In the Matter of		)
						)
		All-Hazard Warning - Comment& 	)      Docket No. 000609173-0173-01

SCC Communications Corp. ("SCC") hereby respectfully submits its comments to the National Telecommunications and Information Administration (NTIA) in response to the Agency’s June 23, 2000 Federal Register Notice seeking comment on issues relating to the means by which government agencies and public and private sectors can work together to ensure that hazard warning systems are developed to save more lives.

SCC appreciated the opportunity to participate in the All Hazards Roundtable sponsored by the NTIA on July 17, 2000 and appreciates further the additional opportunity to respond to questions posed by the Agency in its public notice. SCC agrees with Assistant Secretary Rohde that recent technological advances are fostering new and innovative methods that offer a better means of warning the public than the systems in place today.

SCC has been on the cutting edge of this technological development and is a leader in the deployment of emergency notification systems. SCC’s Emergency Warning and EvacuationÔ (EWEÔ ) service provides a fast, secure, precise and cost-effective method to warn citizens of impending danger or emergencies. EWE is an advanced emergency notification system that utilizes the telephone to notify the public of impending dangers such as natural disasters, flash floods, chemical spills, a hostage situation or virtually any emergency.

In the event of a disaster, local authorities activate the notification system. SCC’s EWE service allows thousands of calls to be made within minutes, utilizing a database of geographically coded telephone numbers. Using either a pre-recorded message for pre-planned events as discussed below or a message that can be recorded dynamically with an unanticipated event, residents receive details of the emergency and potentially life-saving instructions. EWE complements other emergency warning mechanisms already in place such as sirens, personal contact and weather warning systems.

A key feature of EWE is the ability to create pre-planned events. For areas prone to certain emergency situations, such as floods or fires, a pre-planned event can be saved into the system so that EWE can be launched immediately when the crises occurs. Real-time events can also be launched as a crisis unfolds. EWE’s high-volume, automated calling platform can make over one thousand simultaneous calls per minute and provide real-time progress reports via phone or fax.

In short, SCC’s EWE allows communities to advance public safety with the most superior technology available. This was proven just this summer in Loveland, Colorado where wildfires in Bobcat Gulch threatened many homes and lives. SCC and Qwest (formerly known as US WEST) launched a wildfire warning and notification to residents throughout the county. The warnings allowed the residents to collect their personal and irreplaceable property and escape unharmed from the uncontrolled fires.

Q1. Is it technologically feasible today to deliver hazard warnings: to wireless devices, such as cell phones and pagers; over the Internet to users who are online; to standard telephones in the form of a call warning; to broadcast television; to satellite services; to cable television; and to emerging and developing technologies?

R1. As described above, it is not only technologically feasible to deliver early hazard warnings to wireline phones; it is being done with great success today. It is also technically feasible to deliver hazard warnings to the other instruments, but it is more technically challenging to provide warnings to wireless phones for reasons discussed in response to Question 2 below.

The best warning systems share the following characteristics – they are broadly applicable across all technologies, they are geographically specific, they are not limited to one technology, they give local public safety officials control, they are designed with a funding mechanism that accommodates service models with recurring fees and lastly, the systems do not burden the wireless network. As the NTIA knows, it is necessary to make use of all available technologies and distribution methods in order to reach the greatest number of people, including those in rural America and those whose disabilities may impair their ability to receive warnings through traditional means.

R2. Although there are no technological impediments to launch emergency call warnings to wireline phones, the same cannot be said for wireless. Wireless systems are not designed to carry the call volume that would be made by a broadcast call in an emergency situation. A broad warning message to all wireless customers in a given geographic area could overload the wireless network, possibly causing the loss of other calls in progress, including other important emergency calls. Network outage could also impair wireless systems at a time when emergency service providers are trying to communicate via cell phones. Due to the wireless network’s limited capacity, it is necessary to use data instead of voice transmission and to send the warnings in waves so that the network is not overloaded.

A second concern with the delivery of emergency warnings across the wireless network is the difficulty in locating wireless customers. Because many customers travel, the location of the caller is not static. However, the wireless industry is developing location solutions that will be available in the future to deliver emergency messages to cellular and personal communications services phones. Once Phase II wireless location detection devices are successfully deployed, it may be possible to better identify the location of wireless phones, thus permitting the use of emergency notification to warn wireless phone users.

R3. Economic impediments to the full deployment of emergency notification systems include costs to upgrade existing, older, analog wireless networks to accommodate

call volume so that the network is not disrupted. Other costs include the deployment of technology by the wireless industry to assist public safety personnel in the location of wireless customers and the costs incurred by providers for the management and maintenance of the database.

R4. any Legal impediments regarding the use of early notification technologies may include the threat of lawsuits for failure to adequately disseminate hazard warnings. Unintended errors such as dropped calls, database misinformation or failed call completion may subject carriers and vendors to litigation that will only serve to stymie further development and deployment of this life-saving technology. Emergency service providers, carriers and vendors work to balance public and private needs in order to provide the best emergency notification services possible. This balance serves the public interest and should be accorded protection from liability and other legal concerns.

R5. SCC recommends that the NTIA take steps to promote liability protection for carriers, vendors, agents, and public safety agencies for the preparation and delivery of emergency warnings at both the national and state levels. This limitation of liability should extend to civil damages or criminal liability arising from any act or omission in the development, design, installation, operation, maintenance, performance or provision of emergency notification services unless the act is grossly negligent, reckless or intentional. NTIA should also undertake a review of current statutory provisions regarding cyber hacking and terrorism to ensure that current law extends to and protects the integrity and security of warning notification systems.

R6. SCC suggests that the NTIA continue to foster and support forums with industry and public safety agencies so that issues and concerns can be addressed and shared among those who are responsible for providing safety measures to the general public. The NTIA should also make federal grants available to states and localities for the deployment, maintenance and operation of advanced telephonic warning systems. Those same grants should also be used for the ongoing training of emergency notification systems personnel.

Furthermore, the NTIA should develop public education campaigns that integrate broadcast, cable, satellite, wireline, wireless, and Internet industries in order to build citizens’ awareness and use of emergency warning systems. Continued public awareness is an integral part of the success of any emergency notification system.

Lastly, the NTIA should undertake a study to ascertain the level of success, reliability and availability of both the message aspect of the emergency warning notification and also the public’s response to those warnings.

3. CONCLUSION

SCC appreciates the opportunity to comment on the issues raised by the NTIA, both at the All Hazards Roundtable and in response to the questions listed in the public notice. SCC is committed to assist public safety agencies charged with the responsibility to respond to emergencies. To that end, SCC recommends that NTIA continue its efforts

to assist the industry and public safety entities in making early emergency warnings to citizens in need, the standard across the country.