NG911 NPRM Could be Controversial, But It's Expected to Pass With Few Tweaks

The FCC appears headed for approval Thursday of a draft NPRM on facilitating the launch of next-generation 911 with relatively few changes (see 2305180069), industry officials said. APCO asked for added language and NTCA raised small carrier concerns, but otherwise a docket on the NPRM has been quiet since the draft item was circulated two weeks ago. Comments were filed last week in docket 21-479.

The NPRM is a follow-up to a National Association of State 911 Administrators' petition seeking a rulemaking or notice of inquiry to fully implement NG911 (see 2110190066 and 2201200043). Commenters disagreed last year on what actions, if any, the FCC should take (see 2201200043).

“We’re not expecting much to change” on the draft, with most waiting until comments are due, said a lawyer with wireless industry clients.

NTCA reported on a series of meetings with the Public Safety Bureau and aides to all four commissioners. The FCC needs to develop “an accurate and complete record with respect to the categories and extent of costs that voice providers will incur should the draft rules be adopted as proposed,” NTCA said: Members of the group “are often trapped behind other upstream operators’ non-IP networks when it comes to the exchange of voice traffic with other providers.”

The small carrier representatives “urged the Commission to ensure that the record of this proceeding will properly account for the types of transport and transit costs that could be imposed on small, rural customer bases and the effect this could have on consumer rates for voice services.”

NTCA proposed language that could be added to the NPRM in four locations reflecting its concerns. As one example, in a paragraph on costs NTCA suggested the FCC add to the end: “Finally, we seek comment on whether a provider’s ability to originate traffic in IP format, or whether it provides broadband services to end-users within its service area, has any relationship to or bearing on the costs the provider will assume to transmit NG911 traffic outside the boundaries of its network and serving area.”

The Competitive Carriers Association agrees with many of the concerns raised by NTCA, a spokesperson emailed: “CCA members also experience issues with upstream operators’ non-IP networks and are always concerned about the costs and timeframes associated with smaller/non-nationwide carriers implementing new regulatory requirements. CCA is following this proceeding closely.”

APCO officials didn’t have meetings at the FCC. Instead, the group suggested the addition of language in eight places sprinkled throughout the NPRM. The changes are intended to “ensure that the NPRM solicits useful insight into the proposals’ potential impacts on emergency communications centers and the opportunity to support the transition to NG9-1-1,” APCO said.

APCO suggested the NPRM ask such questions as how interoperability of systems should be defined and demonstrated and whether originating service providers and covered 911 service providers should be “responsible for achieving interoperability, with no costs passed to [public safety answering points] or 911 authorities?” Another proposed question: “Should we specify that originating service providers’ obligations to deliver calls in an IP-based format extends to the new types of ‘calls’ expected for NG911, such as photos and video?”

The draft warns of potential problems if the FCC doesn’t act. With the transition to NG911, 911 authorities are replacing circuit-switched architecture of legacy 911 networks “with IP-based technologies and applications, which provide new capabilities and improved interoperability and system resilience. Most states have invested significantly in NG911, but some report that they are experiencing delays in providers connecting to these IP-based networks,” the draft argues: “As a result of these delays, state and local 911 authorities incur prolonged costs because of the need to maintain both legacy and IP networks during the transition. Managing 911 traffic on both legacy and IP networks may also result in increased vulnerability and risk of 911 outages.”