Report of Emergency Access Advisory Committee 
(EAAC) Subcommittee 1 on Interim Text Messaging 
to 9-1-1
Version 1.0
March 1st, 2013
1Table of Contents
Executive Summary........................................................................................................................1
1 Overview ..................................................................................................................................3
2 User Needs and Constraints .....................................................................................................4
2.1 User experience...............................................................................................................6
3 Originating Devices and Network............................................................................................7
4 Transport Networks including TCC.......................................................................................11
5 PSAP end................................................................................................................................15
6 National Interim Text and Vendor Proprietary Solutions ......................................................19
7 Education and Outreach .........................................................................................................20
8 Recommendations ..................................................................................................................23
Appendix A: Glossary...................................................................................................................27
Appendix B: Use Cases for SMS-based Text-to-9-1-1.................................................................29
Appendix C: Joint ATIS/TIA SMS to 9-1-1 Architecture............................................................36
Revision History ...........................................................................................................................37
Executive Summary
The ability to text 9-1-1 is key to ensuring that 9-1-1 remains accessible to people with 
disabilities, who are unable to make a voice call to 9-1-1, and to address situations where 
making a voice call is not possible or recommended. This was recognized by the EAAC as part 
of the December 2011 report to the FCC, where the EAAC recommended that an achievable 
interim method for text-based messaging to 9-1-1 would be necessary until NG9-1-1 is fully 
developed, deployed and adopted by industry, public safety and consumers. The EAAC tasked 
Subcommittee 1 to make recommendations to encourage the availability of pre-NG9-1-1 interim 
Text-to-9-1-1. Furthermore, the EAAC adopted a resolution to support “as an interim solution 
for Text-to-9-1-1, at a minimum, short message service (SMS), and other technologies as 
appropriate, with a three digit short code 9-1-1.”
The Subcommittee considered questions around the user needs and constraints for text-
to-9-1-1, the role of originating networks and devices, the characteristics of the transport 
networks between the originating networks and the 9-1-1 PSAPs, and administrative and 
operational considerations on the PSAP side. Based on a detailed investigation of these 
2questions, the Subcommittee developed a set of recommendations for accessible Text-to-9-1-1
in the following areas:
1. General recommendations for Text-to-9-1-1
2. Recognized Features of SMS-based Text-to-9-1-1
3. Policy Considerations for Near-term Text-to-9-1-1 Service
4. Public Education
5. Future Considerations – Next Steps
As the technical, operational, and regulatory frameworks for Text-to-9-1-1 continue to 
develop, the EAAC wishes to note that the adoption and application of these recommendations 
will need to be determined through the appropriate rulemaking and standards development 
processes. The EAAC also notes that some of the recommendations may require further research 
and development of technical standards, best practices or guidelines, before they can be applied. 
The EAAC recognizes that public expectations, including individuals with disabilities, for 9-1-1 
emergency communications should be taken into consideration where further research and 
development may be necessary.
In recommending SMS “at a minimum” for a Text-to-9-1-1 solution, the EAAC 
understood that the capability to support certain features was uncertain. However, the EAAC 
resolved to recommend this solution without significant modifications to existing capabilities in 
order to encourage the timely deployment of interim Text-to-9-1-1.
The EAAC recommends that the FCC and appropriate standards organizations, in 
consultation with appropriate stakeholders such as representatives of Public Safety and 
individuals with disabilities, study and consider the following issues to determine whether these 
issues can be resolved without significant modifications to existing capabilities and prior to the 
completion of the transition to NG9-1-1:
1. The impact of domestic and international roaming on the ability to successfully use the 
interim solution.
2. The inability to provide feedback to users in some cases when the user cannot 
successfully use the interim Text-to-9-1-1 solution.
3. There are many text message services that may look like SMS but may not use the SMS 
technology and therefore will not be connected to the interim service.
4. The feasibility of PSAPs to communicate with SMS-originated Text-to-911 messages via 
conversion to/from TTY.
The EAAC wishes to sincerely thank the EAAC members and invited experts for their 
contributions to this report and working to further the spirit of collaboration and purpose that has 
sustained the EAAC.
31 Overview
The Federal Communications Commission’s (“FCC”) Emergency Access Advisory 
Committee (EAAC) is pleased to offer the following recommendations to advance near-term 
access to 9-1-1 for individuals with disabilities.
Established by the FCC pursuant to The Twenty-First Century Communication and 
Video Accessibility Act (CVAA) of 20101 (“CVAA”), the EAAC believes that achieving equal 
access to 9-1-1 emergency services by individuals with disabilities as part of the migration to the 
national Internet Protocol (“IP”)-enabled emergency network (“NG9-1-1”) is a matter of long-
term national policy. The EAAC recognizes that achieving the goal of an accessible NG9-1-1 
system will require the collective commitment of all stakeholders, including consumers, 
industry, public safety and policymakers, to address the critical issues of technical standards, 
service deployment, and appropriate governance and funding.
As part of the December 2011 report to the FCC, the EAAC recommended that an 
achievable interim method for text-based messaging to 9-1-1 would be necessary until NG9-1-1 
is fully developed, deployed and adopted by industry, public safety and consumers.2 In 
furtherance of this recommendation, the EAAC requested that all stakeholders, including
industry, consumers and public safety, the FCC and Department of Justice, work together to find 
an interim solution that can be rapidly deployed to provide nationwide access to 9-1-1 services 
through an industry standards-based mobile text communications solution(s) to provide critical 
coverage for this important constituency during the transition to NG9-1-1.
In January 2012, the EAAC designated a subcommittee to make recommendations to 
encourage the availability of pre-NG9-1-1 interim Text-to-9-1-1 (“Subcommittee”). In March 
2012, the EAAC adopted a resolution to support “as an interim solution for Text-to-9-1-1, at a 
minimum, SMS, and other technologies as appropriate, with a three digit short code 9-1-1.” The 
Subcommittee has expended significant time and resources developing the following report by 
learning from each other and collaborating on issues in furtherance of near-term Text-to-9-1-1.
The Subcommittee’s first effort was to complete a set of assumptions on which to focus 
the Subcommittee’s efforts. These assumptions include:3
? Using any number besides 9-1-1 creates a problem.  “9-1-1” is extremely successful as a 
“branded” number.  It is unrealistic to expect the public to remember to call any other number, 
especially when they have an emergency. This short-term solution should not necessarily be 
subject to all of the requirements of either voice 9-1-1 calls or long-term solutions so that it can 
be implemented in the near term and without extensively reworking the carrier, handset, or PSAP 
systems.
                                                
1 Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260, 124 Stat. 2751 
(CVAA) (amending sections 3, 255, 303, 503, 330, 710, and 713 of the Communications Act, and adding sections 
615c and 715-19, codified at 47 U.S.C. §§ 153, 225, 303, 330, 503, 610, 613, 615c, 616-20).
2
FCC EAAC Report and Recommendations, PS Docket No. 10-255, at 26 and 28-30 (Dec. 12, 2011) (resubmitted 
in final Jan. 26, 2012) (“EAAC Recommendations for Interim Text Access and Interim Mobile Text Solution”).
3 See Presentation of EAAC Subcommittee 1, Text-to-911 Solutions to 911 Interim to NG911 (Sept. 14, 2012) 
(outlining key assumptions about Pre-NG911 Interim Text-to-9-1-1).
4? The FCC should work with consumers, industry and policy makers to secure any needed 
additional liability protection for all entities that are implementing new Text-to-9-1-1 calls.
? The EAAC believes that if the text message to 9-1-1 solution is not available to all people, with 
and without disabilities, that it would be too complicated for carriers and others to qualify some 
people as eligible and others as ineligible to make an SMS/text message call to 9-1-1 during 
emergency situations. The liability issues from denying access to unregistered callers would 
complicate the issue further.
? The EAAC directed this Subcommittee to take this topic up in 2012 and submit a separate report 
on this important topic.
? From a consumer standpoint, direct access via mobile Text-to-9-1-1 is a critical goal.
Using these assumptions as the base of work, the Subcommittee designated four 
subgroups to consider User Needs and Constraints, Originating Networks and Devices, 
Transport Networks, and Public Safety Answering Point (“PSAP”) issues. After considering the 
issues, the Subcommittee developed recommendations to address near-term opportunities for 
Pre-NG9-1-1 Text-to-9-1-1.
As the technical, operational, and regulatory frameworks for Text-to-9-1-1 continue to 
develop, the EAAC wishes to note that the adoption and application of these recommendations 
will need to be determined through the appropriate rulemaking and standards development 
processes. The EAAC also notes that some of the recommendations may require further research 
and development of technical standards, best practices or guidelines, before they can be applied. 
The EAAC recognizes that public expectations, including those of individuals with disabilities, 
for 9-1-1 emergency communications should be taken into consideration where further research 
and development may be necessary.
The EAAC wishes to express its appreciation to the individual Subcommittee members, 
EAAC members and FCC staff for the time and commitment that has gone into preparation of 
this report, and for the progress that the EAAC has made since it first met on January 14, 2011.
2 User Needs and Constraints
This section responds to key questions posed by EAAC in its survey on the user experience 
during a text-to-9-1-1 call, and outlines questions related to user expectations. Full information 
on the sample and data can be found at http://transition.fcc.gov/cgb/dro/EAAC/EAAC-REPORT.pdf.
Which text communication methods do users want to use in the interim?
In order of importance:
1. Native SMS
2. Over-the-top SMS apps (3rd party app that goes through 3rd party service to send SMS 
to another device, on tablets and computers)
3. Combinations of voice and text.
Note: There are four variations of this scenario.
5a. User makes a voice call to 9-1-1 and for the duration of the call the user as 
well as the PSAP intermix voice and text.
b. User makes a voice call to 9-1-1 and for the duration of the call the user uses 
voice and the PSAP sends text back.
c. User makes a voice call to 9-1-1 and for the duration of the call both the user 
and the PSAP text only.
d. User will send text to the PSAP and ask for a voice call back and then for the
duration of the call the user can text and the PSAP respond with voice.
For other possible interim solutions, beyond SMS, the EAAC survey4, question 16, on p. 23, 
covers this aspect. The results are as follows:
1. SMS (45.1%) 
2. Real-time text (RTT) (45.7%) 
3. Email (43.7%) 
4. Instant Messaging (IM) (31.1%) 
5. Web page (30.2%)  
6. Systems built into car (21.3%) 
Note: The EAAC resolution5 supports "as an interim solution for text-to-9-1-1, at a minimum, 
SMS, and other technologies, as appropriate, with a three digit short code 9-1-1." The user 
preferences suggest that RTT, e-mail, and IM should be evaluated for their feasibility as
additional means to contact a PSAP, in accordance with the "other technologies, as appropriate" 
part of the resolution. Due to PSAP constraints, web-based access and systems built into cars
may have to wait until the longer term.
Which devices do users want to use in the interim?
Ranking of devices in order of importance, also see EAAC survey Question 21:
1. Mobile phones and devices (61.8% for cell phone, 53.7% for smartphone, pager, PDA)
2. Tablets (Survey results under “Others” shows that 9 respondents mentioned iPads or 
iPods)
3. Computers 
Note: This survey question shows which devices users would employ for texting 9-1-1.  Both 
computers and tablets support over-the-top text-to-9-1-1.
                                                
4 See EAAC, Report on Emergency Calling for Persons with Disabilities Survey Review and Analysis 2011, July 
21, 2011, available at http://transition.fcc.gov/cgb/dro/EAAC/EAAC-REPORT.pdf .
5 See FCC EAAC, Resolution regarding Text Messaging to 911 (adopted March 30 2012)
6Note: Regarding point 1 above: EAAC does not have a detailed breakdown for the cell-phone 
figure. It is possible that the 61.8% figure includes all three types: smartphones, feature phones 
and basic phones.
Note: Regarding point 2 above: Since the EAAC survey was conducted, the market share of 
tablets has increased rapidly. The importance of tablets as number two in the above ranking is 
based on the assumption that today many more people with disabilities use tablets than when the 
survey was originally conducted and the adoption of tablet use among this community will 
continue to grow.
2.1 User experience
The points below reflect the user expectations of the respondents, as they pertain to text-to-9-1-
1.6
Direct access: The expectation of the respondents is that users have direct access to 9-1-
1 services. There are no third parties sitting in the path between callers and telecommunicators.
Initiating contact with 9-1-1: Users will expect that the primary method of initiating 
contact with 9-1-1 is via sending a text message using the three-digit code 9-1-1.
Calling 9-1-1 by voice and receiving text back:  Deaf and hard of hearing users who 
have some voice communication capabilities may be able to initiate a 9-1-1 voice calls. These 
users may expect to call 9-1-1 by voice and request the PSAP telecommunicator to text them 
back.
Not being required to register for 9-1-1 services: Users cannot be expected to plan 
ahead for emergencies. The expectation is that they will not be required to register prior to using 
text-to-9-1-1 services. Education may be necessary to help a user appreciate that they will need 
to be a subscriber to the relevant text service by which they are attempting to use 9-1-1 services.
Bounce-Back message: Users will expect to receive information on the success or 
failure of a text-to-9-1-1 message. If PSAPs in an area do not support text-to-9-1-1 yet, the user 
will expect to receive an automated text response immediately that states that text-to-9-1-1 is not 
available and that a call should be made to 9-1-1.
Note: It is important that the content of this message be accessible to people with widely 
varying reading abilities, and as such needs to be crafted carefully to consider the unique
needs of people with disabilities.
Note: The nature of SMS may limit the technical feasibility of the user expectations with 
respect to bounce-back messages. It may not be possible to determine success or failure
of SMS message delivery, but rather only the availability of text-to-9-1-1 services. 
                                                
6 Although the EAAC recognizes that each point describes user expectations for interim Text-to-9-1-1 services, the 
availability of each point will be subject to technical and economic feasibility. Where such features are not 
technically or economically feasible to implement for interim Text-to-9-1-1 services, the unavailability of such 
features should be communicated to the end user through public education, as appropriate.
7Likewise, the store-and-forward nature of SMS may cause delivery to happen as soon as 
technically feasible, rather than immediately.
Roaming: Users will expect the text-to-9-1-1 service to work nearly everywhere within 
USA. Users are likely to get confused if there are technical limitations pertaining to roaming
between carriers within USA.
Note: To the extent that text-to-9-1-1 during roaming within the USA cannot be solved 
via technical means, it is important that users, as stated in the previous paragraph, are 
informed about success and failures of a text-to-9-1-1 message. The expectation is that if 
a failure occurs due to roaming, or for some other technical reason, the user is informed 
via an automated text response immediately. Like in the previous note, the contents of 
this message would need to be crafted carefully.
Note: Failures because of roaming when US users are in other countries and when 
phones with foreign subscriptions are used in USA may be easier to understand and 
accept even if they will also cause dissatisfaction. They could also point to a solution 
(e.g., if the user is told the problem is because the user is texting on a phone from outside 
the country, the user may know to seek out a phone for that country to report their 
emergency).
Note: As above, the nature of SMS may limit the technical feasibility of the user 
expectations with respect to bounce-back messages during domestic and foreign 
roaming.
Feedback on progress: Users expect to receive responses to SMS emergency messages 
within a certain amount of time. If a response is delayed, they may become anxious and assume 
that contacting 9-1-1 has failed. The expectation is that, even if it takes time to process a text 
message to 9-1-1, users are kept abreast of what is happening via appropriate text responses.
Note: There are different causes for why SMS responses may be delayed, and these need 
to be assessed on a case-by-case basis. For any such cause, the responsibility must be 
determined, and the technical feasibility of an SMS response informing the user of the 
delay must be evaluated. For example, delays that happen due to internal processes in the 
PSAP cannot be handled in the same way as delays that happen due to the technology 
used for setting up a session between the Text Control Center (TCC) and the PSAP [e. g. 
a TTY call]; and these in turn are different from delays caused by the store-and-forward 
nature of SMS.
3 Originating Devices and Network
This section responds to the key questions posed by the EAAC regarding the role of originating 
networks and devices in Text Messaging to 9-1-1, at a minimum, via short message service 
(“SMS”) while also considering the key assumptions outlined by Subcommittee 1.7 The EAAC 
recommends that the FCC recognize the capabilities and limitations of wireless service provider 
                                                
7 See FCC EAAC, Resolution regarding Text Messaging to 911 (adopted March 30 2012); Presentation of EAAC 
Subcommittee 1, Text-to-911 Solutions to 911 Interim to NG911 (September 14, 2012) (“EAAC WG1 
Presentation”).
8SMS offered to wireless subscribers as an emergency communications service; lead consumers, 
industry and public safety in managing stakeholder expectations; and ensure adequate liability 
protections are available to support the provisioning of Text messaging-to-9-1-1 service 
accordingly.
Which networks should support 9-1-1 mobile text? 
Utilizing the existing standards-based SMS network architectures and capabilities currently 
offered by wireless service providers to wireless subscribers, with minimal modifications or 
alterations, would be the most technically and economically feasible way to ensure rapid 
deployment of SMS-based text messaging to 9-1-1 (“SMS-to-9-1-1”).
Significant modifications or alterations to the existing wireless service provider SMS network 
standards and architecture would create technical and economic feasibility issues. Such changes
would require development of new chipsets and firmware for mobile devices and equipment, 
and revision of existing network standards and elements in the core wireless networks.  
Modification efforts would take many years and delay implementation of SMS-to-9-1-1 by 
which time messaging capabilities for Next Generation 9-1-1 (“NG9-1-1”) could have already 
been developed and deployed.
While SMS-to-9-1-1 services can lay a foundation for consumer education and network and 
PSAP capabilities that may carry forward into NG9-1-1 deployment, a near term deployment of 
SMS-to-9-1-1 services should not divert industry, public safety, and government resources from 
further developing and deploying NG9-1-1. All stakeholders should be encouraged to continue 
standards development for an NG9-1-1 environment to support necessary emergency 
communications capabilities on future services, networks and equipment.
What are the originating network issues around other text formats (e.g., Over-the-Top or 
Proprietary Solutions)?
Consistent with Section 2 of the CVAA, originating network service providers and equipment 
manufacturers can only support emergency communications over the services and equipment 
offered directly to wireless subscribers.8While wireless mobile devices may support Over-The-
Top (“OTT”) and other third party proprietary IP-based text applications that offer “SMS”-like 
messaging services, third party OTT and other SMS-like messaging service providers should 
utilize a standards-based approach based on the C/E gateway9 architecture in order to minimize 
implementation challenges for industry and PSAPs and ensure the consistent availability of 
Text-to-9-1-1 service for industry, PSAPs and consumers.
                                                
8 Twenty-First Century Communications and Video Accessibility Act of 2010, Pub. L. No. 111-260, 124 Stat. 2751,
Section 2(a)-(b) (2010) (as codified in various sections of 47 U.S.C.) (“CVAA”); see also, Implementation of 
Sections 716 and 717 of the Communications Act of 1934, Report & Order and Further Notice of Proposed 
Rulemaking, FCC 11-151 ¶ 45 (rel. October 7, 2011).
9 C-gateway - "Carrier side gateway", converting between a carrier message format and a standardized format 
within the transport network.
E-gateway - "Emergency service side gateway", converting between that standardized transport format and the 
actual format used by the target PSAP.
9What are the originating network issues around SMS? 
The technical and operational issues surrounding the use of SMS as an emergency 
communications service are well documented.10   Consistent with these issues, utilizing 
standards-based SMS network architectures and capabilities currently offered by wireless 
service providers to subscribers on their home networks (i.e., not roaming on another wireless 
carrier network), with minimal modifications or alterations, would be the most technically and 
economically feasible way to ensure rapid deployment of  SMS-to-9-1-1. Any solution that 
requires significant modifications to existing wireless network architectures and standards will 
delay deployment of SMS-to-9-1-1 and consume resources needed for NG9-1-1 deployment.
In order to encourage the timely deployment of text messaging to 9-1-1 services, the EAAC has 
assumed that a text-messaging to 9-1-1 solution should not be subject to all of the requirements 
of either voice 9-1-1 calls or long-term solutions (i.e., NG9-1-1) so that it can be implemented in 
the near term and without extensively reworking carrier, handset, or PSAPs systems.11  Given 
this assumption, the following issues should be recognized as necessary to support the near-term 
deployment of SMS-to-9-1-1:12
Wireless Subscribers with SMS Capable Handsets: Under existing wireless network 
architectures and standards for SMS, wireless carrier SMS text message services are 
subscription-based and only service-initialized SMS-capable mobile devices have SMS text 
message functionality.
For this reason, wireless subscribers must have an active text message service plan.  In addition, 
support of SMS-to-9-1-1 on non-service initialized (“NSI”) mobile devices is not feasible 
because, at a minimum, support for NSI mobile devices would require new standards and 
significant modifications to handsets already available to end users and the wireless originator 
network radio and core infrastructure.
Therefore, requiring an “all 911 calls” feature for SMS-to-9-1-1 service would create lengthy 
delays in its implementation.  In addition, an “all 911 calls” feature for SMS-to-9-1-1 and non-
service initialized mobile devices would impose significant technical and operational burdens on 
PSAPs.13
Home Network v. Roaming: Just as SMS text messaging services are unique to each 
wireless service provider, each implementation of SMS-to-9-1-1 will be unique to a wireless 
service provider’s capabilities. In inter-carrier domestic or international roaming situations, 
                                                
10 Facilitating the Deployment of Text-to-911 and Other Next Generation Applications, Framework for Next 
Generation 911 Deployment, Notice of Proposed Rulemaking, FCC 11-134 ¶ 53 (Sept. 22, 2011); see also, Text 
Messages in a PSAP Environment, APCO Emerging Technologies (rel July 30, 2012) available at
http://psc.apcointl.org/wp-content/uploads/APCO-Emerging-Tech-Text-to-911-Final1.pdf and Texting to 9-1-1: 
Examining the Design and Limitations of SMS, 4G Americas (October 2010) available at 
http://www.4gamericas.org/documents/SMS%20to%20911%20White%20Paper%20Final%20October%202010.pdf
11 Supra n.1, EAAC WG1 Presentation, Slide 3.
12 The EAAC believes specific technical issues should be addressed through the FCC’s open proceeding on NG911 
and text to 911.
13 See e.g., Petition for a Notice of Inquiry Regarding 911 Call-Forwarding Requirements and Carriers’ Blocking 
Options for Non-Initialized Phones, Notice of Inquiry, FCC 08-95 (Rel. April 11, 2008).
10
SMS-to-9-1-1 cannot, at this point, be supported because addressing the “Text Originator 
Information” and “Home Network Control” issues would require significant modifications to the 
wireless originator network and core infrastructure that will ultimately delay the deployment of 
SMS-to-9-1-1 services. Roaming capabilities should be addressed in NG9-1-1 multimedia 
emergency services.
Text Originator Information: SMS text messages that are sent between wireless service 
provider roaming partner networks (i.e., inter-carrier roaming) do not always pass 
through “Text Originator Information”, including location information. An SMS cannot 
be routed to the appropriate PSAP without text originator information.
Home Network Control: SMS text messages are under home operator control which 
means that SMS messages are routed to a wireless subscriber’s home network for 
processing regardless of the network and location from which the SMS message 
originated. In an international roaming situation, home network operator control is 
problematic because the home operator network is outside the U.S. and is not capable of 
routing a SMS toward the appropriate U.S.-based PSAP.
Intermixed Voice and SMS:Many users would benefit from a possibility of having
SMS intermixed with a voice call. The current wireless carrier network architectures route voice 
calls and SMS separately. The voice call path to the PSAP is already implemented. It would 
therefore be a significant modification to restructure these connections to allow integration with 
the SMS path to handle the two paths as one call with one PSAP operator. It is therefore more 
realistic to not implement this integration until the implementation of NG9-1-1.
Bounce-Back Notifications of SMS-to-9-1-1 Availability: A wireless subscriber should 
receive an automatic reply to their SMS-to-9-1-1 message if SMS-to-9-1-1 services are not 
supported by the appropriate PSAP or the wireless network over which the subscriber originates 
an SMS-to-9-1-1 message.
Given the issues to generally support SMS-to-9-1-1 in a roaming situation, the feasibility of a 
bounce back message in an inter-carrier domestic or international roaming scenario requires 
further study by an appropriate standards body, such as the joint Alliance for
Telecommunications Industry Solutions (ATIS) and the Telecommunications Industry 
Association (TIA) SMS to 9-1-1 standards committee.
Non-Proprietary Solutions: In order to ensure the timely and consistent deployment of 
SMS based Text-to-9-1-1, industry and public safety cannot be expected to support diverse and 
proprietary Text-to-9-1-1 solutions. The joint ATIS/TIA industry standard14 for wireless carrier 
native SMS-to-9-1-1 is one non-proprietary solution that can encourage the timely deployment 
of Text-to-9-1-1 and support a flexible and interoperable environment for multiple wireless 
carrier and public safety network configurations.  This joint standard also defines capabilities 
necessary to support SMS-to-9-1-1, including standardized interfaces from the originating 
                                                
14 References to “Joint ATIS/TIA SMS-to-9-1-1 industry standard” throughout this report refer to the draft of J-
STD-110, Joint ATIS/TIA Native SMS to 9-1-1 Requirements and Architecture Specification. For additional 
information regarding this draft standard J-STD-110, please contact the ATIS Document Center Administrator at 
<doccenter@atis.org>.
11
network via the transport network to the PSAP, obtaining coarse location for routing, handling 
bounce-back messages, and managing the text message dialog between the originator and PSAP. 
Once finalized, the joint ATIS/TIA industry standard will be an open standard available for any 
entity to adopt, such as Over-The-Top providers.
Do phones or networks or both block three digit 9-1-1 SMS addresses?  (if phones - how 
many phones?)
SMS-to-9-1-1 should be supported by a 3-digit SMS-capable wireless handset, including feature 
phones and smartphones. Using any number besides 9-1-1 creates the problem that the wireless 
subscriber will have difficulty remembering the new number when they have an emergency.
However, some legacy devices may not support the ability to send to a 3-digit SMS code.  
Originating networks and devices should be permitted to implement a longer SMS code overlay 
that has the same functionality as the 3 digit code.  Both the 3-digit and longer codes could be 
implemented by providers that may have devices that will not support 3-digit short codes.
Options for location provision.
The joint ATIS/TIA industry standard for wireless carrier native SMS-to-9-1-1 is one solution 
that can encourage the rapid deployment of Text-to-9-1-1, support a flexible and interoperable 
environment for multiple wireless carrier and public safety network configurations, and define 
capabilities necessary to support SMS-to-9-1-1, including standardized interfaces from the 
originating network via the transport network to the PSAP, obtaining coarse location for routing, 
handling bounce-back messages, and managing the text message dialog between the originator 
and PSAP. Once finalized, the joint ATIS/TIA industry standard will be an open standard 
available for any entity to adopt.
Managing Public Expectations is Critical during Interim Text-to-9-1-1 Availability
The FCC should take a lead role and work with consumers, public safety, the wireless industry 
and other stakeholders to develop a public education program that appropriately explains the 
capabilities and limitations of SMS-based Text-to-9-1-1 service. (See specifically Section 7 of 
this report) As part of managing public expectations, a text originator should receive a response 
notifying the originator if Text-to-9-1-1 service is not available.
4 Transport Networks including TCC
This chapter describes the EAAC’s consensus recommended requirements and characteristics of 
the network for transport of text between the originating networks and the 9-1-1-operators in the 
PSAPs.
Requirements
1. The transport network SHALL convey text messages directed to the short code “911” 
originating from a user’s terminal and delivered to the transport network from the 
originating network.
12
2. The transport network SHALL contain a routing function which will select the 
geographically appropriate PSAP.
3. The transport network SHALL convey the messages originated in user terminals to the 
PSAP.
4. The transport network SHALL initially handle only SMS text originations but be 
standards-based and extendable to handle other text protocols.
5. The transport network SHALL convey text messages from the PSAPs to the originating 
network for delivery to the user terminals, routed by the routing functions.
6. The transport network SHALL link the user and the PSAP operator together for the 
duration of a series of text interactions (a conversation), conveying text messages 
between the user and the PSAP involved in the text interactions.
7. The transport network SHALL adapt the communication to protocols on the user side, 
and offer a defined interface for the originating networks.
8. The transport network SHALL adapt the communication to protocols on the PSAP side 
based upon the capabilities of each PSAP.
Assumptions
1. Originating networks provide communication services to users including text. The 
possibility to handle text sessions with 9-1-1 is added to these services by the originating 
networks.
2. The initially supported text service is the Short Message Service (SMS). The architecture 
and functionality shall enable addition of other services in the same architecture.
3. The mechanisms used shall work for both session-less message communication (like 
SMS), and for session-oriented messages initiated by a call to 9-1-1.
4. The originating network exchanges user communication content with the transport 
network in specific interface points, where routing and protocol translation occurs.
Architecture components and structure
1. Text Control Center, TCC. A name for the combination of gateways and routing 
elements needed to route messages and convert them according to the protocols used in 
the originating network and the emergency service networks and PSAPs.
2. C-gateway functionality. The routing and protocol translating functions in the TCC of 
the transport network, which are the first to receive the message from users to 9-1-1 from 
the carrier side of the network, are called C-gateway functions. They create new sessions 
through the transport network with PSAPs and keep track of existing sessions and 
convert messages between the service provider format and a protocol suitable for 
transmission in the transport network, e.g., a NENA i3 standardized protocol.
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3. The C-gateway functions are provided with location together with the message, or 
retrieve location, and pass this information along to the E-gateways to be used for 
routing and location information to the PSAP.
4. The transport network shall be able to be connected to NG9-1-1 networks when they are 
deployed, and provide the SMS communication with NG9-1-1 at that time.
5. Depending on target PSAP type, the following happens.
a. For NG9-1-1, it goes straight into the Emergency Services IP Network (ESInet)
and to the PSAP handling the session or to the most appropriate PSAP for new 
sessions.
b. For an Interim PSAP, it goes through a gateway on the emergency side, called E-
gateway.
c. For a legacy PSAP, it goes through an E-gateway with a legacy protocol (i.e., 
TTY) towards the PSAP.
Functionality and protocols
1. A standard protocol for network conveyance of SMS is used between the originating 
network and the C-gateway.
a. Information needed for routing shall be provided to the transport network in a 
form that is either directly usable for routing, or possible to convert through 
standardized procedures to a form suitable for routing the call.
2. Formats/protocols to be used to transport text between C-gateways and E-gateways are 
selected from standards based protocols (e.g., NENA i3 specification text protocols, 
ATIS or TIA standards).
3. Formats/protocols to be used to transport text between the E-gateway and the PSAP:
a. Legacy – TTY, via E9-1-1 or direct to PSAP, (feasibility needs to be verified 
because of the functional limitations in TTY communication including Voice 
over IP (VoIP) transport. If TTY is found to  not be a feasible delivery 
mechanism, then a routing system to capable interim or i3 PSAP is needed) 
b. Interim - A specified protocol suitable for text communication and location 
information provision.
c. NG9-1-1 NENA i3 - native SIP/Message, MSRP, SIP/RTT, with support for SIP 
location conveyance (RFC 6442).15
Note: It should be recognized that additional detailed specifications and testing are
required for all of the above cases.
                                                
15 SIP Message - Technical method for text message communication within the Session Initiation Protocol SIP.
MSRP - "Message Session Relay Protocol", another protocol for messages in SIP 
SIP/RTT - "SIP/Real-Time Text", Method for transmission of text as it is created, used in the SIP protocol 
environment..
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4. Text conversation creation and maintenance, tying messages together into a text 
conversation, and dissolving the text conversation when appropriate. 
As specified in NENA i3 - but with longer timeout than specified there. (Note: 2-3
minutes is specified by NENA, while experience from Europe is that the time between 
messages is commonly close to 2 minutes for real SMS conversations). The text 
conversation is usually manually disconnected by PSAP when task is completed.
a. C-gateways coordinate messages in a sequence so that they are routed to the same 
PSAP.
b. Disconnect text conversations by PSAP command or by timeout.
5. Transcoding issues around SMS.
The main handling of transcoding issues is in the E-gateway.
If TTY is used in legacy PSAP, there are a lot of transcoding problems to be solved and 
specified.
a. TTY has only upper case. TTY has a limited set of special characters. 
Information loss can appear from SMS to TTY because of lack of characters in 
the set.
b. Proposed translation table exists in the ITU-T V.1816 standard.
c. TTY has two cases. Letter case and number case. If a case shift character is lost, a 
long row of corrupted characters may appear. Manual action by PSAP is needed 
to recover.
d. Only one way transmission at a time. Formal turn-taking is needed. If not obeyed, 
transmission will be lost or corrupted.
e. TTY is very slow. Only about 6 characters per second can be transferred. An 
SMS message of 150 characters takes about 35 seconds to transmit.
6. Transcoding issues around other text formats.
There are fewer problems with other text formats, but there are some which need to be 
discussed and are left for future study:
a. Long SMS messages are, for instance, composed of chained short messages that 
also may arrive out-of-order.
b. Conversion from RTT to text messaging may confuse RTT users into thinking 
that the connection is broken because of the slowness of messaging.
c. Three(+)-way messages may become Multimedia Messaging Service (MMS)
messages.
7. PSAP capability database. 
A PSAP capability database is needed for storing information on protocol supported by 
each PSAP, so that the E-gateway can select the proper conversion. The access to this 
                                                
16 ITU-T Recommendation V.18 "Operational and Interworking Requirements for DCE:s Operating in the Text 
Telephone Mode". http://www.itu.int/rec/T-REC-V.18/en
15
database needs to be specified as well as its maintenance and financing. A possibility to 
coordinate this function with the Location to Service Translation (LoST) servers should 
be investigated.
5 PSAP end
There are a number of administrative and operational considerations for the PSAP text delivery 
and response end of the Interim Text process.  Impacts and issues requiring careful planning and 
implementation relative to overall Interim Text solution characteristics and to local 9-1-1 
Authority and PSAP processes and procedures.
Text Control and Delivery:
Several optional methods have recently been described for delivering SMS to a 9-1-1 Center:
? Delivery to the PSAP call handling equipment via Automatic Call Distribution system (where 
installed) is preferable.
? Delivery to a standalone web-based interface is workable as a temporary step, however taking 
calls for an extended period of time outside of the normal call handling system will present 
challenges and risks. Maximum integration with existing PSAP call handling and logging 
systems is desirable.
? Delivery via gateway at a local, multi-PSAP IP network where available (could include early 
NG9-1-1 systems).
? Delivery via SMS conversion to TTY.
Operational Considerations:
? National level solutions should not rely on the delivery of SMS calls to PSAPs via 10 digit 
telephone lines.
? National level solutions should not require a voice call to be placed to 9-1-1 before SMS is 
engaged (make a voice dial then switch to text. This is used in some local solutions but it is not 
feasible for national use).
? Delivery to the PSAP should be in the manner that the PSAP or multi-PSAP 9-1-1 Authority 
designates and is part of a standards process (e.g., each carrier cannot have a different solution at 
each PSAP, which would force the PSAP to support multiple, different solutions).
? The national level Interim Text-to-9-1-1 solution must assure that the process for gathering 
information from 9-1-1 Authorities as to their operational readiness and delivery preferences is 
not cumbersome. A process must be identified by which a single point of contact is established to 
gather this information from 9-1-1 Authorities. This could be the TCC vendor or a Public Safety 
organization that already has national PSAP data. Consideration should be given to leveraging 
the existing processes for wireless routing spreadsheets that PSAPs must currently use.
? A continuous connection between the text caller and the destination PSAP during an active text 
call should be maintained for a period of time defined by the PSAP unless the PSAP ends the 
connection. However, the connection between the text caller and a specific PSAP call taker may 
not be able to be maintained throughout the conversation.
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? To the extent technically feasible (realizing SMS is a store and forward system), the interim 
Text-to-9-1-1 solution should assure that text messages are delivered to the PSAP in 
chronological order.
? If the TCC does not see a reply from the PSAP or its equipment for an SMS-to-9-1-1 message 
within a configurable amount of seconds of TCC release toward the PSAP, a notification should 
be sent to the text caller that their text has been sent to the 9-1-1 center and a reply is pending. 
(Reply wording to be defined)
? The interim Text-to-9-1-1 solution should provide an automatic message to any texting caller 
who attempts to text 9-1-1 in an area that does not support receiving 9-1-1 SMS messages.  The 
message should be standardized between carriers as much as possible and should clearly advise 
the caller that they must use an alternate method such as a voice call, relay, or TTY call to reach 
9-1-1.
? The message transport system should provide a message to a text caller indicating that a 
communication path has been terminated by a PSAP.
Also see Section 7 Education and Outreach
9-1-1 Authority Actions:
? All 9-1-1 authorities and PSAPs should proactively assess the proposed delivery interface 
options for interim Text-to-9-1-1 and whether or not they are prepared to handle text messages. 
PSAPs who determine they are not in a position to handle text messages by the designated 
deployment timeframe of the national level interim solution are encouraged to make alternate 
arrangements for a designated PSAP to handle their text messages, and to proactively research 
what it would take to accept these messages in the near future.
? PSAPs should be responsible for designating whether or not they wish to receive text messages
and, if so, their preference for delivery method according to the accepted standard. 9-1-1 
Authorities or PSAPs should formally request SMS-to-9-1-1 delivery to their PSAP(s) and 
identify the desired delivery method(s).
? The PSAP should also designate the minimum period of time that the TCC should maintain text 
interaction during periods of inactivity between a caller and the receiving PSAP. The minimum 
period of time for inactivity will eventually need to be standardized on a national level. This 
standardization will be determined by stakeholders from both public safety and the private sector 
and should be based upon testing with consumers and operational experience.
? 9-1-1 Authorities or PSAPs should be responsible for keeping their text delivery preferences up 
to date with the service provider, TCC vendor, or other central point for interim SMS-to-9-1-1
services.  PSAPs should assess requirements for logging of text messages and assure that the 
delineation of responsibility for this functionality is clearly defined.
? PSAPs that are handling multiple calls during busy times may decide to terminate a text 
connection to assure that their telecommunicator is able to handle other incoming emergency 
calls in a timely manner.  The decision as to how long a PSAP telecommunicator stays “ready” to 
accept text from a specific caller should be based on local policy.
? The method by which a PSAP is/is not able to handle delivery of other services such as medical 
pre-arrival instructions must be implementation-specific and based on local policy.
Also see Section 7 Education and Outreach
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FCC Considerations:
? The FCC should facilitate (to the extent appropriate for the FCC) a method to channel PSAP text 
readiness and delivery preferences through a single point of contact process.
? The FCC should facilitate public education (directly and/or through Public Safety organizations) 
on the national level interim solution. Consumers must be made aware that proprietary text 
systems may not be compatible with the national level interim solution. Focused education 
should be provided for the deaf, deaf-blind, hard of hearing and speech disabled community of 
users to assure they understand the capabilities of the interim solution and to assure they 
understand that TTY will continue to be supported for those that rely on it.
? The FCC should work with appropriate industry representatives to identify and maintain a public 
list of any wireless handsets that will not support SMS-to-9-1-1 text capabilities or identify 
feasible alternative technology solutions, such as a four digit code. The FCC should work with 
appropriate industry representatives to allow a solution via educational or technical means.
? The FCC should characterize what the expectation is of the many proprietary systems that have 
been purchased/implemented in different areas to handle Text-to-9-1-1.  PSAPs may choose to 
implement other text systems as long as it does not preclude their ability to support the national 
level SMS interim solution. Educational efforts will be complicated by the use of multiple 
solutions.
? Other than deployment or maintenance testing, Text-to-9-1-1 test messages should not be 
required and should not traverse the network to the PSAP call takers.  If it is deemed necessary to 
provide the ability for the general public to “test” Text-to-9-1-1 capabilities, an alternate method 
must be applied to handle this Text-to-9-1-1 verification process.  Further investigation of the 
options is required.
What are the secondary deployment priorities for national level SMS-to-9-1-1?
? An open standardized interface between the TCC and legacy E9-1-1 PSAP call handling 
software. In a pre-NG9-1-1 system, the call handling software is often referred to as CPE 
(Customer Premise Equipment).
? The capability to open an audio path with the caller’s device would greatly improve the PSAPs 
ability to determine the nature of the incident being reported. Further study of the technical 
feasibility of this feature is required.
? A method by which to incorporate 9-1-1 text calls into a PSAP’s call handling analysis system 
(typically a management information system –MIS) so they can effectively analyze any impact to 
the quality of the service they provide.
? An E9-1-1 class of service that will allow PSAPs to differentiate an SMS message from other 
voice or TTY calls.  This may be possible for only some interface methods.
? The capability for Intra-PSAP transfers (i.e., transfer between telecommunicators or to a 
supervisor in the same PSAP or 9-1-1 system) is required to assure effective operations.
Presumably a function of the Public Safety equipment or delivery network.
? Ability to transfer text calls to other text capable PSAPs or other text capable systems outside the 
9-1-1 service system. Presumably a function of the Public Safety equipment or delivery network.
? Ability of the text call-handling application to handle multiple texts dialogs simultaneously.
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If implementation at legacy PSAPs is voluntary, should a time limit be imposed wherein a 
legacy PSAP or designated authority is mandated to accept text calls other than current 
TTY? 
While a time limit should not be imposed prior to initial implementation, there should be a 
deadline for a PSAP to designate an answering point.  Within 6 months of interim Text-to-9-1-1
solution availability, a time line for PSAP acceptance should be established, based upon initial 
implementation experiences. The following are PSAP operational considerations that should be 
incorporated into the ongoing dialogue of interim text deployment:
? While it is a fact that TTY is mandated for all PSAPs, it is not accessible to the general public. 
The impact of interim text, even when converted to TTY, cannot be equivalently 
compared.  Appropriate solutions should be pursued for national deployment; consideration of 
time mandates is not appropriate at this early stage of development. 
? The text solutions based on SMS do not support voice in the same call as SMS. There are users 
who need to use a combination of voice and text when communicating with a PSAP (i.e., voice 
in one direction and text in the other).  It may be hard-of-hearing persons who want to talk, but 
need to get text back as a complement or replacement for voice from the call-taker.  Persons with 
speech disabilities may have the opposite need.  It is also essential for the PSAP to have an 
opportunity to listen to sound from the place of emergency. When used together with TTYs, 
these modes of operation are often called VCO for "voice carry over", when it is used for letting 
the user talk, and HCO for "hearing carry over", when the user wants to hear. With modern 
technology the audio path is simultaneous with text, and the VCO and HCO terms could be 
replaced with "simultaneous voice and text".  The industry should research if this technology can 
be made available for deployment within interim solutions. The PSAP call handling interface 
should have the capability to indicate when it is possible to use voice in parallel with interim text 
calls, when it is not possible , and when voice is possible but with functional limitations.   
Further discussion should take place to identify specific requirements for these capabilities.
? Small PSAPs with 1-2 individuals on duty, who must answer incoming calls as well as dispatch 
and manage radio traffic will be increasingly challenged to multitask and manage incoming 9-1-1 
text calls. Simultaneously “talking and typing” has become a common multitasking skill for 
many PSAP personnel.  Text calls however will require multitasking at a different level.  A 
telecommunicator who must track unit status by typing information into a Computer Aided 
Dispatch (CAD) system will not be able to simultaneously “type” responses to a caller via text. If 
a national level interim text solution is backed by the FCC, these PSAPs will need time to 
identify and implement procedures.
? Some PSAPs may consider using a centralized approach whereby a single PSAP handles text 
calls for a group of other PSAPs. Such a central PSAP must have the capability to contact a local 
PSAP for assistance as needed. This type of mutual aid scenario will take time to analyze and 
implement.
? Not all PSAPs have TTY built into their call handling systems or CAD; many still use legacy 
standalone TTY devices. This does not lend itself to a productive way to implement text for the 
general public.
? Some PSAPs do not have computerized call handling systems or CAD.  Telecommunicators in 
these cases use hand written processes to create incidents and track emergency responders in the 
field.
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? Once national level interim text is adopted and a number of PSAPs start making the transition to 
use it, a responsible authority should review what can be done to encourage adoption by the 
PSAPs that will initially not be able to opt in. The interim solution will be around for many 
years, so all concerned parties need to do everything they can to further its use.
Are there limitations that will be encountered in an interim text solution that will impact 
the level of service that is typically provided during a voice based 9-1-1 call? 
? Services typically provided by secondary PSAPs or other dispatch centers may not be available 
during an interim solution via text if the secondary PSAP does not support text. Primary and 
secondary PSAP interaction via voice communication may be required. (Primary PSAP would 
respond to text caller).
? Services provided by other partner agencies, such as transportation agencies, poison control and 
language services, may not be available if those entities cannot support a text conversation or if 
the PSAP is unable to create a multiparty communication with such partner agencies.
? Emergency Medical Dispatch (EMD) instructions as provided for voice calls may not be initially 
available or may not be able to be provided in a timely manner to text-based callers.  It is 
understood that EMD is not uniformly available to TTY callers. The FCC must be cognizant of 
the fact that the general public may expect this level of service to be provided if they text an 
emergency to 9-1-1.
6 National Interim Text and Vendor Proprietary Solutions
More than a dozen proprietary text solutions, often involving additional multimedia data 
features, have appeared during the 2011-2012 timeframe, been marketed to PSAPs and 
Counties, and implemented in localized areas around the USA. Other than those that utilize a 
silent 9-1-1 voice call to establish initial connection to a PSAP, these solutions often have no 
interaction with the E9-1-1 systems, rather using Internet or other separate networking and 
proprietary software and often use separate hardware at the PSAP to accomplish their user to 
PSAP interaction.
With the coming presence of a national SMS interim text solution, and without any other 
actions, users would be confronted with a situation where their local PSAP or County may (or 
may not) have implemented one of several proprietary solutions, quite possibly applicable only 
within their jurisdiction.  When the mobile user moves out of the area where they know a 
specific proprietary solution is available, they would not know if, or which, proprietary solution 
is applicable at their new, current location.  However, the national SMS solution is likely to be 
available to them there.
The user will likely try their usual “at home” method, then find that it does not work and be 
forced to manually start a new emergency communication sequence, losing valuable time in an 
emergency situation.  It may be possible to integrate some proprietary solutions into the national 
TCC routing and delivery process, but that will require more investigation and the determination 
of whether the solution providers are willing to take that approach.  There may also be other 
options, which again will require more investigation.
The FCC should work with public safety, Department of Justice (DOJ), and hearing and speech 
disability community to work with commercial vendors to ensure their software solutions meet 
expectations for emergency services. A combination of Public Safety, FCC, DOJ, deaf, deaf-
20
blind, hard of hearing, and speech disability groups could likely use “directive influence” in
negotiating with vendors for any changes to their software solutions.
Without such an approach nationally, text users will increasingly continue to be uncertain as to 
what works where, with an attendant risk of delayed emergency contact and response.
7 Education and Outreach
As the requirements of an interim text-to-9-1-1 solution are different from the requirements of 
long-term NG9-1-1 deployment, it is critical to engage in education and outreach with all 
affected parties to educate them on the availability and limitations of interim text-to-9-1-1. In 
particular, it is expected that the roll-out of a nationwide interim solution will not happen all at 
once, since not all PSAPs will be ready and willing to accept text-to-9-1-1 immediately.  
Moreover, interim text-to-9-1-1 will have technical limitations that NG9-1-1 will not have, and 
thus users need to be educated on these.  In June 2012, the FCC convened a meeting of 
stakeholders to begin discussing public education messaging and outreach efforts for interim
Text-to-9-1-1.
As this education development effort continues, the EAAC concludes that it is essential that 
parties from the stakeholder groups who understand the details of the planned national SMS 
solution be involved, both for input and for review of planned education materials prior to 
delivery. Some aspects of the education effort need to occur early in the development timeframe, 
specifically for Public Safety, both for various levels of Public Safety management and for 
PSAPs and Telecommunicators. Early information and education is not just a consumer matter.
For instance, Public Safety management needs to be aware, early in the national effort, of what 
impacts to expect for training needs, staffing levels, calltaker work level, budget, `call’ data 
storage and access, and other operational aspects.  This planning information is needed with 
significant lead time, ideally 6-8 months prior to expected first deployment of Interim Text 
service.  Early clarification of how the national SMS interim text solutions relates to other 
available options must be part of initial education and information for Public Safety 
stakeholders.
The EAAC therefore recommends that the FCC continue facilitating meetings of all 
stakeholders consisting of government, industry, consumer, and public safety stakeholders for 
the development of educational materials so as to not delay deployment.
Categories of Outreach and Training:
There are five main categories of stakeholders that need to be involved in these efforts:
? persons who are deaf, deaf-blind, hard of hearing, and those with speech disabilities
? the general public who may use text in situations where voice is not usable, for example due to 
extreme noise or a danger for the caller
? Public Safety community
? wireless service providers
21
? organizations working with communication for the users: relay services, Telecommunications 
Equipment Distribution Programs (TEDPs), National Deaf-Blind Equipment Distribution 
Program (NDBEDP), consumer advocacy organizations, and relevant user organizations
Initial Scope and Goals:
? Have target audience understand what text-to-9-1-1 is.
? Provide the answer to what is text-to-9-1-1.
? Provide a clear and concise explanation of what texting means to end users.
? Understand how it may differ from one location to another until NG9-1-1 is active in their 
location.
? Provide a clear and concise explanation of the commonalities and differences between 
different texting methods.
? Have target audience understand how text-to-9-1-1 is different from voice to 9-1-1.
? Address notion that a text message generally reaches the same call takers as voice-9-1-1, 
rather than going to a dedicated vehicle: telemetric call center or VRS/IP/TRS17
Communication Assistant (CA).
? At message delivery, the PSAP will not receive dispatchable caller location due to technical 
limitations of the interim solution.
? Have target audience understand that roll-out will be staggered. Have them understand the 
timeline for deployment.
? Public Safety related services such as emergency medical instruction may be based on local 
capabilities and may not be uniform across the nation.  Local capabilities impact the PSAP 
services that may be available.
? Have target audience understand who can use it?
? Anybody with a service plan with a US carrier that includes SMS and a mobile handset that 
can send texts.
? Especially beneficial for deaf, deaf-blind, hard of hearing, and persons with speech 
disabilities.
? Can be used when making a voice call could be dangerous (crime, abuse, hostage situations).
? Can be used when making a voice call is impossible (disaster or emergency situation when 
ambient noise level makes it impossible to hear questions from the PSAP call taker or 
responder).
                                                
17 VRS - Video Relay Service
IP - IP Relay Service
TRS – Telecommunications Relay Service (http://www.fcc.gov/guides/telecommunications-relay-service-trs) 
22
? Have target audience understand how to use it?
? Uses native messaging application on a wireless handset, or a third party application 
downloaded by the user that accesses the handset's SMS functionality.
? Question of whether or not to use short-messaging “short hand” [e.g., srsly (seriously), 
ASAP (as soon as possible), B4 (before), F2F (face-to-face), TY (thank you), ETA 
(estimated time of arrival), BTW (by the way), LMK (let me know), DWI (driving while 
intoxicated)].
? Typing a text message in all capital letters will appear as though you are shouting at the 
recipient and should be avoided.
? Have target audience understand when they can and cannot use it?
? Use Text-to-9-1-1 when you cannot or should not use your voice or hearing.
? And when you cannot because your wireless service provider, handset, or PSAP does not 
provide text-to-9-1-1 service.
? Address misconceptions about the reliability of text messages during congestion.
? Have target audience understand when they *should* use it and when not? 
? Use only in a real emergency, when you would make a voice, TTY, or relay call to 9-1-1 in 
similar circumstances. For example, text-to-9-1-1 is not a way to report broken street lights.
? Should only be used when you cannot use voice-9-1-1.
? Have target audience understand how they can find out if text-to-9-1-1 works for their carrier, 
handset, and location.
? Educate target audience about testing text-to-9-1-1. Note: The feasibility of testing is not yet 
known and will be determined later.
? What other ways are there to find out in advance?
? Educate target audience when they activate a handset with their carrier.
? Have target audience understand what can go wrong and what should they do then.
? Text-to-9-1-1 may take longer under normal circumstances.
? Text-to-9-1-1 may result in out-of-order or lost messages.
? Text-to-9-1-1 may not work if the user is roaming.
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8 Recommendations
I. General Recommendations for Text-to-9-1-1
Consistent with the December 2011 EAAC Report and March 2012 EAAC Resolution, 
the EAAC makes the following general recommendations to achieve standards-based methods 
for text-based communications with public safety answering points (“PSAP”) (“Text-to-9-1-1”) 
during the transition to Next Generation 9-1-1 (“NG9-1-1”) services:
a. As a near term and interim solution, users prefer direct access to a PSAP (i.e., “Text-to-
9-1-1” without third party involvement) via native mobile short message service 
(“SMS”). Other text-based communication technologies, such as e-mail, real-time text 
(“RTT”) and instant message (“IM”) (i.e., “Over the Top”/third party text messaging 
services), should be evaluated for feasibility of providing direct access to a PSAP.
c. Utilizing the existing standards-based mobile SMS network architectures and capabilities 
currently offered by wireless service providers to wireless subscribers, with minimal 
modifications or alterations, would be the most technically and economically feasible 
way to ensure rapid deployment of SMS-based Text-to-9-1-1.
d. All Text-to-9-1-1 solutions, including native SMS-based and “Over the Top”/third party 
text messaging services, should utilize a standards-based approach based on the C/E 
gateway architecture in order to minimize implementation challenges for industry and 
PSAPs and ensure the consistent availability of Text-to-9-1-1 service for industry, 
PSAPs and consumers. Industry, PSAPs and consumers should not be expected to utilize 
non-standards-based Text-to-9-1-1 solutions. PSAPs can voluntarily choose to select a 
non-standards-based Text-to-9-1-1 solution, but industry should not be expected to 
support these non-standards-based solutions.
e. As a near term and interim solution, Text-to-9-1-1 should not be subject to all of the 
existing 9-1-1 requirements for telephone calls (e.g., voice calls to 9-1-1) or long-term 
solutions (e.g., NG9-1-1) if such requirements would require significant modifications to 
existing industry or public safety networks, equipment or standards.
f. Text-to-9-1-1 should generally be available to subscribers of SMS-based and “Over the 
Top”/third party text messaging services. Text-to-9-1-1 should not be limited to 
individuals with disabilities because any limitation in this manner may create public 
confusion and unnecessary risk for all entities.
g. Further research, including standards development for the transition of Text-to-9-1-1 to 
NG9-1-1, is necessary to maintain consistency of text- based communications to 9-1-1 
services in order to avoid public confusion.
h. Additional liability protection may be necessary for all entities involved in the support of 
Text-to-9-1-1.
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II. Recognized Features for SMS-based Text-to-9-1-1 Service 
The EAAC recommends that the FCC and appropriate standards organizations18, in 
consultation with appropriate stakeholders such as representatives of Public Safety and 
individuals with disabilities, should consider the following features for SMS-based Text-to-9-1-
1 services, subject to the technical and economic feasibility of such features:
a. Direct Access: SMS-based Text-to-9-1-1 should ensure a message originator has direct 
access to an appropriate PSAP without initially contacting a relay service.
b. 911 digits: Using any number besides “911” to originate SMS-based Text-to-9-1-1 will 
create public confusion and add uncertainty to an emergency communication. Alternative 
technical or educational solutions may be necessary if the three digit code “911” is not 
supported by existing wireless handsets or SMS network architectures or standards.
c. Wireless subscribers with SMS capable handsets: Message originators must not be 
required to pre-register to initiate SMS-based Text-to-9-1-1, but a valid SMS service 
subscription is required.
d. Voice and Text: Use of a voice and text communication in the same “call” should be 
supported in NG9-1-1 and should be further researched for non-SMS based solutions.  
However, this capability will not be feasible for near-term implementation of SMS-based 
Text-to-9-1-1.
e. SMS Roaming: Due to existing SMS network standards and architectures, SMS-based 
Text-to-9-1-1 may not be available when a text message is originated on a wireless 
network other than the home wireless network to which a message originator has a valid 
subscription (i.e., roaming on a wireless network). Additional research may be required 
to provide a “bounce back” notification in this situation.
f. Continuous Connection and Chronological Communications: Recognizing that SMS is 
a store-and-forward service, the transport networks used for SMS-based Text-to-9-1-1
should maintain continuous and, to the extent feasible, chronological communications 
between the message originator and PSAP.
g. Feedback on Progress of Communication: The transport network used for SMS-based 
Text-to-9-1-1 or the PSAP should provide a message originator with feedback on the 
progress of a SMS-based Text-to-9-1-1 communication.
h. Inactivity timer: A standard time for PSAPs to “release/terminate” an SMS-based Text-
to-9-1-1 communication in case of inactivity should be researched, recommended and 
implemented.
                                                
18 These groups include, but are not limited to, the Alliance for Telecommunications Industry Solutions (ATIS), the 
Association of Public-Safety Communications Officials International (APCO), the National Emergency Number 
Association (NENA), and the Telecommunications Industry Association (TIA), each having a mission to develop 
national consensus standards for telecommunications goods and services.
25
i. “Bounce Back” Notifications: An automatic response should be provided if Text-to-9-1-
1 service is unavailable due to lack of network or PSAP support. Additional research 
may be required to provide a “bounce back” notification when service is unavailable in 
certain technically challenging situations, such as roaming.
III. Policy Considerations for Near-term Text-to-9-1-1 Service
The EAAC recommends that the FCC consider the following policy issues related to 
Text-to-9-1-1 services:
a. Originating service providers should utilize a standards-based approach (e.g., ATIS-TIA 
industry standard for wireless carrier native SMS to 9-1-1) based on the C/E gateway 
architecture in order to minimize implementation challenges for industry and PSAPs and 
ensure the consistent availability of Text-to-9-1-1 service for industry, PSAPs and 
consumers independent of the originating network capabilities. Originating network, 
device and service providers should not be expected to support third-party proprietary 
services or solutions.
b. Consistent with recognized standards (e.g., ATIS-TIA industry standard for wireless 
carrier native SMS to 9-1-1), Public Safety Authorities and PSAPs should choose 
whether to request and the method of delivery of Text-to-9-1-1 communications. If a 
PSAP chooses not to accept Text-to-9-1-1 communications (“non-participating PSAP”),
an alternative PSAP (“designated PSAP”) shall be chosen to accept and handle Text-to-
9-1-1 communications.
IV. Public Education
The EAAC recommends that the FCC consider the following public education issues 
related to Text-to-9-1-1 services:
a. Under the coordination of the FCC, national Public Safety organizations and state and 
local public safety entities, along with leading deaf, deaf-blind, and hard of hearing 
organizations, should lead the education efforts with their citizens about the availability 
and limitations of Text-to-9-1-1 services.
b. Other stakeholders, such as industry and other organizations representing individuals 
with disabilities, should provide support where appropriate and consistent with FCC and 
public safety public education efforts.
c. The FCC should provide information about the availability of Text-to-9-1-1 consistent 
with open government policies (e.g., make data available for third parties to utilize).
V. Future Considerations – Next Steps
As the technical, operational, and regulatory frameworks for Text-to-9-1-1 continue to 
develop, the EAAC wishes to note that the adoption and application of the previous 
recommendations will need to be determined through the appropriate rulemaking and standards 
development processes.
26
The EAAC recommends that a plan for completion of development work and deployment 
process be established, potentially through further work by the EAAC and its Subcommittee 1, 
and further recommendations in these areas be provided via an expanded report to the FCC.  
Areas to be treated include, but are not limited to:
a. Definition and integration of the Joint ATIS/TIA SMS-to-9-1-1 methodology with 
overall Text-to-9-1-1 implementation impacts.
b. Development of a test plan for the overall Text-to-9-1-1 processing flow from SMS 
message to PSAP interaction for all options.
c. Development and deployment of education materials for text originators (‘callers’), 
Public Safety stakeholders, and other stakeholders as needed
d. Text-to-9-1-1 processing/operations methods development, including establishment and 
management of TCC control databases such as PSAP interface choices.
e. Establishment and management of a publicly accessible and searchable national Text-to-
9-1-1 database of Public Safety service area status. The EAAC expects the FCC to lead 
the development and implementation of this database.
f. Other items needing detail development and which affect deployment plans are defined 
in the body of this report.
A specific plan for further development and deployment is necessary to support completion of 
the desired end result, effective and timely availability of the interim Text-to-9-1-1 service. No 
one stakeholder can effectively finish the Interim Text-to-9-1-1 national project proposed and 
described in this report; an ongoing collaboration is required. Hence, a plan for that national 
collaboration and project is needed to enable its completion. Given the complexity of applying 
these recommendations, the EAAC also notes that some of the recommendations may require 
further research and development of technical standards, best practices or guidelines.
27
Appendix A: Glossary
apps “apps” is the shorthand name for applications such as programs 
and applications which are loaded onto smart phones or tablets.
ATIS Alliance for Telecommunications Industry Solutions
C-gateway Gateway function in the transport network for communication 
between originating network and transport network
CAD Computer Aided Dispatch
CPE Customer Premise Equipment
CVAA Communication and Video Accessibility Act
DOJ Department of Justice
E-gateway Gateway function in the transport network for communication 
between transport network and the PSAP
EAAC Emergency Access Advisory Committee
EMD Emergency Medical Dispatch
ESInet Emergency Services IP Network
FCC Federal Communications Commission
FSK Frequency Shift Keying
i3 NENA’s designation of the architecture for the IP based next 
generation 9-1-1 (NG9-1-1) networks.
IM Instant Messaging
IP Internet Protocol
ITU-T International Telecommunications  Union (ITU) –
Telecommunication Standardization Sector
LoST Location-to-Service Translation protocol
MMS Multimedia Messaging Service
MSRP Message Session Relay Protocol
NDBEDP National Deaf-Blind Equipment Distribution Program
NENA National Emergency Number Association
NG9-1-1 Next Generation 9-1-1
NOVES Non-Voice-Centric Emergency Services
NSI Non-Service Initialized
Originating network Network providing communications services to users.
OTT Over-the-Top
PDA Personal Digital Assistant
28
PSAP Public Safety Answering Point
RFC Request for Comment
RTT Real-time Text
Short Message Service 
(SMS)
Short message service native to a wireless service provider’s 
originating network architecture.
SIP Session Initiation Protocol
TEDP Telecommunications Equipment Distribution Program
Text Control Center (TCC) A name for the combination of gateways and routing elements 
needed to route messages and convert them according to the 
protocols used in the originating network and the emergency 
service networks and PSAPs. The TCC is part of the transport 
network.
TIA Telecommunications Industry Association
TRS Telecommunications Relay Service
TTY Text telephone based ITU-T V.18 Annex A19 standard for an FSK 
modem, used primarily in the USA.
VoIP Voice over IP
VRS Video Relay Service
                                                
19 ITU-T Recommendation V.18 "Operational and Interworking Requirements for DCE:s Operating in the Text 
Telephone Mode". http://www.itu.int/rec/T-REC-V.18/en
29
Appendix B: Use Cases for SMS-based Text-to-9-1-1
The following use cases are based upon the “Use Cases & Suggested Requirements for Non-
Voice-Centric Emergency Services” (NOVES) and are relevant for SMS-based Text-to-9-1-120. 
Other message types will be defined as the development proceeds. Some elements had to be 
adapted for the constraints of an interim SMS-based solution.
Text-to-9-1-1 and receiving text back from the native messaging application
In NOVES two use cases apply: one if the user remains in the same location, and one if the user 
changes location. There the assumption is that the PSAP will be notified of the location change, 
which may not be possible with SMS-to-9-1-1, due to the limitations inherent in SMS. However, 
even in SMS-to-9-1-1, a location change should not disrupt the call flow.
Text Message from a Mobile Device to Emergency Services
Based upon NENA 73-501 v1 Use Case 121:
Short Description
Bob has a mobile device with a native SMS-capable text messaging application. In an 
emergency situation, Bob decides to send a message to Emergency Services.
Actors
Bob – Mobile Device user 
Carol – E9-1-1 call taker.
Pre-conditions
Bob’s device supports SMS text messaging, and has an SMS service plan activated. The 
device is on his home carrier’s radio access network. The PSAP for which Carol works is 
configured to receive text messaging.
Post-conditions
The text message originated by Bob was delivered to Carol at the PSAP.
Normal Flow
1. Bob already has his mobile device turned on.
2. Bob encounters an Emergency situation in which it would be dangerous to make 
a voice call, e.g., armed robbery in the convenience store where he is a customer. 
(It cannot be assumed that Bob is deaf, deaf-blind, hard of hearing, or has a 
speech disability.)
                                                
20 Use Cases & Suggested Requirements for Non-Voice-Centric Emergency Services, NENA 73-501 v1. Online: 
http://www.nena.org/general/custom.asp?page=NG_NonVoiceEmergSvc
21 Id., at p. 17
30
3. Bob composes a text message describing the emergency, and sends the message 
to the three-digit code 9-1-1.
4. The text message is sent to the PSAP designated for the area that Bob is in. A 
callback phone number may be also included.
5. Carol, who works at the PSAP, receives the message. Carol sends a message back 
to Bob asking questions, including questions about the location of the emergency, 
and Bob responds. Bob’s device is configured so that it does not beep or make 
noise when the response from the PSAP is received.
6. Carol decides that dispatching an Emergency Response team is warranted, and 
sends the response team to Bob’s location.
7. Carol sends a message to Bob advising that help is on the way.
User texts 9-1-1 with location change:
Text Messaging from a Mobile Device to Emergency Services with Location Change
Based upon NENA 73-501 v1 Use Case 1122:
Short Description
Bob has a mobile device with a native SMS-capable text messaging application. In an 
emergency situation, Bob decides to send a message to Emergency Services. In an 
emergency situation, Bob sends a text message to Emergency Services (ES). During the 
exchange of text messages with the PSAP, the location of Bob’s device changes.
Actors
Bob – Mobile Device user
Carol – 9-1-1 call taker
Pre-Conditions
Bob’s device supports SMS text messaging, and has an SMS service plan activated. The 
device is on his home carrier’s radio access network. While changing location, the device 
still remains on Bob’s home carrier’s radio access network. The PSAP for which Carol 
works is configured to receive text messaging.
Post-Conditions
The text message originated by Bob was delivered to Carol at the PSAP. During the text 
message exchange with the PSAP, the change in location has resulted in the continued 
delivery of text messages to Carol at the same PSAP.
                                                
22 Id., at pp. 30-31
31
Normal Flow
1. Bob turns on his mobile device if it is not already turned on.
2. Bob encounters an Emergency situation in which it would be dangerous to make 
a voice call (e.g., hijacking of a bus that Bob is riding).
3. Bob composes a text message describing the Emergency, and sends the message 
to the three-digit code 9-1-1.
4. The text message is routed to the PSAP designated for the area that Bob is in. A 
callback phone number may be also included.
5. Carol, who works at the PSAP, receives the message. Carol sends a message back 
to Bob, asking questions, including questions about his location, and Bob 
responds. Bob’s device is configured such that it does not beep or make noise 
when the response from the PSAP is received.
6. Based on the information received from Bob, Carol requests and receives updates 
of Bob’s location via exchanges of text messages with Bob, asking him about his 
new location.
7. Carol decides that dispatching an Emergency Response team is warranted, and 
sends the Emergency Response Team to Bob’s updated (or projected) location.
8. Carol sends a message to Bob advising that help is on the way.
9. Carol continues to ask Bob about his location. Carol may notify the Emergency 
Response team of Bob’s updated location if necessary.
10. Carol continues to exchange messages with Bob until the Emergency Response 
team arrives.
New Use Case for Bounce-Back when PSAP Does Not Support Text-to-9-1-1:
Text Message from a Mobile Device to Emergency Services and Emergency Services 
do not support text-to-9-1-1.
Short Description
Bob has a mobile device with a native SMS-capable text messaging application. In an 
emergency situation, Bob decides to send a message to Emergency Services. The PSAP 
designated for Bob’s location does not accept text-to-9-1-1.
Actors
Bob – Mobile Device user 
Pre-conditions
Bob’s device supports SMS text messaging, and has an SMS service plan activated. The 
device is on his home carrier’s radio access network. The PSAP designated for Bob’s 
32
location does not accept text-to-9-1-1.
Post-conditions
The text message originated by Bob was not delivered, and Bob received a bounce-back 
message informing him of the failure to deliver his message to the PSAP.
Normal Flow
1. Bob already has his mobile device turned on.
2. Bob encounters an Emergency situation in which it would be dangerous to make 
a voice call, e.g., armed robbery in the convenience store where he is a customer. 
(It cannot be assumed that Bob is deaf, deaf-blind, hard of hearing, or has a 
speech disability.)
3. Bob composes a text message describing the emergency, and sends the message 
to the three-digit code 9-1-1.
4. The text messaging routing function determines that the PSAP designated for 
Bob’s location does not support text-to-9-1-1.
5. An automated bounce-back message is delivered to Bob’s device, informing him 
that his message could not be delivered, and to seek alternate means of contacting 
9-1-1.
New Use Case for Bounce-Back when User is Roaming:
Text Message from a Mobile Device to Emergency Services, and the Mobile Device is 
Roaming
Short Description
Bob has a mobile device with a native SMS-capable text messaging application. In an 
emergency situation, Bob decides to send a message to Emergency Services. Bob’s device 
is roaming on a network in the U.S. that is not his home carrier’s.
Actors
Bob – Mobile Device user 
Pre-conditions
Bob’s device supports SMS text messaging, and has an SMS service plan activated. The 
device is not on his home carrier’s radio access network.
Post-conditions
The text message originated by Bob was not delivered, and Bob received a bounce-back 
message informing him of the failure to deliver his message to the PSAP.
33
Normal Flow
1. Bob already has his mobile device turned on.
2. Bob encounters an Emergency situation in which it would be dangerous to make 
a voice call, e.g., armed robbery in the convenience store where he is a customer. 
(It cannot be assumed that Bob is deaf, deaf-blind, hard of hearing, or has a 
speech disability.)
3. Bob composes a text message describing the emergency, and sends the message 
to the three-digit code 9-1-1.
4. During the routing of the text message it is discovered that Bob is roaming, and 
thus no information about his location, which is necessary for routing, is 
available.
5. An automated bounce-back message is delivered to Bob’s device, informing him 
that his message could not be delivered, and to seek alternate means of contacting 
9-1-1.
Call 9-1-1 and receive SMS-based text back
This use case is primarily geared toward hard of hearing users, who have some voice calling 
abilities, and who may feel comfortable initiating a voice call, but rely on receiving text back 
for best understanding. Possible limitations are:
1. Simultaneous voice and text is not supported by the call path to the PSAP, or the 
PSAP itself.
2. Making a voice emergency call may put some phones in a mode that prevents them 
from receiving text messages until the emergency call has concluded.
Based upon NENA 73-501 v1 Use Case 1023:
Emergency Communication by a Mobile Device to a PSAP via a voice call, then 
switching to Text Messaging Service
Short Description
The use cases allow the text messaging service to be supported as an add-on experience 
to the voice 9-1-1 experience, instead of a standalone or a separate experience.
Upon dialing 9-1-1, the PSAP offers the caller the option of using text messaging service 
if it is supported by the PSAP. If the user accepts, the emergency call switches to text 
messages.
                                                
23 Id, at p.p 28-30
34
The text messaging session between 9-1-1 caller and PSAP has the following 
characteristics:
The caller initiates a voice call to 9-1-1 using the native calling function of his mobile 
device.
The caller may choose to communicate with PSAP via either voice call, or SMS-based 
text messaging, but not both concurrently. If for any reason the text messaging service 
cannot be used, then the 9-1-1 caller and PSAP call taker can fall back to use the voice 
call to 9-1-1.
Actors
Bob is the emergency caller and Carol is the PSAP call taker receiving the emergency 
communication.
Pre-Conditions
Bob’s device supports SMS text messaging, and has an SMS service plan activated. The 
device is on his home carrier’s radio access network. The PSAP for which Carol works is 
configured to receive text messaging.
The user device supports making a voice emergency call, then switching to SMS-based 
text messaging.
The wireless network supports switching from a voice emergency call to text messaging.
Post Conditions
The 9-1-1 caller made a voice call to 9-1-1, asked the PSAP to switch to text messaging, 
and the PSAP responded via SMS. Both the caller and the PSAP continued exchanging 
text messages.
Normal Flow
PSAP uses routable address (e.g., email address or short code) to communicate with 
caller.
1. Bob uses his mobile phone to dial 9-1-1 to report an emergency situation.
2. The call is answered by Carol similar to the existing voice service to 9-1-1.
3. Bob describes his emergency and indicates that he would like to switch to text 
messaging.
4. If the PSAP supports text messaging, Carol sends a message to Bob at his 
callback number, and hangs up the voice call. This message uses a routable 
address (i.e., short code or other type of routable SMS address) to uniquely 
identify the PSAP that initiated the message. If the PSAP does not support 
switching to text messaging, Carol indicates so on the voice call.
35
5. If Bob receives a text message from Carol, he responds to it with his own 
message.
6. If Carol receives a message from Bob, Carol then exchanges more messages with 
Bob.
7. Carol obtained the initial location information of Bob’s device from the voice 
call. From the message exchange, Carol determines the exact location.
8. Carol sends a message to Bob advising that help is on the way. Carol keeps 
exchanging messages with Bob until the emergency concludes.
36
Appendix C: Joint ATIS/TIA SMS to 9-1-1 Architecture
This Appendix provides information about the current architecture of the ATIS/TIA industry 
standard for wireless carrier native SMS to 9-1-124.  This architecture is still in development and 
may be subject to change prior to publication of the standard. Please note that the Joint 
ATIS/TIA SMS to 9-1-1 architecture utilizes different terminology than the terminology used in 
this report.
In the following diagram, the Interworking Functions (IWF) boxes within the TCC box 
correspond to the C/E gateways described in this report.  The SMS IWF, Location IWF, and 
Routing IWF would be associated with the C gateway.  The TTY IWF, ALI IWF, HTTP IWF, 
and i3 IWF would be associated with the E gateway.
                                                
24 This diagram currently in draft status as contained in the draft of J-STD-110, Joint ATIS/TIA Native SMS to 9-1-1 
Requirements and Architecture Specification, and future changes may be made to this diagram prior to final
approval. For additional information regarding this diagram or draft standard J-STD-110, please contact the ATIS 
Document Center Administrator at <doccenter@atis.org>.
37
Revision History
Date Version Description
3/1/13 1.0 Version presented for approval at the full EAAC meeting on March 1st 2013.