By a unanimous vote on July 18, 2024, the Federal Communications Commission took a groundbreaking step forward to accelerate the transition to end-to-end Next Generation 911 (NG911) in the United States. The Commission’s action will boost efforts to modernize emergency services by advancing the transition to an IP-based 911 system, promising faster, more efficient responses during critical situations.
Intrado was an active participant in shaping these rules, meeting several times with the FCC to talk about the key decisions for extending NG911 and what it’s like to work, on the one hand, with PSAPs who are preparing and, on the other hand, with the OSPs who will initiate NG911 service to the PSAP. I’m glad to see that the Commission incorporated a lot of what we said into the final order.
The PSAP community is pleased with the outcome. Upon news of the vote, Brian Fontes, CEO of the National Emergency Number Association, remarked that the ruling would be an opportunity for stakeholders to work together on a plan forward and that the move would improve 911 services “for everyone, especially those who depend on inclusive services, like deaf or hard-of-hearing individuals.”
So, let’s discuss the key elements of the decision and do a little forecasting.
Understanding the NG911 Transition
Aside from improved accessibility and inclusivity, there are several motivating factors behind the push to IP.
- Cost Savings: Time Division Multiplexing (TDM) is an outdated, legacy solution that is expensive to maintain and operate. Plus, it’s getting harder and harder to procure these circuits as providers across the country seek to turn down this technology in favor of IP.
- Efficiency & Reliability: IP-based systems allow for a more direct route – and alternate routes – for traffic to flow, bypassing common TDM failure points.
- Better Data: IP is more media-friendly, allowing data sharing beyond what legacy TDM interfaces can handle. This includes text messages, as well as photo and video delivery.
Technical issues aside, the biggest challenge may be how to fund the rest of the transition. The public safety community has been vocal about its desire to move forward with NG911 for years, but funding the transition has been an ever-present challenge.
In his statement last week, Mr. Fontes added, “Now, it is crucial that Congress commit to fully funding the NG911 transition. Without federal help, local governments will struggle for years to maintain current 911 operations while simultaneously building, testing, and performing a perfect cutover to NG911.” He’s right, and we’re seeing this every day.
What This Means for 911 Authorities and Their PSAPs
The Commission’s decision outlines specific responsibilities for 911 Authorities, including:
- Designation of Delivery Points for 911 Traffic: These must be within the state or territory where the 911 Authority and PSAPs are located.
- Valid Requests: These can be submitted through written notification to the Originating Service Providers (OSPs) that serve the PSAP or to a Commission registry (currently under development) that OSPs will be obligated to check periodically. To be valid, a request must be based on actual operational readiness and must include the NG911 Delivery Point location and certification of readiness to receive and transmit 911 traffic in Session-Initiated Protocol (SIP) (a Phase 1 request) or i3 (a Phase 2 request). PSAP requests must also indicate that their NG911 provider is available to complete testing and deployment.
I should probably mention that OSPs may challenge PSAP readiness by asking the Commission’s Public Safety and Homeland Security Bureau to evaluate. Throughout the Commission’s decision, however, it’s obvious that the rules are the default, and OSPs and 911 Authorities/PSAPs have the leeway to make alternate arrangements to avoid challenges. The Commission also recognized the importance of the NG911 Core Service Provider in this process. This is where Intrado can be particularly helpful in facilitating an understanding between the OSP and the PSAP.
While there are still obstacles ahead for many PSAPs with funding and implementing NG911, the timeline and expectations are clearer for OSPs: if they serve areas that have not yet transitioned to NG911, they must begin to plan now.
What This Means for OSPs
The FCC’s decision mandates that OSPs – including wireline, Commercial Mobile Radio Service (CMRS), text, interconnected VoIP, and internet-based TRS providers – shift to NG911 in two phases. Similar to the approach the FCC adopted twenty-plus years ago for the transition to Enhanced 911, this phased rollout is designed to ensure smooth transition while maintaining the integrity and reliability of emergency services.
- Phase 1: OSPs must deliver 911 traffic in IP-based SIP format to designated Delivery Points set by the 911 Authority.
- Phase 2: OSPs must deliver 911 traffic in IP-based SIP format that supports routing, caller location, and the transmission of emergency information in accordance with NG911 commonly accepted standards, often referred to as i3 formatting.
Key Deadlines
The FCC structure includes deployment timelines for OSPs following a PSAP request for service. In addition, the transition to Phase 1 will generally be completed before starting Phase 2, while allowing PSAPs and OSPs to reach agreements to progress directly to Phase 2 where appropriate.
Compliance timelines are as follows:
- Six months for non-rural wireline, nationwide CMRS, text, and VoIP providers.
- Twelve months for Rural Local Exchange Carriers (RLECs), non-nationwide CMRS, and internet-based Telecommunications Relay Service providers.
What Can OSPs Do Now to Prepare?
While circumstances vary among OSPs, using in-house resources to achieve compliance with these rules is possible but will likely include a significant logistical and technical effort to overhaul and implement new data transmission. It will also require status management of every PSAP where an OSP delivers traffic, meaning OSPs must track for every PSAP to determine whether it is completely NG911 ready (SIP in an i3 format), partially deployed (SIP), or not yet deployed (TDM). That’s where we come in.
The great news for our carrier/OSP customers is that, in addition to engaging directly with the FCC on the final form of the rules, Intrado is already providing solutions and services that support the new regulations.
If you are already leveraging our IP peering solution, DirectRoute, you have a leg up in the move to compliance. There is no need to build anything in-house and no need to independently manage the status of all the PSAPs you serve.
Intrado’s holistic solution determines a PSAP's network status and NG911 capabilities so that we can automatically pass data (via TDM or Direct IP) in the format the PSAP accepts, current formatting (often called i2), SIP, or i3-formatted SIP, based on each PSAP’s infrastructure capabilities.
Intrado is evolving our solution to be a turnkey service for OSPs that:
- Is the single point of contact for a request
- Establishes connectivity to every ESInet
- Determines the target ESInet and delivers calls directly
- Converts i2-signaling into i3-compliant signaling
- Customizes i3-signaling per the preferences or requirements of each target ESInet
With Intrado’s solution, OSPs avoid maintaining the routing, ESInet requests, and format capabilities for each network’s standards. We allow you to operate seamlessly regardless of network and devices, and there are no net new operational needs.
Bottom line, Intrado has the most expansive IP peering network available and will ensure requests for assistance get to the right PSAP, in the right format, in line with the requirements of the FCC’s NG911 order.
What’s Next?
As more PSAP requests start to come in (likely starting 2Q 2025), staying ahead of these changes is crucial for maintaining a competitive edge as well as regulatory compliance. As we move toward a safer, more connected future, staying informed and proactive will be key to navigating these changes successfully.
Our legal and regulatory teams continue to monitor all developments and maintain dialog with the Commission and with our solutions teams, and we will share any significant updates. In the meantime, if you have questions about NG911 and its impact on your business, please reach out to speak with one of our experts.
