assistance with the continuity of phone service for Americans affected by a major disaster, which was critical for those displaced by Hurricane Katrina, and also those who were able to quickly regain phone service in the wake of the September 11th attacks.
Currently when we dial a phone number, our calls are routed to the intended destination through a local “switch” that corresponds to the dialed number’s area code. But when local switches are destroyed in a disaster, phone service can be cut off. With wireless services, even if calling from a location disaffected by the disaster – our calls still try to find our home switches. But fortunately, after Katrina and September 11th, the LNPA was able to “port” impacted telephone numbers around damaged switches to operational ones in other parts of the country. For Katrina alone, more than 300,000 wireless numbers were ported to enable users to make and receive critical phone calls, while 60,000 numbers were restored after the September 11th attacks.
Unfortunately, should the FCC move forward, there is no guarantee after 2015 that this post-disaster service will continue, and without this capability, Americans involved in and out of disaster zones may be unable to use their phones due to damaged or destroyed infrastructure.
It is concerning that the FCC would consider a plan that would undercut critical public safety programs by failing to require ALI, LEAP, and post-disaster porting services. Additionally, the timeline to transition these services causes concern due to the intricacy of moving millions of phone numbers to new servers while at the same time guaranteeing no interruption of the above mentioned public safety systems. These tools and services need to be shown to work before the transition is finished, to avoid possible disruptions in public safety investigations and responses. That’s why some of the nation’s most respected voices in American public safety are weighing in to caution the FCC about moving forward with this plan.
Graham Campbell is a Senior Emergency Management Consultant for Witt O’Brien’s, a leading emergency management consultancy based in Washington D.C. Mr. Campbell has nearly 20 years of experience in public safety, including service as a police officer for the NYPD, working as the Training Manager for the Massachusetts Emergency Management Agency and serving in the private sector representing local, state and federal government entities.
9-1-1 Magazine File Photos by R.D.Larson