Confidential1 1 FCC Text to Gulf Coast NENA October 15, 16

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3 33 Text to – inetwork’s Participation A topic in the FCC’s Public Safety and Homeland Security Bureau’s NG9-1-1 Notice of Proposed Rule Making (PSHS NG9-1-1 NPRM) At inetwork’s meeting with the FCC in February 2011, 80% of the focus was on NG A few thoughts at the end on Text to Comments on Text to In January 2012 we were asked to discuss our thoughts in more detail with special emphasis on a few aspects. March 2012 another meeting with the PSHSB to discuss topics they requested. Focus was on the deaf and hard of hearing Several subsequent filings especially related to costs

Confidential4 44 inetwork’s Initial Proposal Service for the deaf and hard of hearing community only Text to Clearinghouse at a national level − All carriers deliver calls to a central clearinghouse − Clearinghouse determines destination state and selected delivery mechanism − Clearinghouse delivers text messages to the state. Single provider under contract to the FCC TRS/VRS funds to be used for service to the deaf and hard of hearing Allows the states to select the method of delivery and timing of rollout − Centralized handling possible − Change of methods allowed − Encouragement to migrate to NG9-1-1

Confidential5 55 Response to inetwork’s proposal Key concepts embraced and will likely be part of the order (if there is one) − Clearinghouse − Several text delivery options − State/ECD Opt-in Timeline to develop an RFP and execute the process too long Expansion to all subscribers makes funding proposal unworkable

Confidential6 66 Possible Regulatory Scenarios (my crystal ball) Interim (pre-NG9-1-1) rules will be established: Yes - 75% probability Regulatory mandate placed on the wireless carriers: Yes -75% probability Mandate extends to all subscribers – Yes – 75% Regulatory mandate placed on Over-The-Top texting services: No - 95% probability Regulatory mandate placed on States: No - 95% probability Mandate includes delivery to the state: Yes – 75% probability Mandate includes delivery to the PSAP: Yes – 75% probability Mandate for service provider collaboration: Yes – 51% probability Best guess on release of regulations: Q – 51% probability

Confidential7 77 Possible Regulatory Scenarios Continued Wireless carriers obligated to provide multiple text delivery mechanisms − Text to TTY: Yes – 95% probability − Text to NG9-1-1: Yes – 95% probability − Text to internet server: Yes – 75% probability − Text to relay service: No – 75% probability State and Local Authorities Participation − Mandate: No - 95% probability − Opt in: Yes - 75% probability

Confidential8 88 National Text to Clearinghouse Exposes a standard interface to OSPs that remains constant throughout the evolution to NG Allows states to choose the text to solution that they feel is most appropriate for their population now Allows states to migrate to other solutions as they become available and to NG9-1-1

Confidential Text to TTY

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Confidential11Confidential11 Text to NG9-1-1

Confidential12Confidential12 We are a NG9-1-1 State Right? Yes but… A true NG9-1-1 system is end-to-end − Carriers interrogate the ECRF for routing information and then deliver the message via SIP directly to the ESRP − Text message stays in SIP through all routing and diversions − Text is delivered to NG9-1-1 Call Handling System Location object in the SIP body decoded by the CPE New window pops up on the display to facilitate interaction All of this is targeted in ANGEN Phase 4

Confidential13Confidential13 Today’s Reality A true NG9-1-1 system is end-to-end − Carriers interrogate the ECRF for routing information and then deliver the message via SIP directly to the ESRP Wireless carriers are delivering calls via SS7 to the Legacy Network Gateways − Text message stays in SIP through all routing and diversions Messages stay in SIP from the inside of the Legacy Network Gateways to the handoff to the PSAP CPE − Text is delivered to NG9-1-1 Call Handling System Location object in the SIP body decoded by the CPE Some CPE in the state is ready to take SIP but not a full NG9-1-1 interface New window pops up on the display to facilitate interaction Most CPE aren’t ready to to identify an incoming test message and pop a window All of this is targeted in ANGEN Phase 4

Confidential14Confidential14 So What’s The Plan? Well, it’s up to the Alabama Wireless Board. Our technical recommendation − Initially, implement the text to internet server method. Text messages are collected at a state level Deposited into a server PSAP is notified of arrival PSAP uses browser to access server and exchange text messages with “caller” The operations challenge − How to organize? Does every dispatcher get trained? − What is the likely volume? − And all the other policies that need to be established….

Confidential15Confidential Text to Internet Delivery

Confidential16Confidential16 Reducing the Anxiety Once you see it in operation, many of your concerns will be reduced You re not in this alone! Every agency will need to address it You won’t be asked to do anything without a great deal of thought and planning − Public Safety and Homeland Security Bureau are sensitive to these issues − NENA and APCO are working closely with the Bureau

Confidential17Confidential17 Suggested Next Steps Get familiar with the topic Invite wireless carriers, vendors, and other stakeholders to speak. Webinars? Get engaged and file comments. − The wireless carriers are very active − Vendors are also activity shaping rules − Some authorities are engaged. Read their filings inetwork will continue to be engaged in the process and make proposals to the AWB for implementation in Alabama if/when rules are promulgated

Confidential18Confidential18 Questions