• Kim Scovill

NASNA Files NG911 Petition at FCC

CC docket 94-102 and PS dockets 18-64, 18-261, 11-153, and 10-255

October 19, 2021

The National Association of State 911 Administrators has filed a petition for rulemaking or, in the alternative, petition for notice of inquiry to facilitate the deployment of next-generation 911 (NG-911) services.

In the filing in CC docket 94-102 and PS dockets 18-64, 18-261, 11-153, and 10-255, NASNA asked the FCC to launch a rulemaking or notice of inquiry to: “1) Establish Commission authority over originating service providers’ (OSPs) (i.e., wireless, landline, and interconnected VoIP) delivery of 911 services through IP-based emergency services networks (ESInets). 2) Amend 47 C.F.R §§ 9.4 and 9.5 as needed to advance the transition to and implementation of NG911 services. 3) Require the cost of compliance, as it was with the implementation of wireless enhanced 911 service, text-to-911, and real-time text (RTT), is the responsibility of the OSPs, except where cost-recovery is provided by state law or regulation.

“Specifically, and comparable to the FCC’s King County decision, that the FCC establish a NG911 cost demarcation point or points, for allocating costs when the parties cannot agree on the appropriate demarcation point(s),” NASNA added.

“Additionally, NASNA urges the Commission to consider adding a NG911 Readiness Registry (NG911 Registry) to its existing text-to-911 or public safety answering point (PSAP) registries—or combine the two and add a NG911 Registry,” it said. “While the aforementioned registries are voluntary, we believe having a NG911 Registry would be a meaningful tool for state and local 911 authorities and OSPs to use to advance the implementation of NG911. Alternatively, that the FCC establish NG911 Readiness stages or phases to be utilized by both state/local 911 authorities and OSPs in transitioning to NG911 services.”

Link to Filing -https://ecfsapi.fcc.gov/file/1019188969473/Final%20NG911%20Cost%20Clarification%20Filing.pdf

“Over the years, the Commission has been instrumental in creating processes for the orderly but timely implementation of new 911 technologies, including wireless enhanced 911 service, delivery of 911 calls originating from Voice-over-Internet-Protocol providers, and text-to-911 service. NASNA believes the Commission should play a similar role in the implementation of Next Generation 911 services,” the petition concluded. “Without action from the Commission, it is difficult to envision how full, nationwide implementation of NG911 can be achieved. With the Commission’s support and direction, however, NG911 can be implemented in a timely and coordinated manner that will provide a better result for the citizens who call 911 every day and rely on 911 to provide them with the emergency services they require.” —Paul Kirby, paul.kirby@wolterskluwer.com

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