Public Safety Seeks FCC Ruling on 911 Network Competition
The FCC should write detailed rules on 911 network competition, said public safety groups in comments responding to an FCC Wireline Bureau public notice. The notice arose out of two arbitrations involving interconnection disputes between competitive 911 network provider Intrado Communications and Embarq and Verizon (CD June 8 p6). However, some telecom companies said the broad issue of 911 competition should be dealt with in a separate proceeding.
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The FCC should put out for comment and adopt a “local competition type order” on 911 services and IP-enabled 911 systems, said APCO, the National Emergency Number Association and other public safety groups in joint comments. The order should tackle “the many issues that must be resolved to enable the transition” to a competitive IP-based E911 environment and full next-generation 911 systems, “including specific federal [911] statutes and regulations to ensure a consistent regulatory framework.”
Seeking comment on a broad policy issue in the context of an arbitration is “an unusual step,” admitted the public safety groups, but they praised the FCC for taking it. “The Commission has an opportunity to use this proceeding as a foundation to provide needed guidance and certainty in an increasingly complex and uncertain regulatory environment.” New rules would help states “to avoid unnecessarily continuing multiple case-by-case lengthy disputes that are each largely based on an interpretation of federal statutes and regulations.”
Intrado urged the FCC to write pro-competitive policies for the 911 market. “Given the consequential benefits to public safety and network reliability and furthering of the Commission’s interest in broadband development and market competition, competitive 911/E911 services will secure manifest advantages for consumers and public safety agencies alike,” it said.
But parties on the other side of the Intrado dispute said the arbitration proceeding was not the right vehicle for broad competition rules. “The only question the Bureau is asked to consider is whether, under the existing rules, Intrado is entitled to interconnection under Section 251(c), and if so, what terms should apply,” said Verizon, which urged the FCC to dismiss the Intrado petition. The Independent Telephone & Telecommunications Alliance, of which the former Embarq is a member, agreed: “More general questions regarding competitive provision of 911 services … are better suited to a general rulemaking or other proceeding.”
Meanwhile, AT&T said any new FCC rule should promote only facilities-based competition. Such competition “can promote investment and innovation in the present, Time Division Multiplex … technology-based 911/E911 services market, as well as the IP-based, next generation … market of the future,” the carrier said. The FCC shouldn’t apply unbundling rules to 911 networks, it said. That approach “is flawed because it chills investment and innovation (as the Commission itself has observed with respect to the market for local exchange services), which is particularly detrimental to 911/E911.”