The FCC Seeks Comment on Nationwide Implementation of Next Generation 911 Services

FCC Proposed NG911 Changes Could Shift Costs to LECs.

Last week, the Federal Communications Commission (FCC) adopted a Notice of Proposed Rulemaking (NPRM) proposing new rules to require communications service providers to transition to Internet Protocol (IP)-based trunks for Next Generation 911 (NG911), allow meet points for 911 interconnection trunks to locations outside the state, and require providers to transmit location information within the call path instead of through the Automatic Location Information (ALI) database. The NPRM also proposes a six-month timeframe after a certified request from a 911 authority or from the effective date to complete implementation, whichever is later.  Each of these proposed requirements are likely to add significant costs to rural carriers’ provision of NG911 service. In the absence of a state or local cost recovery mechanism for these NG911 costs, the FCC proposed that all costs to implement this transition be borne by the LECs.

Under the existing 911 system, 911 calls travel on dedicated Time Division Multiplex (TDM) 911 networks to reach a selective router that directs the call to the closest Public Safety Answering Point (PSAP) or 911 call center, which in turn can dispatch aid. NG911 promises to support new and enhanced 911 capabilities, including text, video, and data, as well as more resilient IP infrastructure. The NPRM proposes rules that will clarify hurdles encountered in several states during the nationwide transition to NG911.

What the FCC is Proposing

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.

Implementation Timeline

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.

If you are interested in learning more about the impact of these proposed rules or would like to file comments please contact Jennifer Holtz, VP, Regulatory Affairs Department, either by clicking the button below to connect with her by email or by calling 301-459-7590 during normal office hours.

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