Industry Warns of High Costs to Comply With Proposed NG911 Rules
NTCA and the Rural Wireless Association warned of looming costs for smaller carriers if the FCC approves rules to facilitate a move to next-generation 911, in comments on a June NPRM (see 2306080043). The FCC’s proposed approach got general support from the National Association of State 911 Administrators, the National Emergency Number Association and other public safety commenters (see 2308090036), but industry is raising concerns. Comments were due at the FCC Wednesday in docket 21-479 and were still being posted Thursday.
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“NTCA supports the aims of the rules generally, but as currently drafted, they would require small, rural operators such as those represented by the association to assume costs for the transport of traffic to points well outside their existing network footprints, or even far outside the state in which service is provided,” NTCA said: “These new costs could be significant as new, dedicated transport routes would need to be established, and they would need to be recovered from small, rural customer bases and thereby raising universal service implications for the affordability of voice services.”
NTCA also said the NPRM is based on flawed assumptions about how rural LECs operate. “RLECs generally do not have settlement-free peering arrangements; most RLECs exchange Internet traffic through paid-for transit arrangements that provide access to one of several distant Internet Exchange Points,” contrary to statements in the NPRM, the group said. These data routing arrangements “almost certainly cannot be leveraged for the voice traffic at issue here at no additional cost” and wouldn’t offer “the assured quality and reliability” that policymakers want for NG911 traffic, NTCA said.
The NPRM doesn’t recognize the significant costs of the proposed new rules for small wireless carriers, RWA said. To change connection points to a time-division multiplexing-capable network, a CMRS carrier will first need to buy and install a session border control allowing the connection from the carrier’s IP-cable network to a public safety answering point that remains only TDM-capable, the group said: “The cost of purchasing such a gateway is $100,000, which is a significant capital expense that cannot be recovered from the small subscriber base (typically, ranging from 100 to 10,000 subscribers) served by RWA members, many of whom already rely on universal service support to remain operational.”
“The NPRM’s proposed transition timetables do not adequately reflect the inherent challenges of such a dramatic technological evolution,” AT&T commented: A proposed six-month transition timetable is “a laudable aspirational goal” but “will not be realistic in all circumstances. The current 911 system evolved over the course of decades; it is not realistic to expect such a major transition to be completed in just six months.”
Funding Concerns
APCO urged caution in the rules, noting no fully enabled NG911 systems operate in the U.S., and emergency communications centers (ECCs) are still waiting for federal funding from Congress. “Even in jurisdictions that have made progress, the public safety community faces interoperability problems and resource constraints that inhibit progress toward NG9-1-1,” APCO said: “The Commission’s proposals have the potential to accelerate the transition but would benefit from a more comprehensive vision and must avoid rules or assumptions that might lock ECCs into a particular approach to implementing NG9-1-1.”
“As the NPRM recognizes, the NG911 transition is happening -- successfully -- today,” said CTIA. Any deadlines to deliver traffic in NG911-compatible format should be “sufficiently flexible to account for challenges or delays that may be outside of originating service providers’ control, as was the case in the transition to E911,” the wireless association said. The FCC should also clarify that the emergency services IP network (ESInet) is “the default demarcation point for cost allocation in the NG911 environment,” CTIA said.
ESInets are “often the foundational step that 911 authorities take towards implementing NG911 and, similar to the adoption of E911 services, NG911 implementation will be the product of significant collaboration among a multitude of stakeholders,” including originating service providers (OSPs), 911 authorities, PSAPs and PSAP vendors, CTIA said.
T-Mobile urged the FCC to clarify that in the absence of mutually agreed points of interconnection between OSPs and 911 authorities, when a PSAP “sits behind” an ESINet, “designated interconnection points for delivery of traffic to that PSAP must be no further than an ingress point of the ESINet.” T-Mobile said without that clarification, “the proposed rule could lead to situations where OSPs are required to take on functions and outlays that would be more appropriate for an ESINet.” Requiring providers to connect directly to PSAPs already connected to an ESINet “could burden OSPs with transport and traffic obligations that more appropriately rest with the ESINet operator,” the carrier said.
ATIS suggested numerous changes to the proposed rules. Among them, the FCC should “establish a reasonable limit on the number of interconnection points but not dictate the location of interconnection points; allow the establishment of reasonable business agreements between 911 authorities and service providers to facilitate the selection of the points of interconnection” and “allow for flexibility in the use and deployment of Legacy Network Gateways,” ATIS said.