On December 20, 2021, the Public Safety and Homeland Security Bureau released a Public Notice seeking comment on the National Association of State 911 Administrator’s Petition for Rulemaking (“Petition”). The Petition asks the FCC to initiate a rulemaking or issue a notice of inquiry to:
- Establish FCC authority over originating service providers’ delivery of 911 services through IP-based emergency services networks (”ESInets”).
- Amend 47 C.F.R. sections 9.4 (which requires telecommunications carriers to transmit all 911 calls to a PSAP, designated answering point, or other designated local emergency authority as set forth in section 9.5) and 9.5 (which established the requirement for 911 call delivery in phases, all deadlines of which have expired) as needed to advance the transition to and implementation of NG911 services. Specifically, the Petition requests the commission amend section 9.4 to make clear it is applicable to all carriers that are required to provide 911 services and expand the term transmit to account for NG911 protocols. The Petition requests that section 9.5 be amended to specifically address NG911, including standardized requirements associated with NG911 and a time frame for implementation.
- Require the cost of compliance, as it was with the implementation of wireless enhanced 911 services, text-to-911, and RTT, is the responsibility of originating service providers, except where prohibited by state law or regulation. Specifically, the Petition requests that the FCC establish a NG911 cost demarcation point or points for allocating costs when the parties cannot agree.
- Consider adding a NG911 Readiness Registry to its existing text-to-911 or PSAP registries, or combine the two and add a NG911 Registry. Alternatively, the Petition suggests the FCC could establish NG911 Readiness stages or phases to be utilized by both state/local 911 authorities and originating service providers in transitioning to NG911 services. Phase I would indicate that the ESInet is ready to receive 911 calls from the originating service provider via a Legacy Network Gateway. Phase II would indicate that the ESInet is ready to receive 911 calls in a SIP format. Phase III would indicate that the ESInet is ready to receive 911 calls in NG911 format.
Comment are due January 19, 2022.
Reply comments are due February 3, 2022.
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