On March 27, 2025, the FCC adopted a Further Notice of Proposed Rulemaking (FNPRM) related to NG911. The FNPRM looks to build on the Commission’s July 2024 NG911 Transition Order (see ICORE Blog dated 11/26/24) which addressed the delivery of 911 traffic in IP format. The FNPRM seeks comment on proposed rule changes to both facilitate the NG911 transition and ensure that the transition does not inadvertently create vulnerabilities in critical public safety networks.
The FNPRM proposes to update the Commissions existing 911 reliability rules to ensure that they apply to service providers that control or operate critical pathways and components in NG911 networks. Further, comment is sought on proposals to update the reasonable reliability standards that providers of critical NG911 functions must employ to ensure the reliable delivery of 911 traffic to NG911 delivery points. The Commission believes that the proposed rule modifications are needed to ensure the reliability of critical functionality including transport, aggregation, and data facilities in the NG911 system at the interstate and national level and the accessibility of NG911 services.
Additionally, the FNPRM proposes to establish interoperability requirements for the interstate transfer of 911 traffic between ESInets to optimize PSAP call transfer capabilities during service disruptions. The Commission seeks to ensure that PSAPs can transfer calls to nearby PSAPs located across state lines with minimal need for calls to be retranslated or reformatted in order for such transfers to occur. Comment is also sought on a proposal to modify the current reliability certification rules by adding an interoperability certification requirement. Finally, the FNPRM seeks comment on proposed modifications to the certification and oversight mechanisms in the existing 911 reliability rules to improve implementation of reliability and interoperability in NG911 systems. In that regard, the Commission proposes to allow state and local 911 Authorities to obtain reliability and interoperability certifications directly from providers so that they can more easily exercise their existing authority within their jurisdictions.
Comments to the FNPRM have recently been filed by interested parties. On August 4, 2025, NTCA and various Rural Local Exchange Carrier groups (NTCA et al) filed joint comments in this proceeding seeking clarification in two specific areas. NTCA et al submit that the FNPRM lacks clarity as to whether state Public Service Commissions, state 911 Authorities, or the FCC bears ultimate responsibility for oversight and enforcement with respect to network reliability and NG911 call completion. NTCA et al believes that this uncertainty as to the jurisdiction for oversight and enforcement could undermine the assurance that a 911 call will be delivered successfully. Further, NTCA et al seek clarification affirming that state 911 authorities and NG911 Network Providers cannot pass on to originating service providers any compliance costs that they may incur as a result of the adoption of the proposed changes contained in the FNPRM. USTelecom also filed comments in this proceeding. While supporting the Commission’s goal of a more reliable NG911 system, USTelecom urged the Commission to refrain from imposing additional regulatory mandates at this time until stakeholders gain more operational experience under the new NG911 framework created by the July 2024 NG911 Transition Order.
Reply comments in this proceeding are due September 17, 2025. We will continue to monitor this important issue and provide updates as more information becomes available.
