Carriers Say Coordination Critical to NG911 Rollout

"A smooth transition to NG911 is unlikely to be accomplished if deployment occurs on a PSAP by PSAP basis,” T-Mobile said (http://xrl.us/boaxdx). “While PSAPs can choose when they move from a legacy 911 to an NG911 system, the networks used to connect carriers to the PSAPs ... need to be cut over on a state or regional basis. Because NG911 requires an entirely new architecture, state coordination and deployment (or regional coordination and deployment where metropolitan areas may cross state lines) is critical to ensuring efficient and cost effective implementation.” T-Mobile said there was general agreement on this point in an earlier comment round. T-Mobile also said the federal government should provide guidance and updated standards. “Because NG911 represents an entirely new architecture for connecting consumers with public safety, it is critical that nationwide, interoperable technical standards are adopted and implemented across the board, and that the Commission support the relevant standards-setting bodies in their work,” the carrier said.

"State or regional level deployment, rather than at the county or PSAP level, will speed roll-out of a long-term solution,” Sprint said in its reply comments (http://xrl.us/boaxeb). “Because there are approximately 6,800 PSAPs with varying technology solutions in place, it would be enormously difficult to implement a ‘one-size-fits-all’ approach,” it said. “A centralized authority, however, will be necessary to efficient deployment."

NENA said states must be given “effective tools” to ensure a smooth transition and ensure competitive providers have access to the necessary network elements and data assets currently held by incumbent providers “at reasonable rates and on reasonable terms” (http://xrl.us/boaxew). State coordination is necessary but “is not synonymous with state domination,” the group said. Funds for 911 should be protected from diversion for other uses by the states, NENA argued: “Consumers pay 911 fees in good faith and, if state legislators are unwilling to keep that faith, Congress should act to compel them.” But NENA also said NG911 is “a naturally-federated service and does not require a FirstNet-like entity to manage funding or roll-out."

CTIA said Congress should develop “comprehensive, nationally-defined, limitation-of-liability protection for all stakeholders in the development and deployment of NG911 services that can spur innovation and deployment of advanced services much faster than would occur under the existing, highly uncertain liability protection landscape” (http://xrl.us/boaxfi). “A uniform, nationwide policy framework that clearly delineates the roles and responsibilities of all parties involved will best provide certainty for the numerous entities involved in NG911.” CTIA said eliminating outdated regulation is also important. CTIA cited an example offered by one of its members: “T-Mobile noted that NG911 networks will operate on an entirely new architecture that does not include selective routers, yet many existing 911 regulations specifically reference the selective router. For example, the selective router currently serves as the demarcation point allocating financial responsibility between wireless carriers and PSAPs. T-Mobile’s findings emphasize the broader point that the Commission and/or Congress will either need to remove requirements that reference outmoded technologies or, at the very least, make clear that such requirements do not apply in the NG911 context."

Meanwhile, the FCC this week released its Fourth Annual Report to Congress on State Collection and Distribution of 911 and Enhanced 911 Fees and Charges (http://xrl.us/boaxgq). The commission said New York, Illinois, Arizona, Maine and Rhode Island diverted 911 fees to other uses, and New Jersey, West Virginia, and Guam used 911 fees for other public safety purposes. “Guam, for example, reported that $486,223 was expended for other public safety-related activities, including leasing ambulances and maintaining the territory’s public safety radio communications system,” the report said (http://xrl.us/boaxgq). Two states, New Jersey and West Virginia, indicated they used 911 fees for other public safety-related purposes consistent with their funding statutes. New Jersey’s funding mechanism allows for 911 fees to be used to support other public safety related items, such as National Guard Support Services and the Division of State Police Operating Budget. West Virginia states that its funding mechanism allows for 911 fees to be allocated towards its Department of Homeland Security and Emergency Management, it said.