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Vendor's Corner: NENA i3: Something Less Than the Holy Grail of NG9-1-1

Author: Stephen Meer, ENP, Intrado

Copyright: Copyright 9-1-1 Magazine, Feature Content

Date: 2011-03-08
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There is one thing everyone in the public safety community agrees on: the time to overhaul the Enhanced 9-1-1 infrastructure is overdue. The current voice architecture was conceived in 1968 by borrowing various existing technologies that serviced other areas of telephony with the underlying enhanced data environment following about five years later. Nothing new or revolutionary was invented then and, unfortunately, almost nothing new or revolutionary has been invented since, apart from modifications to accommodate mobility. The key underpinnings of today’s 9-1-1 framework are still based on that same wireline, analog, circuit-switched technology. The fact of the matter is 9-1-1 has failed to evolve with modern, digital telecommunications, and that gap is quickly turning into a chasm that broadens every day. To adequately deal with this we must get serious about implementing the additional functionality and benefits of next-generation 9-1-1 (NG9-1-1). That is the part we agree on, but exactly how to achieve this is a matter of increasing debate.

An Un-detailed Definition

The National Emergency Number Association (NENA) has put considerable effort into creating a theoretical framework for an NG9-1-1 system they call i3. NENA’s i3 document outlines their idea of a completed, fully integrated IP-based network of networks shared by all emergency agencies. This work has been monumental and is viewed by many industry stakeholders as the comprehensive definition of next-generation 9-1-1. The document offers many good ideas; however, we need to be clear about what i3 is and what i3 is not.

In the most basic terms, the i3 document is a partial set of functional interface specifications for NENA’s proposed next-generation solution. It is not NG9-1-1; and it is by no means the only document we need to consider to successfully define and reach NG9-1-1. Taken in proper context, the current version i3 document is a piece of the next-generation definition. It is one of a plethora of documents currently being written by many organizations that need to be utilized collectively to effectively migrate our aging 9-1-1 system to a modern, digital architecture that can and will evolve with our broad range of public communications systems.

The i3 proposal presents the most sweeping changes the 9-1-1 industry has ever seen, dwarfing the work done to incorporate wireless Phase I and Phase II functionality. Yet, as written, i3 presumes and relies on a number of technical, operational, and regulatory dependencies that are not clearly identified or defined. Such gaping holes render the proposed architecture impractical and impossible to effectively deploy or operate. For example, the entire 252-page document includes only three lines and three words dealing with the encoding and decoding of voice in the system, and those words fail to establish a clearly delineated voice interface.

It is common for standards documents to avoid the details of implementation, and i3 is no exception. However, i3’s lack of guidance in this area creates a house of cards; a domino effect of missing information relative to interfaces, data flows, operational requirements, costs, and risks that is essential to the development of the defined system. This silence, coupled with the poorly defined interfaces that are included in the document, will significantly hinder the development of necessary network elements. As it stands now, the document is open to broad interpretation by manufacturers and system operators which will inevitably lead to incompatible components, lack of flexibility, and overwhelming costs. In short, i3 will deliver an unworkable system that will fail to deliver on its requirements or its promises.

Unrealistic Expectations

      From PSAP managers to state legislators to federal policy-makers, a shocking number of emergency services decision-makers are being led to believe the proposed i3 technical requirements outline everything needed for a comprehensive next-generation framework. Promises are being made up the 9-1-1 food chain regarding what i3 can deliver, but the unsuspecting public, as well as the emergency services community, is going to be disappointed.

The wording of the document is often vague and encourages readers to expect services that are still out of reach. Many PSAP operators erroneously expect to implement an i3 system and then instantly and easily have access to functionality such as text capabilities and video sharing. However, the document fails to address the fact that carriers and other providers need to deliver capabilities and operational methods that allow for this functionality—something they cannot yet do—and, as of today, i3 has not defined these requirements to a level of usability.


Disregard for the Wireless World

The foundation of i3 is unfortunately based on the idea that dramatic changes in telecommunications will result in a purely Internet-based communications network. This is unrealistic as it creates a dramatic disconnect between the wireless world where the majority of 9-1-1 calls are initiated and the 9-1-1 system designed to receive and process these calls.

      In reality, it will be the wireless community that spearheads the delivery of text, pictures, and video from the public to the PSAP. Yet, the designers of i3 made no attempt to align the proposed system with the wireless work already underway to deliver these services outside of 9-1-1. In response to this, wireless carriers have banded together to develop their own set of standards for 9-1-1 operability, which has the imminent possibility of resulting in a new and widening chasm between the proposed i3 network and the wireless community. If our next-generation 9-1-1 framework does not embrace the wireless world, then we will simply be replacing one outdated system with another and immediately start down a disconnected path from general telephony, again.


The Work is Not Complete

Next-generation 9-1-1 is necessary. Our current analog framework is simply not adequate for the modern digital age. However, i3 is not an end-to-end proposal, and we cannot risk moving forward without fully understanding the implications of what we are doing. The 9-1-1 industry as a whole needs to recognize that NENA’s i3 document is incomplete and far from the sole definition of next-generation 9-1-1. Next-generation 9-1-1 will be dramatically disruptive to the historical technology, operation oversight, business, regulation, costs and funding of emergency telephony.  Many of these disruptions are suggested directly by the construct of i3, and many more are silently implied. Blindly embracing the concepts of i3 without fully understanding and embracing the related impacts is fraught with peril and is reckless. More work is needed to resolve and document the details necessary to make the i3 proposal usable to manufacturers and system operators and to create an NG9-1-1 network that is beneficial to the public.


Vendor’s Corner is a guest column about product and vendor issues and solutions. Stephen Meer is a co-founder and CTO of Intrado, a leading provider of 9-1-1 operations support systems services for incumbent local exchange carriers, competitive local exchange carriers and wireless carriers.  See


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Posted by:
Date: 2011-03-29 21:10:23
Subject: RFAI - an Expensive Diversion to NG911

NENA’s Future Path Plan was published in 2001.  Since that time, NENA’s technical committees have been developing the standards that will make up i3.  The first i2/i3 standards were actually published in the 2004/2005 time frame.  Yet Intrado waits until the day of i3 approval to express a concern?  I guess I should not be surprised…but I am.   Intrado’s true motivation should be evident to any person moderately knowledgeable about i3 and RFAI.    From a business perspective, ·         Intrado’s biggest revenue generator (cash cow) is ALI DBMS ·         RFAI continues to utilize existing ALI DBMS, i3 does not, this is why Intrado utilizes RFAI ·         Approval/adoption of i3 signals the demise of RFAI ·         Approval/adoption of i3 signals the demise of ALI DBMS (as we know them today) over time ·         Approval/adoption of i3 signals the demise of Intrado’s biggest revenue generator (cash cow)   Intrado sees the handwriting on the wall for i3 approval and a related reduction in ALI DBMS revenue.  Therefore, Intrado is pulling out all the stops to prevent i3 approval.  Even if it means raising weak last minute concerns.
Posted by: brtech
Date: 2011-03-18 10:41:37
Company: NENA Long Term Definition (i3) Work Group
Title: Chair

Two things: 1. Send text. If you want something improved, and any spec can be improved, contribute text. What you have done so far is whine that it's not good enough, not supply suggested text to improve it. Your company used to contribute text. It no longer does. Instead, it complains, in reviews, that it's not good enough. Complaints get no where, contributed text, when edited, gets in the document. 2. NENA ICE Events are proving you wrong. The standards are sufficiently good enough to get multiple interoperable implementations. To be sure, we're not yet testing everything, but what we find as we go through these events is that the spec really is good enough to implement. Nothing is perfect, and the i3 standard certainly is not. We have a long list of things we need to do, but none of them are really crucial to deploying systems that work.
Posted by: S.Meer
Date: 2011-03-16 18:39:56
Company: Intrado
Title: Co-founder and CTO
Subject: NENA i3: Something Less Than the Holy Grail of NG9-1-1

The reason people express their opinions on issues they care passionately about, as I have on the state of our current 9-1-1 system and the shortcomings in the proposed NENA i3 requirement, is to raise a genuine concern. As always, my concern here is driven by a desire to save lives. Conceptually, I support the direction of i3 but believe after years of close and meticulous examination that without significantly more work it could compromise the next generation of 9-1-1. Too many people presume the i3 proposal is ready to be implemented today. Fortunately, that's not the case, which gives all interested parties the necessary time to iron out the flaws. Participating in a public debate over every detail, or lack of detail, in the draft i3 document does not serve the best interests of the 9-1-1 community or the people we're entrusted to protect and serve. Instead, I encourage the public safety industry, government agencies, elected officials and citizens to ask NENA to address the problems in the proposed i3 framework so they can be fixed. It's simply the right thing to do. Thanks
Posted by:
Date: 2011-03-11 18:57:48
Company: NENA Long Term Definition (i3) work group
Title: Chair

This is a reworked version of the Intrado response to the FCC Notice of Inquiry on NG9-1-1. It's factually incorrect, misleading, and self serving. As an example, the salient part of the "3 lines and 3 words" about Voice Mr. Meer refers to are: All User Agents in the ESInet must support g.711 mu-law and a-law. This is in a section that describes how i3 uses SIP as defined in RFC3261 and just following the description that media in i3 is carried in RTP (RFC3550). I am a SIP expert. I was an editor on RFC3261, and co-chaired the SIP working group while that document was written. I can assure you that one line is precise, complete and accurate standards language that will produce fully interoperable implementations of voice calls. No other text is needed. The section cited goes on to recommend that other codecs be implemented (optionally). Another example is his statements on how i3 disregards wireless. Actually, wireless networks are fully supported in i3, both current generation systems that have TDM interfaces and next generation systems that have IP interfaces. The i3 spec defines a Legacy Network Gateway, which is fully specified to interface a legacy wireless network to an ESInet. For next gen wireless networks based on IMS, i3 is expressly designed so that the IMS element called an E-CSCF can provide the proper signaling and routing for i3. What is true is that 3GPP, the standards group that defines IMS, has refused to deal with the specifics of how the E-CSCF does this, despite FOUR YEARS of pleading with them to do so. There is no doubt that we have a lot of work to do to finish the documents that describe NG9-1-1. The ops documents, in particular are not yet in good shape. We have a lot of work to do to educate the 9-1-1 community about what NG9-1-1 is, and how to purchase, build and operate NG9-1-1 systems. Mr. Meer could help that. Instead, he wants a do over. No, thank you.
Posted by: ng911sme
Date: 2011-03-09 10:32:40
Company: Private
Subject: Not grounded in reality

This is so wrong on so many levels it is unreal. First, wireless vendors were invited and even delegated to create the wireless call origination side of i3 back in 2008 (IMS). What did they work on? Technology that Intrado wanted to work on (RFAI) because Intrado leveraged control over the group that was tasked with that effort (ATIS/ESIF). The architecture document for i3 describes both a SIP and an IMS (wireless) implementation. The detailed specification for IMS was not completed because, as I stated, Intrado decided the group responsible for this effort should work on something else. Also, likely 75% of Intrado's income relies on the legacy 9-1-1 systems staying intact. i3 replaces that. Stephen Meer does not want to see his revenue go away and that is exactly what i3 will do unless he changes his corporate direction. The more he can create lag and delay, the better for Intrado and the longer that citizens and PSAP's continue to pay the exorbitant fees his company charges that i3 will replace. The ability to send video, text and voice is well documented in i3. The media is indeed part of implementation and that is well referenced in many supporting standards and documents that any good vendor should understand. It is clear that Intrado and the Positron implementers do not want to read those documents and are suffering from their inability to "do their homework" on media in many of their current and envisioned projects. Please do not take this as a personal smear attempt of Intrado - there are many good people there that have contributed good stuff to i3 and 9-1-1 over the years. I am sure with the right guidance they will likely do very well in NG9-1-1. What we really need now are intelligent vendors in NG9-1-1 capable of delivering quality 9-1-1 services at reduced costs. That is what i3 allows. That is what Mr. Meer hopes will never happen.

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