9-1-1 Organizations, Service Providers Grapple Over NG 9-1-1 Transition Costs, Authority
Thursday, February 10, 2022 | Comments

Public-safety agencies and organizations and originating service providers (OSPs) sparred over FCC authority and cost responsibility in comments on a National Association of State 9-1-1 Administrators (NASNA) petition asking the commission to help advance the next-generation 9-1-1 transition (NG 9-1-1) in the U.S.

The NASNA petition requested that the commission begin a rulemaking or inquiry to help facilitate the implementation of and transition to NG 9-1-1 services. The NASNA petition asked for four specific FCC actions:
• Establish FCC authority over OSP delivery of 9-1-1 service through emergency services IP networks (ESInets),
• Amend portions of its rules to advance the transition and implementation of NG 9-1-1 service,
• Create a NG 9-1-1 Readiness registry, that would either be part of either the existing text-to-9-1-1 registry or the public-safety answering point (PSAP) registry, or as part of a combination of the two registries with NG 9-1-1 readiness information added, and
• Require OSPs bear the responsibility for the cost of compliance to NG 9-1-1, except for areas where cost recovery is provided by state law or regulation.

“Unfortunately, after years of effort and hundreds of millions of dollars spent by state, regional and local authorities, no part of the country can be described as having achieved this vision of NG 9-1-1 with end-to-end broadband communications for ECCs,” APCO’s filing said. “We’d be doing a disservice to the public and the nation’s dedicated public-safety communications professionals to claim that NG 9-1-1 has been successfully deployed in any state, let alone several states.”

APCO noted that NG 9-1-1 progress should be evaluated not just by tracking reports of ESInet deployments.

“First, having a functioning ESInet in place does not mean NG 9-1-1 has been fully deployed,” APCO’s comments said. “ESInets can provide some advanced capabilities but do not provide the end-to-end capabilities needed for ECCs to achieve the full vision for NG 9-1-1. Further, even without a functioning ESInet in palce, some ‘next generation’ capabilities such as real-time text (RTT) can be achieved, and some ECCs have begun using over the top solutions for capabilities like video-to-9-1-1.”

APCO also argued that emergency services IP network (ESInet) deployments suffer from widespread problems including being unable to deliver multimedia or reliably deliver voice calls, being unable to interoperate with PSAP call-handling equipment; and being unable to interoperate with other ESInets to transfer calls and data.

APCO said that the commission can help address these issues and said that several next-generation capabilities should be advanced through FCC action. For example, APCO said the commission should proceed with a notice of proposed rulemaking (NPRM) to require interoperability and location-based routing.

“One of the challenges in facilitating NG 9-1-1 has been disagreement over what NG 9-1-1 is and how it should be achieved,” APCO’s filing said. “The vision for NG 9-1-1, as defined by the public-safety community and expressed in federal legislative proposals, is an interoperable, secure system for emergency communications end to end. The commission should adopt this vision and take a correspondingly comprehensive view of the opportunities for reasonable regulations to advance public safety.”

The National Emergency Number Association (NENA) said that the FCC taking jurisdiction over OSPs in regards to NG 9-1-1 would fall in line with the commission’s modernization of 9-1-1 rules.

“Lack of commission jurisdiction contributes to uncertainty with respect to service and outage reporting requirements and may contribute to industry and technology distortions as vendors seek to avoid regulatory change,” NENA’s filing said.

NENA argued that a rulemaking would be the best way for determining what the extent of commission’s jurisdiction should be.

“Given the maturity of the NG 9-1-1 service provider ecosystem and the NG 9-1-1 standards environment, as well as the numerous installed and planned NG 9-1-1 deployments across the country, we feel that the discourse and its participants are well-informed and prepared to make this important decision,” NENA said.

Additionally, APCO said that the commission should release a notice of inquiry (NOI) to gather more information on what is needed for the NG 9-1-1 transition.

“Much has changed since the commission delivered a report to Congress on a framework for NG 9-1-1, which included a review of regulatory impediments,” APCO’s filing said. “Whereas the need for interoperability requirements and location-based routing are well-understood problems that could be solved through commission action, there are likely additional opportunities for facilitating NG 9-1-1 that the commission should explore further before proceeding to a rulemaking. These opportunities may include issues such as 9-1-1 call and data prioritization. The commission should seek information on the extent to which service providers prioritize 9-1-1 communications and the feasibility of prioritizing new types of communication such as 9-1-1 calls delivered over Wi-Fi or using 5G and other broadband applications.”

Numerous public-safety agencies said that they support the NASNA petition and that the proceedings it requests could help address issues they face in their transition to NG 9-1-1 services.

The Arizona Department of Administration 9-1-1 Program Office (ADOA 9-1-1), the Colorado Public Utilities Commission (COPUC) and the Boulder (Colorado) Regional Emergency Telephone Service Authority (BRETSA) specifically supported the petition’s request to establish NG 9-1-1 cost demarcation points or points for allocating costs when parties cannot agree on the appropriate demarcation points.

“Except in instances where states or local authorities choose to provide cost recovery to originating service providers, the cost of delivering 9-1-1 calls to the 9-1-1 system service provider, in the format required by the 9-1-1 system service provider must be borne by the origination service providers themselves,” COPUC said in its filing.

COPUC argued that this is an extension of laws that require OSPs to deliver 9-1-1 calls to a PSAP without any considerations for cost recovery.

“The requirement to deliver 9-1-1 calls exists regardless of whether any mechanism also exists for the OSPs to recover their costs,” CPUC said. “Furthermore, there is nothing preventing OSPs from recovering the costs of compliance from their users, and if all providers, regardless of technology, are subject to the same requirement, the costs of compliance are competitively neutral.”

NENA said that it supports a deeper conversation on demarcation points.

“The record already reflects the widespread occurrence and substantial impact from demarcation-caused delays in deployment and provision of NG 9-1-1,” NENA’s filing said. “We welcome further, more granular discussion regarding the exact location of those demarcation points as part of a commission rulemaking.”

NENA noted that its standards development community has been working on demarcation points and released a document on it in 2013. While that document is now outdated, NENA said it has begun work on updating it to reflect the current state of NG 9-1-1.

This updated document will, at least in part, assist in identifying where demarcation points can happen, not only for regulatory purposes but also for deployment of systems, purchasing of NG 9-1-1 elements, mutual aid agreements and other purposes,” NENA said.

ADOA also said any mandatory timeframes for OSPs to transition to NG 9-1-1 should include legacy providers so that those legacy providers “will cease from continuing to charge 9-1-1 authorities for legacy 9-1-1 services.”

BRETSA also expressed concerns about the higher costs that public-safety answering points (PSAPs) will face from the NG 9-1-1 transition.

“As BRETSA has stated in other proceedings, transition to an ESInet means that PSAPs pay significantly, even exponentially higher costs to receive the same 9-1-1 calls they would have received over their E9-1-1 networks, but in digital format until additional NG 9-1-1 features and applications are provided, including features to be provided by wireless providers,” BRETSA said.

To help address this issue, BRETSA said that the commission should address in proceedings which NG 9-1-1 features, capabilities and requirements that wireless providers who provide 9-1-1 services to PSAPs should implement.

“Among the features and capabilities wireless providers must implement for the public to realize the benefits of more costly ESInets and NG 9-1-1 are delivery of 9-1-1 calls in SIP format with PIDF-LO, geospatial routing and other features essential to more efficient and effective NG 9-1-1,” BRETSA’s filing said. “BRETSA believes that ubiquitous deployment of text-to-9-1-1 will be achieved when text-to-9-1-1 messages are delivered through ESInets at statewide-averaged rates or pursuant to state contract having similar effect.

BRETSA also noted that there may be other capabilities that become practical but might require FCC action in order to enable them due to the number of stakeholders required to provide the service, cost allocation issues or other considerations.

BRETSA also expressed concerns about issues with calls being misrouted when PSAPs from different states are involved and said the FCC should adopt standards for the transfer of 9-1-1 calls between PSAPs in different states.

CPUC said it supports all four of the main requests in the NASNA petition. On the issue of the FCC amending its rules to help advance the transition, the CPUC pointed at the portion of the FCC’s rules that require carriers to deliver 9-1-1 calls to a PSAP or similar authority.

“In practical terms, throughout most of the nation, this means delivering 9-1-1 calls to a 9-1-1 system service provider … which then delivers the call to the appropriate PSAP,” CPUC said. “However, the rule states nothing regarding how the call must be delivered, only that it must be delivered. The implementation of NG 9-1-1 requires consideration of the method used to deliver the 9-1-1 call, such as whether the call is delivered in TDM format or SIP format, and whether location information is provided via an automatic location information (ALI) database and separate ALI circuit, or whether location information is attached to the call in the form of a presence information data format - location object (PIDF-LO) attached to the SIP header. Without consideration of these details of how 9-1-1 calls are delivered by OSPs to the 9-1-1 system service provider, full implementation of NG 9-1-1 cannot be accomplished.”

Comtech, a provider of NG 9-1-1 services, reiterated that FCC action is needed to help speed the advancement of NG 9-1-1 services.

“As an NG 9-1-1 provider, Comtech has experience, and is currently experiencing, significant delays in the completion of NG 9-1-1 transitions due to regulatory uncertainty and resistance from certain local exchange carriers providing legacy 9-1-1/enhanced 9-1-1 (E9-1-1) services and originating service providers (OSPs) to expediently completing NG 9-1-1 deployments,” Comtech’s filing said.

Comtech said the biggest roadblock facing NG 9-1-1 transition is the establishment of demarcation points for cost allocation. Comtech urged the FCC to assert authority of OSPs and legacy 9-1-1 providers in regards to NG 9-1-1 and amend its rules in order to adopt “reasonable timeframes for OSPs and legacy 9-1-1 providers to complete NG 9-1-1 transitions, establish a default NG 9-1-1 demarcation point (or points), and adopt a technological-neutral definition for determining a 9-1-1 authority’s NG 9-1-1 readiness.”

The Nebraska Public Service Commission (NPSC) said it supports both expanding FCC authority over OSPs in respect to NG 9-1-1, as well as making OSPs responsible for the cost of compliance. The NPSC also said that it would support the creation and implementation of a NG 9-1-1 readiness scorecard that would be based on the work of the commission’s Task Force on Optimal PSAP Architecture (TFOPA).

“As noted in the TFOPA Readiness Scorecard Report, there presently is no end-to-end accredited technical standard for NG911 and there are many transitional steps to achieving the fully deployed NG 9-1-1 ‘end state,’ ” the NPSC filing said. “As a result, there are no generally accepted mileposts for jurisdictions to assess their relative progress on the long road to full NG 9-1-1 implementation. Utilizing the framework of the TFOPA Readiness Scorecard, as suggested by NASNA, could provide 9-1-1 authorities with realistic metrics on which to assess their own progress toward NG 9-1-1 adoption.”

Organizations representing service providers said they support the transition to NG 9-1-1 services but urged the commission to proceed cautiously because of the complex nature of the NG 9-1-1 environment.

“…Due to the complex nature of the technologies involved; the interplay of existing local, state and federal laws applicable to the 9-1-1 system; and the contractual relationships governing the multitude of parties operating legacy and competitive 9-1-1 systems and the different types of originating service providers (OSPs) that must interconnect with such systems, the commission must proceed with caution before taking any regulatory action,” USTelecom — the Broadband Association said.

USTelecom said that it understands the importance of the issues raised in the NASNA petition and how those issues have led to an uneven NG 9-1-1 transition but argued that without details or “factual examples” of the issues NASNA described, it was difficult for the organization to comment on specific requests made in the petition.

“Based on the very limited information in the record at this time, at most, the commission should proceed with a notice of inquiry to gather additional information before adopting any new rules,” USTelecom said.

USTelecom also noted that despite some challenges that are being faced, progress has been made in the deployment of NG 9-1-1.

“It is not clear that the FCC needs to adopt new rules or modify existing rules at this time, or if the challenges can be resolved through the implementation or modification of existing, or the adoption of new, best practices,” USTelecom said. “… We are acutely aware of the progress that has already been made and continues to be made, as well as the challenges that have arisen. Our general experience suggests that standards-based NG 9-1-1 is being deployed at a steady pace, and that negotiations between OSPs and ESInet operators regarding interconnection are ongoing and successfully occurring in many cases. In other instances, negotiations have been more challenging. This is not surprising given the complexity of transitioning from E9-1-1 to NG 9-1-1 as described above.

CTIA — the Wireless Association also said it supports the transition to NG 9-1-1 and like USTelecom noted that the NG 9-1-1 is successfully happening across the country in certain areas. For example, it said, recent reports to Congress show that 38 states have ESInets operating in them and 19 of those states have statewide ESInets.

Like USTelecom, CTIA said that before moving forward with any regulations, the FCC should conduct a NOI to study how stakeholders in the environment are working through the challenges.

On the issue of whether the commission should take jurisdictional authority over OSPs in regards to NG 9-1-1, CTIA argued that the FCC’s rules already require that OSPs transmit 9-1-1 calls to a PSAP and that those obligations are technology neutral, meaning the issue is required.

On the issue of demarcation points and cost responsibilities, CTIA said that those are one of many issues that stakeholders reach agreement on through negotiation and they will likely differ between states.

“These discussions produce results, as the record of NG 9-1-1 transitions in states and jurisdictions demonstrates,” CTIA said. “The fact that states and jurisdictions have launched as many ESInets as they have shows that stakeholders are able to work through complex issues, including demarcation points and indicates that demarcation points are not an obstacle to NG 9-1-1 deployment. The NG 9-1-1 transition ‘is happening now,’ as NASNA observes.”

NCTA — the Rural Telecom Association said granting the NASNA petition could lead negative repercussions such as rural customers absorbing the costs created by granting the FCC granting that relief.

“More specifically, the commission should avoid consideration and perhaps adoption of ‘one- off’ piecemeal changes to interconnection and ‘network edge’ rules that may apply in some instances of IP voice traffic exchange but not in others, thereby adding confusion and chaos to the marketplace and imposing costs on rural consumers,” the NTCA filing said.

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