NASNA Expresses Concern About NG 9-1-1 Bill in Letter to Senate
Thursday, September 01, 2022 | Comments

In a letter to members of the U.S. Senate, the National Association of State 9-1-1 Administrators (NASNA) expressed concern about a bill that would fund NG 9-1-1 that the Senate is currently considering.

“NASNA was a contributing member of the original public-safety community that developed the base language of earlier iterations of the NG 911 funding bill,” the letter said. “NASNA supported that initial language, and we still support the premise of federal assistance for NG 911. However, we believe now is the time to voice our strong and urgent concern about this current version of the legislation. We are fully aware that there have been matters raised by other public-safety groups and we are concerned that these other interests will unnecessarily detract from and delay NG 9-1-1 implementation. As the group ultimately responsible for NG 9-1-1 deployment in each of our states, we want to point out those matters.”

In July, the U.S. House of Representatives approved H.R. 7624, the Spectrum Innovation Act, which would provide up to $10 billion in NG 9-1-1 funding by mandating that the FCC auction off spectrum in the 3.1 – 3.45 GHz band. The Senate is currently considering that bill.

NASNA expressed four major concerns about the bill. First, it said it strongly believes in the National Emergency Number Association’s (NENA) i3 standard for NG 9-1-1.

“While we support innovation and competition, we do not support any amended language that would give preference to an alternative standard,” the letter said. “Every state, regional and local agency that is implementing NG 9-1-1 is based on the NENA i3 standard.”

NASNA argued the industry has put years of collaboration and work into the i3 standard and said that many states have issued requests for proposals or issued contracts based on the standard.

“States have made significant investments in the proven i3 standard,” the letter said. “The data reflected in the FCC’s ‘Annual NET 911 Report’ reflects that the states have already invested over $1.6 billion towards NG 9-1-1. Even in the event that the full amount of $10 billion proposed in HR 7624 becomes available for NG 9-1-1 with the spectrum auction, we are steadfast in our position that it would not only be fiscally unwise to abandon those investments, but it would also set the progress of NG 9-1-1 back by years.”

Second, NASNA said that the creation of a nationwide NG 9-1-1 cybersecurity center, as mandated in the bill, is redundant to work already being done and unnecessary.

“States already individually have been and will continue to make determinations on the proper security of NG 9-1-1 systems,” the letter said. “The FCC’s Taskforce on Optimal PSAP Architecture (TFOPA) provides a framework for NG 9-1-1 cybersecurity at the state, regional and local levels.”

Additionally, NASNA said that there is already a strong cybersecurity resource for public-safety answering points (PSAPs) with the Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Agency (CISA).

“Rather than creating a second national NG 9-1-1 cybersecurity center, any funds allotted by HR 7624 for this purpose could be directed to CISA to support the NG 9-1-1 cybersecurity programming already in place,” the letter said. “A duplicative cybersecurity center at NTIA is not necessary and attempts to solve a problem that simply does not exist.”

Third, NASNA said that before changing the way 9-1-1 grant programs are done as the bill would do, a sound evaluation should be performed. Currently, two federal 9-1-1 grant programs — ENHANCE 911 and NG 911 — have been administered through a joint office of the National Highway Traffic Safety Administration (NHTSA) and the National Telecommunications and Information Administration (NTIA). Under the bill, the proposed grant program would be under NTIA alone.

“This provides not only a system of checks and balances but ensures that the technical assets of NTIA are utilized and allows the 9-1-1 community to benefit from the safety focused expertise of NHTSA,” the letter said. “While NASNA understands that there is a desire by some to place all 9-1-1 grant oversight and operational/technical support services under the single umbrella of NTIA, NASNA believes this move is premature and overlooks the vital role NHTSA plays in the 9-1-1 environment.”

NASNA argued that NHTSA has provided a variety of tools and data for states to use in the NG 9-1-1 transition over the last several years. The organization argued that not only should the joint office of NHTSA and NTIA remain but the bill should also include an objective evaluation for the best federal organization to house NG 9-1-1 and 9-1-1 resources.

“H.R. 7624 is an opportunity to 1) maintain the successful programming provided to 9-1-1 currently jointly housed in NHTSA and NTIA and 2) establish a means to objectively and collaboratively evaluate 9-1-1 programming on the federal level,” the letter said. “NASNA believes changing the current programming without a sound evaluation will impede the forward progression of NG 9-1-1 for all states, regardless of the NG 9-1-1 deployment status.”

Finally, NASNA said that the plans required of states by the bill would be a barrier to states receiving assistance for NG 9-1-1. The organization argued that states have already moved forward with the technical and operational aspects of NG 9-1-1 without any federal dictates. Additionally, each state has a unique perspective of what is needed to make NG 9-1-1 successful in that state.

“We believe that the overly prescriptive conditions written into HR 7624 for the states’ NG 9-1-1 plan are redundant, unnecessary and create burdensome requirements for the states’ 9-1-1 systems,” the letter said. “The NG 9-1-1 plan requirements are best suited to the grant rulemaking process, not congressional mandates.”

In concluding, NASNA said that it supports the goals of the bill but it believes that in its current form, the bill will not meet those goals.

“While NASNA’s 48 member states support the premise of H.R. 7624, we have concerns that the admirable goals set forth in the bill itself may not be fully realized by its current form,” the letter said. “We are grateful for Congress’s support in move NG 9-1-1 forward, yet we would be remiss in our responsibilities as 9-1-1 program administrators if we did not address these issues with you. Our membership stands ready to answer any questions that you may have about NG 9-1-1 and the impacts of H.R. 7624.”

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