Wi-Fi 911: Running with scissors?

When calling 911 for help, depending on the service you are using, your actual mileage may vary, and what you didn't know may prove harmful to your health.

Is Wi-Fi 911 like running with scissors?

Wi-Fi calling may carry some significant baggage when it comes to emergency calling that you need to be aware of before you acknowledge the EULA.

Credit: Mark J. Fletcher, ENP

Emergency 911 services first materialized in the United States when the Alabama Telephone Company established the service in the sleepy little town of Haleyville on Feb. 16, 1968. At that time, phone companies knew the installation address and phone number of each and every telephone device, and calls were routed based on this information. While seemingly unsophisticated by today’s standards, at the time, it was considered quite a feat of engineering.

The process remained valid until Sept. 21 of 1983 when the world changed forever. In a historic decision by the Federal Communications Commission, the Motorola 8000X, the world's first commercially available portable cell phone, was approved for service and personal mobility took on a brand-new meaning. What was the cost of this miraculous technology? For just under $4,000, consumers could ‘cut the cord’ that tethered them to the wall -- a small price to pay for a device that would revolutionize and redefine telecommunications history.

Phase I cellular location services

In addition to innovation, this newfound benefit of mobility brought forth a few complications as well. Since phone numbers on these devices were no longer linked to a fixed address, the long established 911 routing model was shattered. In April 1998, the FCC responded to the issue with an order requiring cellular carriers to provide 911 centers more information about cellular callers. First, providing the phone number of the device originating the 911 call was required; in addition to the physical location of the cell tower. This information was dubbed as Phase I location accuracy, and while useful for call routing to the right agency, the effective radio coverage areas remain several square miles --far too large, and not nearly precise enough to be useful for a physical response.

Phase II location services

In an emergency situation, accurate location is critical. Shortly after Phase I was implemented, and as cell phones were becoming more popular, the FCC upped the ante by demanding carriers provide even more accurate E911 information. This new location information, appropriately dubbed Phase II, provided the latitude and longitude (X,Y) coordinates, when a PSAP queried the cellular carrier after the initial Phase I cell tower information was delivered. Despite the presence of GPS in many phones, these coordinates are still based on radio signal trilateration calculations made by the cellular network, and no direct connection is made between the cell phone and the PSAP, as covered in a previous Blog. This Phase II delivery from the carriers began to appear in late 2001 where it has remained stagnant.

Personal technology rushed forward over the next 15 years, stimulated by the expansion of the Internet and associated Internet of Things, and along with it, the rollout of public VoIP and Wi-Fi services. Smartphones in use today, with their internet-connected data plans, are able to use a new type of phone service dubbed Wi-Fi calling. Named after their use of carrier Wi-Fi connectivity from public access points operated by ISPs, when these devices are connected to a network, including both public and private, VoIP services emulate carrier voice services, eliminating the need for subscriptions to a traditional carrier voice plan. While connected to the Internet, users can place and receive traditional calls to public numbers as well as receive inbound calls. During the time a user is not connected, inbound calls simply go to voice mail for retrieval once online later.

With normal outbound service not available while not connected, the question remains, “what about calls to 911?” The TV commercials mention, “E911 is always available,” but after carefully reading the Terms and Conditions, some significant caveats apparently exist. Here are some excerpts published by a large Cable TV ISP that has been offering Wi-Fi calling for some time:

E911 DISCLOSURE

“WE STRONGLY RECOMMEND THAT YOU TELL OTHERS IN YOUR HOUSEHOLD, YOUR GUESTS, AND OTHER THIRD PARTIES WHO MAY USE THE SERVICE OF THESE LIMITATIONS. YOU SHOULD MAINTAIN AN ALTERNATIVE MEANS OF CALLING EMERGENCY SERVICES AS THE SERVICE IS NOT MEANT TO BE A PRIMARY LINE REPLACEMENT SERVICE.”

Other critical differences and restrictions are also noted that include:

“[I]f you attempt to place a call when you do not have Wi-Fi connectivity, […] attempted 911 calls may be completed through an available cellular network, but [there is no] guarantee that such calls will be completed and any calls that complete through the cellular network will neither provide call-back nor specific location information to emergency call takers.”

“911 calls placed using this Service will take a longer time to route to the Public Safety Answering Point (“PSAP”). A 911 call placed using the Service will first be routed to a third party call center. A live operator will answer the call and then forward the call onto the appropriate PSAP based on the location you provide verbally to the operator.”

“911 calls using the Service may not ultimately complete to PSAP lines staffed by a trained 911 dispatcher and the PSAP line may not be available at all times.”

That’s a lot for an average person to consume and digest, and these restrictions greatly affect getting help in a life-threatening situation. Despite all of the terms and conditions, the liability waivers, and the warnings that are all openly published, the end result is that Wi-Fi phone services do not provide consistent E911 equivalency to regular telephony service, and the burden of responsibility is placed squarely, and possibly unfairly, on the shoulders of the consumer.

In the U.S., 911 is advertised to work from any device, anywhere and at any time providing unobstructed access to emergency services. Have we become so presumptuous that we are letting new modes of communications supplant the basic underlying security and functionality that we have grown up being accustomed too?

One has to stop and question, “Are we running around on the freshly waxed floor with the proverbial good scissors?” Like Mom always said, it’s all fun and games until someone loses an eye.

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