NASNA Petitions FCC for Rulemaking to Assist in NG 9-1-1 Implementation, Transition
Monday, October 25, 2021 | Comments

The National Association of State 911 Administrators Association (NASNA) filed a petition with the FCC, asking it to start a rulemaking to assist with the implementation of and transition to next-generation 9-1-1 (NG 9-1-1) across the nation.

NASNA asked the FCC to several specific actions including establishing commission authority over originating service providers’ (OSPs) delivery of 9-1-1 services through IP-based emergency services networks (ESInets), amend the commission’s rules to advance the transition to and implementation of NG 9-1-1 and require the cost of compliance to be OSPs’ responsibility.

NASNA said that the FCC establishing its authority over other technological advances such as wireless 9-1-1, Z-axis, text to 9-1-1 and VoIP played key roles in the development and deployment of those technologies.

“Without the commission’s direct involvement, the notable advances made in 9-1-1 services would have been interminably delayed if not foreclosed,” the filing said.

The organization said that amending FCC regulations would not only confirm FCC authority over NG 9-1-1 service but would also clarify the role of FCC in the NG 9-1-1 transition.

For the cost of compliance issue, NASNA said it should be like it was with the implementation of wireless enhance 9-1-1 service, text to 9-1-1 and real-time text, where cost of compliance was the responsibility of OSPs, except for where cost recovery was provided for by state law or regulation.

“Any action of the commission should clearly be established in a manner that does not pre-empt state/local authority over 9-1-1, including existing 9-1-1 cost-recovery mechanisms, but to serve rather as a ‘floor’ of required services by carriers to establish a baselines for 9-1-1 delivery in the emerging environment of NG 9-1-1,” the NASNA filing said.

NASNA also said the FCC should consider adding an NG 9-1-1 readiness registry to its existing text-to-9-1-1 or public-safety answering point (PSAP) registries. The FCC could also combine the two and add a NG 9-1-1 registry, the organization said.

“While the aforementioned registries are voluntary, we believe having a NG 9-1-1 registry would be a meaningful tool for state and local 9-1-1 authorities and OSPs to use to advance the implementation of NG 9-1-1,” the filing said.

If the FCC does not go that route, NASNA recommended establishing NG 9-1-1 readiness stages or phases that state or local 9-1-1 authorities and OSPs could use for transitioning to NG 9-1-1 service.

“Without action from the commission, it is difficult to envision how full nationwide implementation of NG 9-1-1 can be achieved,” the filing said. “With the commission’s support and direction, however, NG 9-1-1 can be implemented in a timely and coordinated manner that will provide a better result for the citizens who call 9-1-1 every day and rely on 9-1-1 to provide them with the emergency services they require.”

Find the full petition here.

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