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Industry Raises Cost, Other Concerns on FCC NG911 Proposals

Industry continued to raise concerns on an FCC proposal on rules to speed a move to next-generation 911 and to call for flexibility, while public safety groups generally supported the agency’s proposed approach, per reply comments posted Monday in docket 21-479. The replies were consistent with initial comments last month (see 2308100025).

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T-Mobile said the FCC should consolidate proposals on location-based routing (LBR) and the transition to IP-based 911 calling. “Many of the questions the Commission has asked in this proceeding mirror questions it posed to wireless carriers earlier this year” on LBR (see 2212210047), the carrier said. Adopt “clear and unambiguous standards for determining readiness” by public safety answering points, T-Mobile said: “Prevent parties, including PSAPs and 911 Authorities, from engaging in arbitrage and shifting their costs to originating service providers" (OSPs).

Verizon agreed the proceeding addresses some of the same issues raised by LBR. “The Commission should adopt a new, flexible regulatory framework for IP delivery of 911 calls that promotes timely and efficient deployment through reasonable timetables for OSPs and meaningful readiness criteria for 911 Authorities and their vendors,” Verizon said. Any new rules should “accommodate critical differences between IP-enabled and legacy wireline OSP networks,” the provider said.

NTCA and others raised concerns about the costs of complying with the rules. The record shows the NPRM’s cost allocation proposal is based on “factual and technical errors: in particular, the failure to properly distinguish between separate elements of a voice network leads the NRPM to underestimate the costs that OSPs will assume,” NTCA said. The group warned these costs “will be significant and could impact universal service as voice rates will increase.” NTCA also questioned whether the FCC has the legal authority to impose proposed cost-allocation rules.

The Rural Wireless Association noted the NPRM estimates the costs for a wireless carrier to move the point of delivery of 911 traffic to a point designated by the 911 authority is only $44. “While this cost estimate may not be way off base with respect to what is required to change the address of the connection point in the switch, it completely ignores the costs of obtaining and installing the equipment needed to make that address change possible,” RWA said. The costs of buying the needed gateway is closer to $100,000, the association said: That’s “a significant capital expense that cannot be recovered from the small subscriber base (typically, ranging from 100 to 10,000 subscribers) served by RWA members.”

Flexibility Urged

The rules should allow for flexibility, since “variables and testing will be unique to each PSAP and OSP,” CTIA said. Obligations to deliver IP-based data and calls should be “premised on a level of ‘PSAP readiness’ that is substantially more detailed than the definition proposed in the NPRM,” the group said: Establishing a default demarcation point at the emergency services IP network (ESInet) level “would help provide certainty and minimize disputes that could hinder the deployment of NG911.”

USTelecom also called for flexibility. “There is widespread recognition in the record that legacy wireline (TDM) technology is different from IP-based technology and there are different technical challenges and policy considerations for each,” USTelecom said. The rules “must be flexible to account for differences in network capabilities and regulatory burdens, and the Commission therefore should adhere to its determination that providers of service on TDM networks need not originate calls in IP format,” the group said.

The Alaska 911 Advisory Board said the rules should accommodate the huge difficulties in providing service in areas like Alaska. The “wide variation in the building blocks of 911 services in Alaska means that it is critical that rules governing the deployment of NG911 not be one-size-fits-all,” the board said: “Timelines, readiness requirements, and exemptions should accommodate the reality that many areas lack the connectivity, [geographic information system] systems, and other resources required for NG911. Rules should not be placed on stakeholders which cannot reasonably be complied with.”

APCO called for a “comprehensive approach” by the FCC to promote the move to NG911. “The greatest impact the Commission can have … would be to require interoperability between OSPs and 9-1-1 service providers, and among 9-1-1 service providers,” APCO said. Several commenters stressed the importance of promoting competition, the group said: “Interoperability is perhaps the strongest driver of a competitive marketplace.”

A national registry denoting PSAP readiness to accept IP calls to 911 is “the only practical option” for expediting NG911, said the Boulder Regional Emergency Telephone Service Authority. “Given the number of OSPs and entities requesting delivery of 9-1-1 calls in NG9-1-1 compatible format, requiring individual notices would itself provide opportunity for OSPs to delay delivery of calls in NG911-compatible format, and distract PSAP personnel from their critical tasks,” the Colorado authority said.