Public Safety, Industry Disagree on NASNA NG-911 Petition

Commenters disagreed on the FCC's role in oversight and implementation of next-generation 911, in comments posted Thursday in docket 21-479 on the National Association of State 911 Administrators' (NASNA) petition seeking a rulemaking or notice of inquiry to fully implement NG-911 (see 2110190066). Some public safety organizations backed a rulemaking clarifying demarcation points for cost allocations.

There's "no regulatory framework in place that defines or requires an acceptable time of when an [originating service provider] must access 911 services ... let alone how an OSP is to deliver a call to the 911 service provider," said the Pennsylvania Emergency Management Agency. PEMA said the FCC should establish its authority over OSPs' "delivery of 911 services to ESInets demarcation points of interface," which Vermont’s Enhanced 911 Board echoed. The FCC is "the only entity with broad jurisdictional authority in the context of NG-911," said Texas 911 organizations.

Clarifying demarcation points for NG-911 cost allocations will “expedite the roll-out of NG911 services by helping to eliminate a major source of disagreement,” said the Iowa Department of Homeland Security and Emergency Management's 911 program. Colorado's Boulder Regional Emergency Telephone Service Authority said similar.

The Minnesota Telecom Alliance disagreed establishing federal demarcation points is necessary. “Federally-designated cost allocation demarcation points would disrupt the NG-911 transition by invalidating or requiring renegotiation of the affected existing meet point and intrastate cost allocation arrangements,” MTA said. The FCC may be able to take a leadership role in identifying solutions, but it's "not clear that rules prescribing specific cost demarcation points would be better or more effective than industry best practices," said USTelecom.

"Negative repercussions" could emerge if NASNA is granted the relief it sought, said NTCA, and certain policy issues raised in the petition "are also found in other contexts and are far better addressed in a comprehensive proceeding to examine them." Any registry should be used for "informational purposes only" because there's "no basis to certify readiness," said CTIA, adding the FCC should initiate an NOI to explore the state of NG-911 "at most."

There's "widespread occurrence and substantial impact" from demarcation delays in NG-911 deployment, said the National Emergency Number Association. NENA said a rulemaking is the "most appropriate method for determining the boundaries of the commission's jurisdiction." Industry "could benefit from greater commission guidance" on demarcation points and "the responsibilities of all parties," said ATIS.

Asserting jurisdiction over the delivery of NG-911 is “necessary” because “call delivery by OSPs to a covered 911 service provider is a growing issue for the states,” said the Colorado Public Utilities Commission. It backed using an NG-911 “readiness registry,” noting that something less granular than the text-to-911 registry “may be appropriate” because NG-911 is “more likely to be implemented on a regional or statewide basis.”

Begin a rulemaking to "adopt baseline requirements defining telecommunications carriers’ rights and responsibilities for providing NG-911," said a coalition of 17 rural ILECs in South Carolina. The group disagreed with NASNA that ILECs should "bear 'the cost of compliance' for interconnecting outside of their service areas" or define demarcation points that shield "911 service providers from the cost of compliance at the expense of the ILECs who have carrier of last resort obligations."

It would be a "disservice to the public and the nation’s dedicated public safety communications professionals to claim that NG-911 has been successfully deployed in any state," said APCO, noting ESInet deployments "have suffered widespread problems." Open a rulemaking to require interoperability for NG-911 and wireless service providers to "support location-based routing," APCO said. An NOI would help the FCC "gather additional information to understand the nature of the problem(s) facing [emergency communications centers]."

Require originating service providers “to access 911 services, via the 911 jurisdiction choice of NG-911 service providers demarcation points, within 150 days or a similarly reasonable timeframe of notification of NG-911 readiness,” said Mission Critical Partners. It backed NASNA's "reasoning for wanting to establish an NG911 cost demarcation point or points" when there's disagreement.

Comtech is experiencing "significant delays in the completion of NG-911 transitions due to regulatory uncertainty," it said. OSPs with cost demarcation disputes "have sufficient financial incentive to extend such debates and, absent Commission adoption of a reasonable timeframe for completing NG911 transitions, suffer no consequences for refusing to cooperate," Comtech said.