CTIA, Maine Disagree on Text-to-911 Cost Split
CTIA disagrees with states over how to split text-to-911 costs, it said in comments due Wednesday in docket 11-153 and posted there Thursday. To resolve a conflict holding up Maine's adoption of text-to-911 via message session relay protocol, and so…
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the state may appropriately assess costs, the Maine Public Utilities Commission asked the FCC to clarify where the point of demarcation is between wireless providers and the state’s next-generation 911 network (see 1701090027). Wireless service providers should pay to connect from the text control center (TCC) to the state’s NG-911 system, the Maine PUC commented. “Placing the burden on a 911 authority, even on an interim basis, is fundamentally unfair when the requirement to provide the service lies with the carriers.” The point of demarcation should be at the ingress designated by the state’s session border controller, “which governs inputs to the statewide ESInet and routes calls using an Emergency Service Routing Proxy (ESRP),” it said. CTIA said the egress side of the wireless providers’ TCC is the appropriate demarcation point: “The Maine PUC offers no justification for upending the established cost allocation paradigm that public safety representatives and wireless providers have instituted and the FCC has recognized for interim text-to-911 solutions.” The National Association of State 911 Administrators supported the Maine PUC. The FCC should set a standard point of interconnection that could be applied to future multimedia communication in NG-911, NASNA commented. “This would aid states that are moving aggressively toward NG911 to better serve the evolving communication preferences of consumers and hopefully minimize the transition timeline.” APCO said the information provided by Maine seemed to support its suggested demarcation point. “To ensure comprehensive applicability across network designs and naming conventions, the Commission might benefit from considering the need for a functional definition of the demarcation point, rather than identifying a specific piece of equipment or network element,” the public safety group commented. The National Emergency Number Association urged the FCC to resolve the matter soon. "Unless and until critical demarcation questions, such as the one raised by Maine, are resolved, states like Maine and other local 9-1-1 authorities will face continued uncertainty and potentially conflicting service provider demands with respect to the structure of legacy voice, interim SMS, and end-stage Next Generation 9-1-1 service."