On June 18, the Federal Communications Commission (FCC) adopted Report and Order (RO) FCC 24-78 which aims to advance the transition to Next Generation 911 (NG911). Unlike the traditional 911 service, NG911 uses IP-based format and routing to allow for the sending of texts, photos, and videos to 911 centers. The RO describes the multi-phase approach, readiness criteria, implementation deadlines, and cost allocation for the two phases of implementation. However, because the RO simply creates default rules and deadlines, Originating Service Providers (OSPs) and 911 Authorities are permitted to amend the provided rules and deadlines if the parties agree to the other terms.
Helpful Definitions
“NG911 Delivery Points” – A geographic location, facility, or demarcation point designated by a 911 Authority where an originating service provider shall transmit and deliver 911 traffic in an IP format to ESInets or other NG911 network facilities
“911 Authority” – A state, territorial, regional, Tribal, or local government entity that operates or has administrative authority over all or any aspect of a communications network for the receipt of 911 traffic at NG911 Delivery Points and for the transmission of such traffic from that point to Public Safety Answering Points (PSAPs)
“Phase 1” – The phase that establishes the transmission platforms required for implementing Phase 2
“Phase 2” – The phase in which the use of NG911 Core Services (a collection of NG911 functions designed to allow for seamless communication and collaboration between telecommunicators and the public safety industry) begins
The Framework
Phase 1
When a 911 Authority provides a request to begin Phase 1, an OSP must begin delivering 911 traffic in IP-based Session Initiation Protocol (SIP) format to in-state NG911 Delivery Points designated by that 911 Authority.
Before providing a request to begin Phase 1, the 911 Authority must certify that it has the necessary infrastructure to receive 911 traffic in SIP format and transmit it to PSAPs. The 911 Authority must also identify the NG911 Delivery Points it will be using and relay that information to the OSPs.
Phase 2
When a 911 Authority provides a request to begin Phase 2, an OSP must begin delivering 911 traffic to the in-state NG911 Delivery Points designated in Phase 1 in an IP-based SIP format that complies with NG911 commonly accepted standards identified by the 911 Authority.
Prior to providing a request to begin Phase 2, the 911 Authority must certify that it can receive 911 traffic in SIP format that is compliant with NG911 commonly accepted standards, as well as the ability to transmit that traffic out to PSAPs. The 911 Authority must also certify that its ESInet is connected to an NG911 Core Services network.
Implementation Deadlines
Upon a valid request to begin Phase 1, one group of entities will have six months until the implementation deadline (Nationwide CMRS providers, covered text providers, interconnected VoIP providers, and wireline providers other than RLECs), while others will have 12 months (Non-nationwide CMRS providers, RLECs, and Internet-based TRS providers).
For Phase 2, the same groups will have the same amount of time (six or 12 months) after the latest of (a) the 911 Authority’s valid request to begin Phase 2; or (b) the date when the OSP is required to comply with Phase 1 requirements, or when it does comply with those requirements (whichever is earlier).
However, it is important to remember that the implementation deadlines provided in the RO are the default; 911 Authorities are free to establish alternative provisions within their jurisdictions.
Cost Allocation
In the absence of alternative costs arrangements, the OSPs will be financially responsible for the costs of transmitting 911 traffic to the NG911 Delivery Points, but the 911 Authorities will be responsible for processing and transmitting the traffic received by the NG911 Delivery Points to the PSAPs.
Conclusion
The International Association of Fire Chiefs would like to express our appreciation to the FCC for moving this impactful service forward. The IAFC will continue to work closely with the FCC on the further development and implementation of NG911 as we are committed to strengthening our membership’s ability to respond to emergencies safely and effectively by providing them with the most useful information before even arriving on-scene.
By: John Drummond, Government Relations Legal Intern, IAFC Government Relations & Policy