Location Based Wireless Alerting

Gary Jones

Director of Standards Policy

T-Mobile

Once in awhile people ask me what I do as the head of standards.  And I've developed this very simple explanation:  I go all over the world and sit in a room for a week with 100 people and argue! 

But eventually we come up with standards on the way telecommunications equipment will be built.  We've heard in this morning’s panels about communications that were designed to be two-way communications between the public and government.

I would like to talk to you about communications that are one-way communications from the government to the public.  We've heard from Marty Bongers (FEMA) that the Emergency Alert System (EAS) exists today.  You've probably seen the EAS messages scrolling across your television screen, or heard the tone on the radio that says, "This is a test of the emergency broadcasting system."  As Marty said, it's never been used by the president, but it exists today.  What the government is trying to do is find ways to enlarge the capability of EAS, to give alerts to as many people as possible in as short a time as possible. 

So I am going to tell you a little bit about what's happening in at least my part of the wireless industry today.  T-Mobile is one of the nationwide wireless communications providers.  However, I'm going to talk about an effort that's much larger than just T-Mobile. 

T-Mobile use a wireless technology called GSM, as do many other carriers.  T-Mobile belongs to a group called 3G Americas.  That's an organization that unites GSM mobile operators and manufacturers in North, Central, and South America to have one voice to represent the families of GSM technologies.  Because the topic of emergency alert effects all wireless carriers, it was deemed appropriate that 3G Americas look at this, at least for the GSM technology.  So 3G Americas has been exploring the policy issues that must be considered, as well as near and far-term technical capabilities that are proposed by the cellular wireless emergency alert as a component for an effective multi-technology approach.

Wireless technologies can only be one portion of the overall emergency alert system.  So today I will talk about what we've been doing in at least the GSM part of the wireless world.  One of the policy considerations is that cellular can only be just one of the tools for EAS.  Any regulation concerning EAS needs to look at the entire issue from all options that would be available for all alerting.  There are a lot of policy questions that need to be addressed.  Marty touched on a few of these.

·        Who initiates the alert? 

·        Who has the authority to initiate an alert? 

·        What kind of incident would trigger an alert? 

·        What should the alert say?  And how should it be said? 

·        Can it be done just in text? 

·        Can it be done as text and a voice message? 

·        Can it be done with a multimedia message, perhaps a map or a graphic? 

·        What should the geographic scope of the alert be? 

·        What is the expectation of service? 

·        And what are the performance criteria for the delivery alerts?

There are also liability concerns that need to be addressed.  What happens if an alert is not delivered?  Is there liability protection for that?  All of these things need to be addressed before we can have an effective nationwide emergency alert system.  Legislation and regulation will need to expressly address the cost recovery mechanisms for this because it's not cheap.  This has to be a win-win-win solution for government, the public, and the industry. 

One of the first things that we did was look at requirements.  The particular challenge for the cellular wireless industry is that there is a considerable void of requirements and no specific priority for EAS in the cellular wireless environment.  Now, you can look at it two ways.  The bad news is that there are no requirements.  The good news is that there are no requirements.  So it's an open field for us to create those requirements -- including requirements from government and requirements from the disabled community.

3G Americas evaluated existing Canadian and U.S. requirements on broadcast and cable television operators because there were requirements listed for those two industries.  3G Americas looked at perceived guideline principles for all alert services and tried to relate them to the cellular wireless environment.

The general service requirements agreed upon by the cellular industry need to have government input.  We need their cooperation and their communication with us to develop these requirements.  We took these perceived guidelines -- and these came from a number of different entities, one being the Partnership for Public Warning -- and the existing requirements on broadcasters and cable operators.  We tried to put some meat around those.  Some of the issues were: 

·        Should this be an opt-in, or opt-out service? 

·        What kinds of user alerts are appropriate? 

·        Should it be a special kind of alert on your device? 

§  A special ring? 

§  A special vibration? 

§  A flashing light? 

·        What level of timeliness is required for the alert?

·        What geographic location should it cover? 

·        Should it be architecturally scaleable? 

·        Can we start small and grow larger? 

·        What are the message levels?

·        What is the prioritization of those messages? 

·        What languages needed to be supported? 

·        Should the user be able to change languages in his receiving device? 

·        How do you deal with roamers so that a roamer gets a targeted local message where he is instead of where he lives? 

·        What type of message would be appropriate? 

·        And, of course, accessibility.  That's where you folks come in.

3G Americas looked initially at nine different technology enablers, and looked for the challenges of supporting EAS in our wireless environment.  Those included things like:

·        short message service (SMS)

·        multimedia messaging service (MMS) which is like SMS but able to deliver multimedia messages.   

·        EAS telephone auto-dialers (that we'll hear about from our next speaker).  

·        Enhanced short message service, that is, messaging associated with location capability. 

·        Messaging associated with a time stamp. 

·        Cell broadcast service. 

·        IP multimedia services:  We heard a lot about the challenges with moving to all IP this morning.

·        Multimedia broadcast and multicast service:  Think about that as a cell broadcast on steroids, able to do a lot more than just deliver a text message. 

·        Incorporating the NOAA Weather Radio in a mobile handset:  This would be an out-of-band broadcast, that is, an additional radio in the handset that would receive signals out of our traditional cellular or PCS band, but would be used to deliver the message.

We initially looked at the nine I just mentioned.  We've now added to the mix two others.  E-mail alerts and incorporating an FM radio into the wireless device. 

We've looked at these nine possible technical solutions, and weighed them against the evaluation criteria.  What was the performance in meeting the perceived requirements and the perceived guidelines? 

·     How did they match up against the requirements as we knew them for the cable and broadcast industry and the perceived guidelines? 

·     What would be the time frame for deploying them in our network?  Was it a short-term fix?  Could it be done easily?  Or was it a more long-term issue? 

·     How big of an impact did it have on our network? 

·     Handset and device impacts?  We're constantly, in the wireless industry, making handsets that are smaller, thinner, lighter. 

o     How would incorporating EAS impact the form factor of the handset? 

o     The position of the antennas?

o     The battery life? 

o     How does it impact legacy handsets? 

o     Would there have to be a migration of new handsets into the marketplace to facilitate this?

When we look at the future solutions like MMS, or enhanced SMS with location capabilities, the handsets of today don't have that capability built into them.  And to take advantage of that new capability would require a new handset. 

All of these things are being considered.

Carrier network performance impact is a big issue for us.  We're constantly trying to make our networks more resilient, able to recover from outages, redundancy.  How would an emergency alert impact not only the delivery of the message, but once the message is out as the questioner asked a minute ago, how would it impact our network when people immediately pick up their phone and start trying to call their loved ones?

And complexity.  Complexity in our world is a euphemism for cost.  How much would it cost?  The more complex something is, we've found, the more it costs. 

What have we found?  Our evaluation did not reveal any particular technical solution that would enable the wireless carrier to satisfy all of the perceived cellular requirements.  No solution could meet all of the guiding principles.  In other words, there was no silver bullet.  There was no one thing that we could do, one capability that we could add to our system that would satisfy all types of requirements, from the president announcing a worldwide situation, down to a traffic accident on a freeway.

Generally all of the future solutions come at a substantial cost to the carrier and would require a new handset.  Now, the good news is that gives us the opportunity to develop and design new handsets that could have capabilities for not only the mainstream but for the disabled community.  Most of the solutions included technical complexities that had substantial impact to our networks:  Impact on capacity, impact on time for delivery, and those all have to be considered.

Additional details are needed.  We needed to do a more in-depth study.  So that's what we're doing now.  That's what 3G Americas is doing now. 

Some findings:  The U.S. Government and the cellular industry really need to work closely together to come to the best solution incorporating the best technical solutions to meet the EAS requirements, and those really need to be determined by, in our opinion, a joint industry-government group. 

All of the communication options should be duly considered.  We've thrown nothing out.  We've considered all of the options at this point.  We need additional technical and deployment information, and a specific modeling of the nine technologies compared to the types of alerts that we envision. 

We want everyone to remember that the wireless communications is only one part of the puzzle.  We can't solve the problem alone.  We're going to be part of the system that Marty described that would involve radio stations, TV stations, satellite, cable, satellite radio.  We'll all be part of the solution.

Our message to the public and the government is a partnership between industry and government is needed for the best possible solutions.  We're very much interested in a win-win-win approach so that the government, the public, and the industry come out with a solution that is not -- does not cause hardship to any of the entities but furnishes a solution to all. 

Requirements prioritization is needed for the wireless industry to be able to fully evaluate in-depth the various technical solutions.  So we need the requirements.  We need to understand the requirements of government and we need to understand the requirements of the disabled community.

We very much like the model that we used for Wireless Priority Service (WPS).  The Wireless Priority Service was developed and is designed to give selected government officials priority access to our network in times of emergency.  The government wanted the ability for selected individuals -- and those individuals have to apply for and be approved for WPS service -- in an emergency situation when the network is congested to get priority for a radio (cellular) channel when all of the channels are in service.  It does not give them exclusive rights to our systems.  In fact, in the most congested conditions, it only gives them the ability to access 25% of our capability.  So the other 75% is reserved for the public to make their calls.  So it is designed to give priority service, but it does preserve the ability for the public to make calls on our network.  (We're very sensitive to the government taking over our stuff!)  

To plan this, the government and the industry came together, looked at requirements from all aspects, created a solution and deployed the solution in a very short period of time.  So we would very much like to talk about that model.         

I’d like to mention a couple of things that have happened very recently.  Both in the House and the Senate are working on emergency alert bills.  Neither of these bills has hit the floor yet, as far as we know.  The bills are similar, and they do propose a joint industry government working group to develop the requirements, the implementation guidelines, and possible deployment funding. Also the FCC announced that they've added the emergency alert item to their agenda for today's meeting.  They announced a first report and order, and a further proposed rule making on EAS, and they plan to consider -- and that's what the notice of proposed rule making is -- they're considering expanding EAS to mobile phones and other wireless devices.  And they're asking for our input.  (Link to First Report and Order and Further Notice of Proposed Rulemaking: In the Matter of Review of the Emergency Alert System.)

In closing, here on my slide is the most familiar person at T-Mobile:  Catherine Zeta Jones. 

       (Laughter)

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