The NPRM proposes three new rules. First, the FCC proposes to require wireline carriers, interconnected Voice over Internet Protocol (VoIP) providers, and Internet-based Telecommunications Relay Service (TRS) providers, to complete all translation and routing to deliver 911 calls, along with the associated location information, in the IP-based format compatible with NG911 to an Emergency Services IP network (ESInet) or other designated point(s). This new proposed requirement, referred to as the “IP Service Delivery Requirement,” means that providers must ensure that their infrastructure supports translating and routing 911 calls in the IP-based format required by the requesting 911 authority. Simply put, providers would need to invest in the appropriate software and network upgrades to ensure compatibility with NG911. The FCC proposed a similar requirement for Commercial Mobile Radio Service (CMRS) providers in another proceeding.
Furthermore, the proposed rules would not require TDM-based carriers to originate 911 calls in IP-based format on their own networks. However, the proposed rules would require such calls to be converted to an IP-based format for delivery to the ESInet or other designated point(s) once a 911 authority has made a valid request to receive IP-formatted calls.
Second, the proposed rules would require wireline carriers, VoIP providers, TRS providers, and CMRS providers to send all 911 calls to the points of interconnection specified by the 911 authority. These locations include PSAPs, designated statewide default answering point, local emergency authority, ESINet, or other point(s) designated by 911 authorities. The FCC believes this will resolve disputes regarding the interconnection point(s) to which providers must be responsible for cost of delivering traffic. There have been many disputes concerning proposed interconnection points that are outside the LATA, outside the State, and sometimes several states away.
Third, the FCC proposes to require wireline carriers, VoIP providers, and TRS providers to be “presumptively responsible” for the costs of delivering traffic in the IP-based format to the interconnection point(s) dictated by the 911 authority.
Fourth, the FCC is proposing to require providers to include the associated location information in the call path, which would replace the ALI database. However, the NPRM fails to address how this would work for wireline carriers who still provide TDM services with limited ability to identify a specific address automatically, if at all. The NPRM also does not propose or define where the location information would be generated or the costs for providers to include the associated location information.
The NPRM notes that states and localities could establish alternative cost allocation agreements with the providers to handle all or a portion of these IP equipment, transport and location costs required of wireline, VoIP, and TRS providers; however, in the absence of such agreements, the responsibility of covering the costs would fall on the local providers not on the 911 network owners.
The FCC also seeks comment on definitions for the terms NG911, ESINet, as well as whether to implement new compliance and reporting requirements.
Finally, the NPRM estimates one-time expenses for all 2,327 wireline and CMRS providers to upgrade their systems and transition to the ESInet to cost only about $103,000 in total. The NPRM further states that increased ongoing costs would be experienced only by a small percentage of providers who do not yet have IP switching facilities for voice traffic. These costs seem exceptionally low and uninformed for making such significant changes made in the NG911 network.
As proposed in the NPRM, telecom and VoIP providers would have to comply with the IP Service Delivery Requirement within six months from the date the requirement becomes effective or six months after a valid request for IP-based service by a state or local 911 authority, whichever is later.
The NPRM gives Internet-based TRS providers a longer time period to comply − twelve months from the effective date of the IP Service Delivery Requirement or twelve months after a valid request for IP-based service by a state or local 911 authority, whichever is later.
Tell The FCC This Will Cost Your Business More than $103,000.
The most effective way for clients to persuade the FCC to lessen the burden on small and rural providers is by filing comments and participating in ex parte meetings with FCC staff. To assist our clients with this endeavor, we are prepared to help your company determine estimated costs associated with transitioning to NG911 and file individual or joint comments with other JSI clients to ensure that the FCC understands the significant burdens that will be placed on small and rural providers if the agency adopts the requirements as proposed.
Comments on the NPRM are due 30 days after they have been published in the Federal Register, with replies due 30 days after the comment filing deadline.