Industry Disagrees With APCO on Need for NG911 Rules

The FCC should adopt interoperability requirements for NG911 “without delay,” APCO said. Interoperability is “a core component” of NG911, and the commission “should reject claims that it is premature to address interoperability given the limited state of NG9-1-1 deployment nationwide,” the group said. “In fact, the nascent state of deployment makes this the ideal time to adopt interoperability and reliability requirements.”

Delaying interoperability “by not adopting rules, or deferring issues to a task force or stakeholder group, risks embedding incompatibilities into early deployments,” APCO warned. The record also “underscores the need for the Commission to promote a common understanding of what interoperability means.” The group noted that there was no agreement in initial comments. “For the public safety community, interoperability is straightforward: the ability to exchange all forms of 9-1-1 traffic without the need for costly, after-the-fact proprietary interfaces, and regardless of jurisdiction, vendors, and equipment used.”

Brian Rosen, who chairs a National Emergency Number Association working group on the i3 911 standard, said some commenters argue that rules would be premature and further study is needed. “Since I know the details of many if not most of the significant failures in NG9-1-1 systems in the last several years, I can say with certainty that there is little to be gained, and much to be lost by delaying.”

But CTIA found “a clear consensus … among public safety and industry stakeholders that the Commission should not address modifications or reforms to its outage reporting rules here, but rather do so in a separate, comprehensive proceeding.” The group disagreed with APCO about the need for rules addressing interoperability. “The record demonstrates that interoperability obligations would be premature while public safety and industry stakeholders are working to develop standards that will facilitate interoperability and other NG911 capabilities.”

The record reflects “broad consensus” in support of a cautious approach to the rules, USTelecom commented. “Premature action at this stage would risk disrupting the careful balance the Commission struck in the [NG911] Transition Order, ultimately slowing progress toward a nationwide NG911 system.” There’s no “established model or specification for interoperability testing in NG911,” the group added. Absent a baseline testing framework or accepted methodology, it’s “unclear how interoperability could be measured or demonstrated in a consistent manner.”

The FCC’s existing rules “already impose sufficient reliability obligations on both affiliated and non-affiliated vendors, including Next Generation Core Services Providers and Originating Service Providers,” said the Industry Council for Emergency Response Technologies. Interoperability standards would be “premature” as NG911 is being deployed, it added. “Instead of prematurely implementing static interoperability rules, the Commission should focus on encouraging industry adoption of the interoperability guidance set forth in commonly accepted NG911 standards and continue facilitating the development of best practices through public-private collaboration and coordination.”

NCTA also said adopting detailed NG911 reliability and interoperability requirements “would be premature at this time.” Instead, the group called on the FCC to convene “an industry working group to consider whether additional rules are needed after the NG911 transition is further along.”

Bandwidth, a company offering a communications platform, said “stakeholders from all sides of the industry agree” with its opening comments “that the complexity of deploying NG911 must be dealt with before imposing any new regulatory obligations.” The FNPRM’s “proposed prescriptive rules will only further complicate the already extremely complex and drawn-out transition to NG911.”

T-Mobile proposed defining interoperability as “the technical and operational capability of NG911 systems, networks, and services to exchange 911 voice, text, data, and multimedia between jurisdictions, [public safety answering points], and service providers, in real time and in a format consistent with commonly accepted NG911 standards.” That definition “reflects both technical feasibility and public safety expectations” and “recognizes that interoperability is not merely a matter of compliance with a given standard, but a practical, outcome-oriented necessity for seamless emergency communications,” T-Mobile said. Verizon said there’s “no regulatory gap” that the FCC must address.

By broadening the definitions of "covered 911 service provider" and “physical diversity,” the proposed expanded requirements "would drive NG911 operational costs to untenable levels,” Lumen said. The FCC also should decline “to adopt requirements that would escalate … costs with no corresponding benefit, or that have little or no discernible nexus to safeguarding NG911 reliability.”