Communications Decision Could Impact Emergency Response

Telecommunication changes may be coming to a little known but important third-party entity called the local number portability administrator. From a public safety perspective, though, these changes may not be for the better. At risk could be first responders’ ability to locate some 911 callers, law enforcement agencies’ capabilities to track criminals and terrorists by their telephones, and the post-disaster resilience of the telephone network. These three issues are on the table as the Federal Communications Commission (FCC) considers a recommendation to change the provider of the local number portability administrator on 30 June 2015 and, by extension, affect these public safety capabilities.

Identifying 911 Callers 

The first issue relates to the effective operation of the nation’s current 911 system. When 911 receives a call from a “silent caller” – one who cannot talk because he or she is injured, panicked, unconscious, under duress, very young, or in a serious situation – that person does notentify where they are calling from. However, 911 operators and dispatchers can check the records that correspond to the caller’s phone number and look up a billing address, telephone carrier, and other information that might help locate the caller. This information is stored in an automatic location information (ALI) database. But, when a number is “ported” – moved from one telecommunications company to another, or from one technology (wireline, wireless, or Voice over Internet Protocol) to another – ALI databases do not automatically sync the new information.

To resolve this, the information technology providers for 911 have worked with the current local number portability administrator, Neustar, to develop protocols for crosschecking their ALI databases against the porting information the administrator maintains. This process occurs thousands of times a week across the United States to keep ALI data current. However, the procurement for a new local number portability administrator does not mention continuation of this capability. This omission prompted the National Emergency Number Association, which represents the United States’ 911 equipment providers, to voice their opposition. “911 services are the backbone of America’s public safety infrastructure,” the association wrote in a letter dated 22 August 2014 to the FCC. It concluded that the 911 system “must deliver 100 percent accuracy, and 100 percent reliability, 100 percent of the time.”

Tracking Law Enforcement Suspects 

The second capability at risk under the procurement that is before the FCC is a crucial tool for local, state, and federal law enforcement. Known as the Local Number Portability Enhanced Analytical Platform (LEAP), this tool allows law enforcement to track suspects by following their phone numbers, even if they change carriers or technologies in an effort to elude investigators. LEAP is critical for maintaining warrants for wiretaps and call histories, and it is thus a staple in investigations and interdiction of terrorism, organized crime, drug cartels, and other high-level crime. According to an 9 August 2014 news report by the Washington Post, this service was used more than four million times to assist criminal investigations in the past year alone.

In the procurement for the new local number portability administrator, LEAP has been viewed as secondary to expediency of porting for consumers and thus not guaranteed. Law enforcement agencies have voiced strong concerns about this. The New York City Police Department, which queries LEAP more than 30,000 times a year, submitted in a letter to the FCC on 9 October 2014 that, without this tool, many of its criminal and counterterrorism investigations will suffer. The United States’ FBI, Drug Enforcement Administration, Secret Service, and Immigration and Customs Enforcement also jointly weighed in, in a letter dated 11 August 2014 and submitted to the FCC, that law enforcement agencies rely on the “important and highly sensitive services” provided by the local number portability administrator “to assist virtually all of the significant criminal and national security investigations.”

A third public safety service is not guaranteed in the procurement: the ability to port phone numbers en masse during or after disasters, in the case that telephone switch infrastructure is inoperable. This capability was used to port more than 300,000 numbers to functional switches after Hurricane Katrina in 2005, and some 60,000 numbers were ported after the 9/11 attacks in 2001. In fact, this capability proved sufficiently robust that public service commissions in both New York State and Florida have added it to their post-disaster protocols. However, the procurement before the FCC for the local number portability administrator would not ensure that this critical function continues.

Transitioning, Testing & Validating Services 

Lastly, the current plan outlines that the entire local number portability database will need to be transitioned in approximately 6 months, though the initial timeline was to last 28 months. There are concerns that a seamless and proven transition could occur in such a short time to the satisfaction of the stakeholders listed above.  

Although the selection of a vendor as local number portability administrator is the FCC’s decision, these vital tools are essential and of interest to the broad public safety community. To assist professionals in law enforcement, public safety communications, and emergency management, FCC should consider requiring that these services be provided, and fully tested and validated, before any potential switchover in provider.

Christina Crue

Christina Crue is a Certified Emergency Manager with nearly 15 years of public safety and emergency management experience in both the government and private sectors. She serves as vice president of Strategic Advisory Services for Witt O’Brien’s. She holds a Masters in Emergency Health Services from University of Maryland University College.



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