By: Andy Regitsky
On June 8, 2023, the FCC is expected to adopt a Notice of Proposed Rulemaking (NPRM) in Docket 21-479 which would require wireline, interconnected Voice over Internet protocol (VoIP), and Internet-based Telecommunications Relay Service (TRS) providers, to deliver 911 calls and texts in IP format upon request of Next Generation 911 (NG911) capable 911 authorities. This follows a proposal released in December 2022, which would similarly require Commercial Mobile Radio Service (CMRS) providers to deliver NG911 calls in IP format.
The Commission explains its rationale for the NPRM:
With the transition to Next Generation 911 state and local 911 authorities are replacing legacy circuit-switched 911 networks with Internet Protocol based networks and applications that will support new 911 capabilities, including text, video, and data, as well as improved interoperability and system resilience. Completing the NG911 transition will also require originating service providers to format 911 calls to be compatible with NG911 and to deliver the calls to new destination points established by 911 authorities. As state and local 911 authorities have begun to invest significantly in NG911, some have reported that originating service providers are refusing to connect to these destination points or are otherwise delaying the transition process, which imposes additional costs and delays on 911 authorities. (NPRM, Fact Sheet).
In the NPRM, the agency takes the following actions:
First, the Commission proposes to require wireline, interconnected VoIP, and Internet-based TRS providers to complete all translation and routing to deliver 911 calls, including associated location information, in the requested IP-based format to an Emergency Services IP network (ESInet) or other designated point(s) that allow emergency calls to be answered upon request of 911 authorities who have certified the capability to accept IP-based 911 communications.
Wireline and interconnected VoIP providers would be subject to this requirement six months from the effective date of the IP service delivery requirement, or six months after a valid request for IP-based service by a state or local 911 authority, whichever is later.
Internet-based TRS providers would be subject to this requirement twelve months from the effective date of the IP service delivery requirement, or twelve months after a valid request for IP-based service by a state or local 911 authority, whichever is later. As noted above, this proposal is like the requirements proposed for CMRS providers and covered text providers made in December.
Second, as state and local 911 authorities transition to IP-based networks, the FCC proposes to require wireline, interconnected VoIP, CMRS, and Internet-based TRS providers to transmit all 911 calls to destination point(s) in those networks designated by a 911 authority, including to a public safety answering point (PSAP), designated statewide default answering point, local emergency authority, ESInet, or other point(s) designated by 911 authorities that allow emergency calls to be answered, upon request of 911 authorities who have certified the capability to accept IP-based 911 communications.
Third, the Commission proposes that in the absence of agreements by states or localities on alternative cost recovery mechanisms, wireline, interconnected VoIP, CMRS, and Internet-based TRS providers must cover the costs of transmitting 911 calls to the point(s) designated by a 911 authority, including any costs associated with completing the translation and routing necessary to deliver such calls and associated location information to the designated destination point(s) in the requested IP-based format.
States and localities would remain free to establish alternative cost allocation arrangements with providers. However, in the absence of such arrangements, providers would be presumptively responsible for the costs associated with delivering traffic to the destination point(s) identified by the appropriate 911 authority.
The Commission notes that “[t]ogether, these proposals are intended to expedite the NG911 transition and help ensure that the nation’s 911 system functions effectively and with the most advanced capabilities available.”
To read the full FCC fact sheet on the proposed rule click here.
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