Industry and Public Safety Agree on Need for Cautious Approach to Spur NG911
Most commenters emphasized the importance of flexibility and developing rules that will accommodate change in comments on a next-generation 911 Further NPRM that commissioners approved 4-0 in March (see 2503270042). Initial comments were due Monday in docket 21-479. The FNPRM proposes updates to the agency’s 911 reliability rules, extending those that cover legacy 911 networks to service providers that control or operate critical pathways and components in NG911 networks.
Sign up for a free preview to unlock the rest of this article
Communications Daily is required reading for senior executives at top telecom corporations, law firms, lobbying organizations, associations and government agencies (including the FCC). Join them today!
NTCA, joined by smaller rural local exchange carrier groups, said industry requires “clear rules that promote the reliability of interconnections of all kinds between operators, including, of course, for reliable routing of emergency 911 calls.” NTCA also urged clarification regarding the proposed NG911 reliability framework “to ensure consistent compliance with concrete, common sense, and readily understandable quality of service and reliability standards for 911 calls.” Clear rules are needed “to avoid confusion as to where the responsibility resides for preventing in the first instance, and rectifying should they arise, NG911 call completion issues,” the filing said.
USTelecom told the FCC it’s too early to hand down rules. “Imposing premature, prescriptive rules risks undermining the collaboration and innovation necessary to a successful transition,” the group said. “USTelecom cautions the Commission against adopting more rules before we have had the opportunity to see the impact of the Commission’s Order facilitating NG911 implementation.”
Verizon noted that the commission’s 911 and outage reporting rules and policies already hold originating service providers (OSPs) “responsible for reliable 911 call delivery and network design practices, regardless of whether they self-provisioned those facilities, or instead procured them from third party providers.”
The March FNPRM “unnecessarily blurs those responsibilities and adds uncertainty into industry’s NG911 implementation efforts,” Verizon said. It also “erroneously reasons that new NG911 configurations create potential regulatory gaps; rather, established rules and policies governing the use of underlying third-party transport and solution vendors squarely address this issue.” Reclassifying OSPs as covered service providers “would impose new regulatory burdens with little if any improvement to reliable 911 call delivery,” Verizon said.
“Avoid blurring the respective obligations of OSPs and covered 911 service providers,” CTIA advised. The commission “already requires OSPs to ensure that 911 communications, including NG911, are reliably delivered to the appropriate” public safety answering points, the group said. Those obligations “achieve the NG911 reliability goals the Commission seeks here.”
T-Mobile warned against “prescriptive regulatory mandates that bypass the industry’s robust consensus-based standards process.” Interoperability can be best advanced “through the leadership of Standards Development Organizations, where industry stakeholders collaboratively develop, validate, and evolve technical standards based on real deployment challenges.”
The Industry Council for Emergency Response Technologies said revised rules should “avoid overly prescriptive or static classifications that could inadvertently limit innovation or conflict with standards-based implementation.” An efficient transition from legacy 911 systems to NG911 is “important and will only become increasingly significant as copper retirement accelerate,” the council said. But the FCC should also take “a light-touch regulatory approach given the significant differences between legacy and NG911 systems.”
The Association of Public-Safety Communications Officials called for a “comprehensive, technology-neutral approach” to NG911. While some jurisdictions have implemented emergency services IP networks (ESInets), APCO cautioned “that the deployment of ESInets should not be considered the equivalent of the deployment" of NG911, and the networks will be “comprised of more than just ESInets.”
APCO said addressing interoperability “is the most important step the Commission can take to facilitate the transition" to NG911. Too often, NG911 problems are the result of “proprietary … solutions that can only interoperate by bolting on prohibitively costly, after-the-fact upgrades.” While interstate interoperability poses the biggest challenges, intrastate interoperability problems also “persist,” the group said.
The FNPRM “rightly acknowledges that its framework for outage reporting reflects an aging view of telecommunications,” the National Emergency Number Association said. The item seeks comment on rule changes to address failures downstream of the OSP but upstream of the ESInet, NENA said, adding that the failures are a significant problem. “NENA’s team has consulted with several states that have had repeated widespread outages in this area where they claim that the ESInet and the Next Generation 9-1-1 Core Service was operating without any flaws,” the group said. “However, wide swaths of the state were unable to place 9-1-1 calls.” States have seen “significant outages of their entire NG9-1-1 systems where software failed in an optical network.”