Next Generation 911 (NG911) service has largely replaced legacy 911-time division multiplexing technology nationwide. It utilizes Internet Protocol (IP) technology to support new 911 capabilities, including using text, video, and data. However, the FCC is concerned that for NG911 service to be fully effective, all network components need to be reliable and there must be complete interoperability between networks when calls are handed off from one to another. Therefore, at its upcoming March 27, 2025, meeting, the Commission is poised to adopt a Further Notice of Proposed Rulemaking (Further Notice) in Docket 21-479 to ensure that NG911 is as effective going forward as possible. Industry comments on the Further Notice will be due 45 days after it appears in the Federal Register.
Here is what the Further Notice proposes:
Update the definition of covered 911 service provider (CSP) in the Commission’s existing 911 reliability rules to ensure that the rules apply to service providers that control or operate critical pathways and components in NG911 networks. According to the Commission:
The current CSP definition focuses on providers of certain network facilities and capabilities that are specific to legacy 911 systems and states that the rules also apply to their “functional equivalents” in the NG911 environment. We propose to specify that certain critical NG911 facilities and capabilities (e.g., Location Validation Functions (LVFs), Geographic Information Systems (GISs), Emergency Call Routing Functions (ECRFs), Emergency Services Routing Proxies (ESRPs), and Policy Routing Functions (PRFs)) are among the functional equivalents referred to in the current rule and that providers of these capabilities therefore fall within the definition of CSPs.
We also propose to expand the CSP definition to encompass the following types of providers of critical connectivity in the NG911 environment: (1) operators of Location Information Servers (LISs) or equivalent IP 911 location databases; (2) operators of Legacy Network Gateways (LNGs); (3) operators of interstate Major Transport Facilities that meet or exceed Optical Carrier 3 (OC3) capacity and carry 911 traffic from multiple OSPs for ultimate delivery to NG911 Delivery Points or ESInets; (4) operators of IP Traffic Aggregation Facilities that carry segregated 911 traffic from multiple OSPs towards ultimate transmission to an NG911 Delivery Point or ESInet [Emergency Service IP network]; and (5) operators of interstate interconnecting facilities between ESInets. (Further Notice Draft, pp. 3-4.
Update the reliability standards for providers of critical NG911 functions to ensure the reliable delivery of 911 traffic to NG911 delivery points. New standards include network physical diversity, monitoring and operational integrity.
Establish NG911 interoperability requirements for interstate transfer of 911 traffic between ESInets to ensure Public Safety Answering Points (PSAPs) can transfer 911 calls and call data to other PSAPs across state borders when necessary. Specifically, the agency proposes to require that CSPs certify whether their interstate interconnecting ESInet facilities achieve interoperability for exchanged 911 traffic sufficiently to enable complete interstate transfers between ESInets.
CSPs would annually certify whether their interstate interconnecting ESInet facilities use conformance-tested equipment and whether they have tested their interstate interoperability capabilities. If a CSP cannot certify to these elements, we propose to require the CSP to certify with respect to those facilities: (1) whether it (or its ESInet facility operator) has taken alternative measures to ensure interoperability between ESInets in multiple states and between providers; (2) whether it believes that one or more of the requirements of this paragraph are not applicable to its facilities; and (3) to additional questions about the non-conforming facilities as directed by the Bureau. (Id., p. 30)
Empower state and local 911 Authorities to obtain reliability and interoperability certifications directly from covered 911 service providers, so that 911 Authorities can more easily address reliability and interoperability concerns within their jurisdictions. Thus, all 911 Authorities are entitled to receive, upon request to the CSP, the annual reliability and interoperability certifications filed with the Commission directly from CSPs operating in their jurisdictions.
The FCC estimates that the costs of the proposed rules will be limited “in light of the independent factors of technological advancement, ordinary market forces, and prior Commission actions, all of which will accomplish a substantial portion of the reliability and interoperability improvements we seek today for certain networks.”
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