In the April 26, 2024, edition of the ICORE Blog, we discussed an FCC NPRM related to the transition to Next Generation 911 (NG911). On July 18, 2024, the FCC adopted a Report and Order (R&O) relative to NG911. In the R&O the FCC adopts rules that will require wireline providers, CMRS providers, covered text providers, interconnected VoIP providers and providers of Internet-based TRS (collectively “originating service providers” or OSPs) to take action to start or continue the transition to NG911 in coordination with 911 Authorities. The Rules provide for a two-phased approach for the transition to NG911. Each phase is initiated by a 911 Authority submitting a valid request to OSPs within the jurisdiction where the Authority is located for the OSPs to comply with NG911 requirements as follows:
Phase 1: Upon receiving a valid Phase 1 request from a 911 Authority, an OSP must begin delivery of 911 traffic in IP-based Session Initiation Protocol (SIP) to one or more in-state NG911 delivery points designated by the 911 Authority.
Phase 2: Upon receiving a valid Phase 2 request from a 911 Authority, the delivery of NG911 traffic to the designated in-state NG911 Delivery Point(s) in IP-based SIP format must include location information embedded in the call signaling using Presence Information Data Format – Location Object (PIDF-LO) or the functional equivalent. In addition, in Phase 2 the OSP must install and put into operation all equipment, software applications, and other infrastructure, or acquire all services, necessary to use a Location Information Server (LIS) or its functional equivalent for the verification of its customer location information and records.
From a timing perspective, Nationwide CMRS providers, covered text providers, interconnected VoIP providers, and wireline providers other than rural incumbent LECs (RLECs) will have six months following a valid Phase 1 request from a 911 Authority to comply with Phase 1 requirements and six months from a valid Phase 2 request to comply with Phase 2 requirements. RLECs, non-nationwide CMRS providers, and Internet-based TRS providers will have one year to comply with Phase 1 requirements following a valid Phase 1 request and 1 year to comply with Phase 2 requirements following a valid Phase 2 request. Completion of Phase 1 is a prerequisite to the commencement of Phase2, however, if an OSP completes the requirements for Phase 1 prior to the six month or one year period, Phase 2 can commence immediately. The R&O stipulates that in order to facilitate collaboration between OSPs and 911 Authorities, OSPs and Authorities are permitted to enter into mutual agreements that modify the Phase1/Phase 2 terms and timelines and the FCC’s rules presumptively do not alter or invalidate such agreements that already exist.
The R&O also addresses the key issue of responsibility for the costs of transitioning to NG911. The R&O stipulates that in the absence of an alternative cost arrangement implemented by a 911 Authority at the state or local level, OSPs will be financially responsible for the costs of transmitting 911 traffic to the NG911 Delivery Points designated by 911 Authorities beginning with Phase 1. As such the 911 Delivery Points are established as the demarcation points where the OSP’s responsibility for the cost of transmitting 911 traffic ends and the 911 Authority’s responsibility begins. In addition, in both Phase1 and Phase 2, OSPs are responsible for the costs of translating 911 traffic into the required IP-based format, including associated routing and location information.
The above is a high-level overview of the nearly 160 page R&O. Should any of our readers have specific questions not addressed above, please let us know and we’ll endeavor to provide additional information as required.
