NASNA, Which Sought FCC Inquiry, Warns NG911 Transition Is Complicated

The National Association of State 911 Administrators warned the FCC that moving to next-generation 911 will be complicated, in comments on an NPRM commissioners approved 4-0 in June (see 2306080043). The National Emergency Number Association said the FCC is on the right track with the NPRM. Comments were due at the FCC Wednesday in docket 21-479. The notice followed a NASNA petition seeking a rulemaking or notice of inquiry to fully implement NG911 (see 2110190066 and 2201200043).

“There is not just one phase of readiness ... for NG911 implementation, rather it is typically a multi-phase transitional process to an end state replacement of legacy 911 technology, and it is not simply a ‘flip of a switch,’” NASNA said: The states the group represents “are at various stages of transitioning to NG911 and our comments reflect the common thread of issues that States face during these NG911 deployment phases.”

NASNA asked the FCC to address standards. “NASNA believes the standards suggested by APCO, and by NENA both have applicability as it relates to the proposed rules, but we believe it is important to acknowledge that an end-to-end NG911 ‘system’ consists of multiple networks and systems which are subject to different, but complementary interoperable standards,” the filing said. ATIS standards are the choice for providers, but NENA standards are utilized by public safety answering points and 911 authorities, NASNA said: “Where these networks meet, there must be an agreement on the structure and interfaces of 911 media, related data exchanges, and security considerations.”

The FCC “correctly focused its proposed rules on both the timeline for … providers to deliver 9-1-1 calls to these points” designated by 911 authorities “and also the format, requiring delivery in IP-based format after a valid request by state and local 9-1-1 authorities,” NENA said. NENA saw no risk in requiring use of IP-based formats only after a request. Some PSAPs would continue to use legacy systems until a transition is complete, the group said. Requiring carriers to deliver 911 calls, including associated location information, in an IP-based format would “expedite” the NG911 transition “which is the primary goal of the NASNA Petition and the Commission’s basis for initiating this proceeding,” NENA said.

NENA also supports a proposed rule requiring wireless, wireline and interconnected VoIP providers to transmit 911 calls to the interconnection points designated by the 911 authority in the absence “of a state or local law to the contrary.” Doing so “would provide a transparent default rule that would encourage 9-1-1 authorities and originating service providers (OSPs) to negotiate interconnection points in good faith,” NENA said: “Such a requirement also would preemptively prevent disputes regarding the points to which providers must deliver 9-1-1 traffic.”

The Industry Council for Emergency Response Technologies (iCERT), which focuses on the emergency response sector, said improved clarity from the FCC would “accelerate NG911 deployment.” Questions about the applicability of FCC rules to ILECs “created considerable confusion, delay, and unnecessary costs to NG911 deployments,” iCERT said: “There is ample evidence to conclude that regulatory uncertainty regarding the manner in which ILECs interconnect with NG911 systems, as well as their cost allocation and billing practices, has resulted in significant, unnecessary, and costly delays to NG911 deployments in various states.” As NASNA noted in its petition, “the biggest regulatory roadblock is the establishment of appropriate demarcation points for cost allocation.”

The Texas 9-1-1 Alliance, Texas Commission on State Emergency Communications and the state Municipal Emergency Communication Districts Association said the FCC did a good job in the NPRM of identifying issues slowing a move to NG911. They cautioned the commission “against adopting a single level of valid request readiness to the extent it would limit the applicability of the Commission’s proposed rule requiring originating service providers to transition from a legacy 911 selective router in a timely manner upon request.” Proposed default presumptions on delivery points and cost allocation “are reasonable next steps and represent a compromise to further NG911 transition, while reserving Commission authority to grant good cause waivers in truly exceptional circumstances,” the Texas groups said.

The National Association of the Deaf and an umbrella group, Communications Equality Advocates, said adopting rules is critical to those with disabilities. “For more than a decade, CEA’s members have advocated for Commission endorsement and encouragement of technologies that our constituents require to achieve parity of communications with the rest of the population,” the groups said: “Ubiquitous deployment of NG911 will yield many benefits, including greater interoperability, system resilience, and improved connections between 911 call centers, and support for transmission of texts, photos, videos, and data, all of which are essential for CEA’s constituents.”