On June 8, 2023, the Federal Communications Commission (FCC) adopted a Notice of Proposed Rulemaking (NPRM) aimed at advancing the nationwide transition to Next Generation 911 (NG911). The FCC’s proposed rules seek to establish requirements for wireline telecommunications carriers, interconnected Voice over Internet Protocol (I-VoIP) providers, and Internet-based telecommunications relay service (iTRS)[1] providers to facilitate the adoption and implementation of NG911. If adopted as proposed, wireline telecommunications carriers and I-VoIP providers would get six months to come into compliance, while iTRS providers would get twelve months.
NG911 represents a significant evolution from the current, circuit-based 911 system, as it utilizes IP-based format and routing. This transition will enable the transmission of text, photos, videos, and data, enhancing emergency communications capabilities. However, the transition has been hindered even where public safety answering points (PSAPs) already support NG911 delivery because some telecommunications service providers have been reluctant to roll out needed support on their end.
The proposed rules, if adopted, would mandate wireline, I-VoIP, and iTRS providers to deliver 911 calls, along with relevant location information, in the requested IP-based format. This delivery should be made to the designated PSAP once the PSAP confirms its readiness to receive NG911 calls.
Additionally, the FCC proposes rules that would require wireline, wireless, interconnected VoIP, and Internet-based TRS providers to transmit all 911 calls to point(s) designated by a 911 authority. These providers would be considered presumptively responsible for the costs associated with the delivery to the designated point(s). However, it is worth noting that states and localities retain the ability to establish alternative cost allocation arrangements with the above-mentioned providers.
Wireline and I-VoIP providers would be subject to the NG911 delivery requirements six months from the effective date of the IP service delivery requirement, or six months after a valid request for IP-based service by a state or local 911 authority, whichever is later. iTRS providers would be given an additional six months.
Interested parties are encouraged to submit comments and reply comments during the designated comment and reply comment period. The comment and reply comment deadlines will be announced in a subsequent Public Notice upon publication of the NPRM in the Federal Register.
If you have any questions about the proposed rules or the NG911 transition more broadly, please contact Michael P. Donahue, Esq. at (703) 714-1319 or mpd@commlawgroup.com.
[1] iTRS consists of video relay, Internet Protocol (IP) Relay, and IP captioned telephone services. These forms of iTRS are defined in 47 C.F.R. § 64.601.
