Last Thursday the FCC adopted new rules to transition to Next Generation 911 (NG911) technologies. NG911 marks a significant advancement in emergency response systems, utilizing modern IP-based technologies to improve the speed, reliability, and accuracy of emergency communications. These rules outline the specific requirements for service providers to facilitate this transition:

Phase 1 Requirements

Upon receiving a valid request from a 911 Authority, service providers must adhere to the following requirements within six months:

1. Deliver 911 Traffic in IP-based SIP Format: Providers must ensure that all 911 traffic directed to the relevant Public Safety Answering Points (PSAPs) is delivered in the IP-based Session Initiation Protocol (SIP) format as requested by the 911 Authority.
2. Enable ESInet and NG911 Network Facilities: Providers must obtain and deliver 911 traffic to enable the Emergency Services IP Network (ESInet) and other NG911 network facilities to transmit all 911 traffic to the destination PSAP.
3. Designate NG911 Delivery Points: All 911 traffic must be delivered to the NG911 Delivery Points designated by the 911 Authority.
4. Connectivity Testing: Providers must complete connectivity testing to confirm that the 911 Authority receives 911 traffic in the IP-based SIP format requested.

Phase 2 Requirements

Following the initial compliance with Phase 1 requirements, service providers must meet additional criteria within another six months:

1. Comply with Phase 1 Requirements: Continue to meet all the Phase 1 requirements.
2. Deliver Traffic to NG911 Delivery Points with Location Information: Ensure that 911 traffic includes embedded location information using Presence Information Data Format – Location Object (PIDF-LO) or its functional equivalent and deliver this traffic to the NG911 Delivery Points.
3. Implement Location Information Server (LIS): Install and operationalize all necessary equipment, software applications, and other infrastructure to use a Location Information Server (LIS) or its functional equivalent for verifying customer location information and records.
4. Connectivity Testing with NG911 Standards: Complete connectivity testing to confirm that the 911 Authority receives 911 traffic in the IP-based SIP format that complies with the identified NG911 commonly accepted standards.

Implementation Deadlines

The FCC has set specific deadlines for different types of service providers:

1. Non-rural Wireline Providers, Nationwide CMRS Providers, Text Providers, and Interconnected VoIP Providers:
   • Comply with Phase 1 requirements within six months of receiving a valid request.
   • Comply with Phase 2 requirements within six months of completing Phase 1 compliance or the earlier Phase 1 deadline.
2. Rural Local Exchange Carriers (RLECs), Non-nationwide CMRS Providers, and Internet-based TRS Providers:
   • Comply with Phase 1 requirements within twelve months of receiving a valid request.
   • Comply with Phase 2 requirements within twelve months of completing Phase 1 compliance or the earlier Phase 1 deadline.

Challenging 911 Authority Requests

Service providers have the right to challenge 911 Authority requests if they believe the requests do not meet the specified conditions. Providers can submit a petition to the Public Safety and Homeland Security Bureau within 60 days of receiving the request. The Bureau will review the petition and may pause the implementation deadline, affirm the request, or take other necessary actions.

If your organization requires assistance with NG911 compliance efforts, Marashlian & Donahue, PLLC is here to help. If you would like additional information about the NG911 requirements for service providers, please contact Michael Donahue (703-714-1319; mpd@commlawgroup.com) or Christine McLaughlin (703-714-1328; czm@commlawgroup.com). Further information about Marashlian & Donahue’s Emergency Services 911 practice is available here.