Next Generation 911 (NG911) is here and is vastly superior to the outdated analog 911 service Americans have relied on for so many years. NG911 is an Internet Protocol (IP)-based digital system. It allows callers to seamlessly send digital media—like photos, videos, real-time texts, and precise location data—to emergency dispatchers, enabling a significantly faster, safer, and more informed emergency response. Most importantly, NG911 allows calls to be easily routed around disaster areas, ensuring service disruptions are minimized.
Unfortunately, the last time the FCC set up a system to enable system reliability for 911 service was 2013, well before the advent of NG911. This has led to significant problems as the industry moves to the new technology.
As the nation has embarked on the transition to NG911 over the last decade, the Commission has seen a corresponding increase in major, multi-state 911 service outages that have disrupted access to life-saving emergency services for millions of Americans. Too often, these outages have occurred in parts of transitional NG911 systems outside the scope of the 911 reliability framework adopted in 2013, which does not address the increasingly complex array of call scenarios in the Internet Protocol (IP) call origination context we live in today. We believe that, in many of these instances, operators could have prevented or mitigated outages by implementing reliability measures appropriate for IP-based systems. (Draft Second Report and Order and Further Notice of Proposed Rulemaking, PS Docket Nos. 21-479 and 13-75, at para. 2).
Because the 2013 911 reliability framework cannot reliably support NG911 call flows, the Commission is expected, at its June 25 meeting, to adopt a Second Report and Order (Order) and Further Notice of Proposed Rulemaking (Further Notice) to reduce the risk of future outages in transitional and end-state NG911 networks. In the Order, the agency takes the following actions.
Covered 911 service providers – The Commission updates its definition of covered 911 service providers (CSPs) to identify categories of providers whose operations are essential to NG911 call delivery, whose failure could cause significant outages, and who therefore must meet enhanced reliability standards under the NG911 framework. The updated CSP definition includes operators of Emergency Services IP networks (ESInets), Next Generation Core Services (NGCS) providers, and providers of real-time location services, major IP transport, IP 911 traffic aggregation, and essential gateways for converting legacy and IP traffic.
Reliability standards – The Commission modernizes and streamlines the 911 reliability benchmarks applicable to CSPs to reflect widely recognized best practices appropriate to IP-based 911 networks. These benchmarks incorporate well-established IP best practices in the areas of physical diversity, operational integrity, and network monitoring and reflect achievable standards identified by the Commission’s Communications Security, Reliability, and Interoperability Council (CSRIC).
Interoperability – To support the seamless transfer of 911 calls and associated data across the NG911 ecosystem, the FCC requires NGCS and ESInet CSPs to report their recent actions to enable interstate NG911 interoperability, while seeking further comment on more detailed interoperability requirements.
Certification Process – The FCC eliminates the requirement that CSPs file annual compliance certifications and adopts a streamlined filing process for CSPs going forward. There will be an 18-month transition period, after which CSPs will file initial reliability certifications in conformance with the new rules, which they will need to update only in the event of material changes. This will reduce unnecessary regulatory burdens on CSPs while focusing the certification process on essential information relevant to ensuring NG911 reliability.
Oversight – The agency allows 911 Authorities to access CSP certifications and reports subject to confidentiality safeguards and codifies the process of the Public Safety and Homeland Security Bureau (PSHSB or the Bureau) for investigating and remediating noncompliance, providing transparency to service providers.
In the Further Notice, the Commission seeks comments on requiring NG911 service providers to conduct multi-party interstate interoperability testing of 911 traffic, and about how 911 Authorities can integrate advanced video calling into NG911 networks to improve accessibility. Industry comments will be due 30 days after the Further Notice appears in the Federal Register.