RedSky Informs FCC of Need for Consistent E-911 Program to Protect People

February 28, 2005

In comments filed Monday with the Federal Communications Commission (FCC), Chicago-based RedSky Technologies Inc. said that the process of deploying enhanced 911 (E-911) capabilities in
multi-tenant office structures and campuses across the country needs
significant changes and a sharper focus if millions of American workers, students and citizens are to be as well-protected on the job and in schools as they are at home.

“This critical issue requires more accelerated action,” the company
concluded. RedSky’s comments on the status of E-911 deployment, and telecommunications carrier policies and practices that impact E-911 were submitted to the FCC as part of the agency’s examination of the status of state actions to effectively deploy E-911 systems.

When properly configured and deployed, E-911 services automatically
provide 911 emergency operators — and first responders — with specific location information as to the calling number and the location within a large business or multi-tenant facility.

RedSky, a provider of E-911 software for multi-line business
telephone systems, noted that E-911 deployment requirements, enforcement efforts and penalties, along with education of the public on how to effectively use E-911 capabilities in the workplace versus at home, are lagging despite the fact that 12 states now operate under E-911 legislation.

And even where laws are in place, the requirements often are reportedly inconsistent from state to state. High-risk facilities, such as schools and government facilities, even are specifically exempted.

By some estimates, there are more than 70 million Americans working or visiting office buildings, retail complexes, manufacturing centers, warehouses, health care complexes, educational institutions, etc., who are not as protected as they could be when they dial 911. The company cited two recent high-rise office fires in Chicago as examples of how E-911 capabilities would’ve improved response time, more effectively used public resources and ultimately saved lives.

RedSky recommended that the FCC take leadership in four areas:
— Driving consistent E-911 standards across states and local
— Requiring employers and public officials to proactively educate
workers and telephone system operators regarding E-911 capabilities and operation;
— Extending compliance to existing systems, not just new systems; and,
Crafting and enforcing meaningful penalties as a tool for driving
compliance by large business telephone system operators.

“The Commission should move expeditiously to take action, provide
essential leadership, and establish a consistent national E-911 standard,” RedSky recommended. “Ideally, that standard should align with the model E-911 legislation championed by NENA, the National Emergency Number Association.”

The company also cited specific practices and policies of
telecommunications carriers that impact timely and cost-effective E-911 implementation, particularly for companies with multiple service providers and a multi-state presence. These impediments include:

— Unnecessarily complex network security procedures that make E-911 administration burdensome and expensive for private system operators;
— Non-uniform system interfaces and procedures which vary state by state and carrier by carrier that interfere with establishing a nationwide standard for creating and updating E-911 automatic location identification databases.

RedSky said that it believes that the most important role the Commission can play is to provide leadership and consistent standards in the face of the urgent public safety and security concerns that E-911 addresses.

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