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Specifically, Maine asked for clarification as to the point of demarcation for text-to-911 between wireless providers and Maine’s next-generation 9-1-1 (NG 9-1-1) system.
As part of its planned migration to NG 9-1-1, Main undertook, on an interim basis, to provide text to 9-1-1 via teletypewriter (TTY) on its legacy enhanced 9-1-1 (E9-1-1) platform to enable individuals who are hearing impaired or deaf to contact 9-1-1. Maine implemented the interim text-to-9-1-1 solution at two of the state’s public-safety answering points (PSAPs), tasked with answering 9-1-1 texts for the entire state from the five wireless carriers that provide service in Maine.
In October 2015, following its deployment of a “statewide end-to-end NG 9-1-1 system,” it began “working with wireless carriers and their respective text control centers (TCCs) on migrating from 9-1-1 via TTY to 9-1-1 to text via MSRP using Maine’s National Emergency Number Association (NENA) i3 compliant system.”
In response to its deployment request, Maine received conflicting proposals from two TCCs. One TCC responded to the deployment request with a pricing proposal for multiprotocol label switching (MPLS) connectivity “that included a one-time project charge, monthly recurring charges for a three-year contractual period, and recurring monthly costs for dedicated MPLS circuits,” all to be paid by Maine.
Maine regarded the proposed pricing as “unreasonably high,” and requested an alternative proposal using a virtual private network (VPN). The TCC then submitted a VPN-based pricing proposal with “recurring monitoring charges.”
The other TCC “expressed a preference for connecting via VPN as opposed to MPLS circuits and thus far has not requested compensation for the use of VPN.”
Noting the “disagreement among TCCs about both the preferred technology and the cost of providing text to 9-1-1 via IP,” Maine said that “[t]he root cause of this issue appears to be the point of demarcation between carriers and Maine's emergency services IP network (ESInet).”
Maine said that “the point of demarcation should be at the ingress designated by the session border controller (SBC) of the state of Maine ESInet,” but contends that the TCCs, “acting on behalf of wireless carriers, argue that the point of demarcation should be the egress side of the SBC used by the TCCs.”
Maine seeks the FCC’s assistance “in resolving this conflict regarding the delivery of interim text to 9-1-1 via MSRP by clarifying where the point of demarcation is between wireless providers and Maine's NG 9-1-1 network to appropriately assess costs.”
In support of its proposed demarcation point definition, Maine cites the FCC’s 2001 King County decision, which identified the demarcation point between wireless service providers and PSAPs in the legacy E9-1-1 environment as the input to the 9-1-1 selective router. Maine asserts that “in the NG 9-1-1 environment, the equivalent to the E9-1-1 selective router would be the state ESInet SBC, not the TCC’s SBC.”
Maine said “it should be the wireless carriers' responsibility to carry the cost of delivering text-to-911 for their customers to our network, just as the carriers are required to do for regular 911 service.”
Comments are due Feb. 8, and reply comments are due March 10. The full public notice is here.
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