The Colorado Public Utilities Commission’s 911 Program has issued advance notice of its intent to submit a Phase 1 Next Generation 9-1-1 (NG911) deployment request to the Federal Communications Commission (FCC). While the request will be initiated by Colorado, its implications extend well beyond the state’s borders. Under the FCC’s NG911 transition framework, the resulting obligations may apply to a broad range of originating service providers that deliver 911 traffic for Colorado end users, including providers headquartered or operating elsewhere in the United States. Although the notice is informational only and does not constitute the formal Phase 1 request, it offers an early look at the compliance requirements and implementation timelines that affected providers may soon be required to meet.
What Is Happening?
Under the FCC’s NG911 transition rules (47 C.F.R. Part 9, Subpart J), a valid Phase 1 request from a state 911 authority triggers specific obligations for Originating Service Providers (OSPs) to migrate the delivery of 911 traffic from legacy networks to IP-based NG911 infrastructure.
Colorado has announced its intention to file such a request and has begun identifying the SIP Points of Interconnection (POIs) through which providers will deliver 911 traffic into the state’s Emergency Services IP Network (ESInet).
Who Will Be Affected?
The FCC’s Phase 1 NG911 requirements apply to several categories of providers, including:
- Competitive Local Exchange Carriers (CLECs);
- Interconnected VoIP (I-VoIP) providers;
- Nationwide Commercial Mobile Radio Service (CMRS) providers;
- Covered text providers; and
- Internet-based Telecommunications Relay Service (TRS) providers.
Important Clarification for Wireless Resellers and MVNOs
The FCC’s NG911 obligations applicable to CMRS providers generally apply to the facilities-based mobile network operators that control the routing, transport, and delivery of 911 traffic to the public safety network.
Accordingly, most pure wireless resellers and Mobile Virtual Network Operators (MVNOs) that rely entirely upon an underlying facilities-based wireless carrier to originate, route, and deliver 911 traffic generally are not expected to bear the direct NG911 interconnection obligations associated with Phase 1 deployment requests. Instead, those obligations typically remain with the underlying mobile network operator that controls the relevant transmission facilities and 911 routing functions.
Providers operating under reseller, MVNO, or hybrid wireless business models should nevertheless evaluate their network architecture, contractual relationships, and 911 responsibilities to determine whether any NG911 obligations could apply.
What Will Providers Be Required To Do?
Once Colorado’s request becomes effective, affected OSPs will be required to:
- Deliver 911 traffic in the IP-based SIP format requested by the Colorado 911 Authority;
- Enable the ESInet and related NG911 facilities to receive and process 911 traffic;
- Deliver 911 traffic to designated NG911 delivery points; and
- Complete connectivity testing to verify successful delivery of NG911 traffic.
Compliance Deadlines
The FCC rules establish different implementation periods depending on provider classification:
Six-Month Compliance Period
- Non-rural wireline providers;
- Nationwide CMRS providers;
- Covered text providers; and
- Interconnected VoIP providers.
Twelve-Month Compliance Period
- Rural Local Exchange Carriers (RLECs);
- Non-nationwide CMRS providers; and
- Internet-based TRS providers.
The Colorado 911 Authority may approve alternative implementation timelines in appropriate circumstances.
Colorado’s Proposed NG911 Delivery Points
Colorado has identified one confirmed in-state SIP Point of Interconnection in Colorado Springs and is evaluating several potential locations for a second in-state delivery point in the Denver/Aurora area. The state also confirmed that national providers may continue to connect through designated Lumen national NG911 delivery points located in Chicago, Illinois and Highlands Ranch, Colorado.
The Colorado 911 Program has invited comments regarding the proposed delivery point locations prior to finalizing its Phase 1 deployment request.
Recommended Next Steps
CLECs, interconnected VoIP providers, internet-based TRS providers, and other potentially affected service providers should begin evaluating:
- Existing 911 network architecture and routing arrangements;
- SIP interconnection capabilities;
- Vendor and network partner readiness;
- Potential costs associated with NG911 interconnection;
- Testing and implementation requirements; and
- Applicable compliance timelines.
Early planning can help avoid implementation challenges once Colorado formally submits its Phase 1 request and the FCC’s compliance clock begins running.
Questions?
The CommLaw Group continues to monitor NG911 implementation efforts nationwide and advises providers regarding FCC emergency services compliance obligations.
If you have questions regarding Colorado’s planned NG911 transition, your company’s obligations, or implementation planning, please contact:
Christine McLaughlin
czm@commlawgroup.com
Michal Nowicki
mjn@commlawgroup.com