October 15, 2024 by Flynn Nogueira

NG911 FCC Report and Order: Responsibilities for OSPs

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Industries: 9-1-1 & Law Enforcement

Topics: NG9-1-1 PSAPs Public Safety Applications

In July the Federal Communications Commission (FCC or Commission) adopted a Report and Order in an effort to help expedite the transition to NG911 nationwide. The Commission’s rules define the responsibilities and deadlines for OSPs (Originating Service Providers) to deliver 911 calls to points of interconnection designated by a 911 Authority using Internet Protocol (IP) in commonly accepted standards format. 

What the order requires 

The order requires OSPs, specifically (1) wireline providers; (2) commercial mobile radio service (CMRS) providers; (3) covered text providers; (4) interconnected Voice over Internet Protocol (VoIP) providers; and (5) Internet-based Telecommunications Relay Service (TRS) providers to transition to NG911 call delivery in two phases. To commence each phase, the 911 Authority must submit a valid request to OSPs within the 911 Authority’s jurisdiction. 

Frequently Asked Questions

Below are some of the questions we are receiving from agencies regarding the Report and Order. 

What entity is responsible for implementing requirements as stipulated in the Report and Order?

The Report and Order speaks to what the OSPs must do after receiving a valid request from a 911 Authority.  It also defines what a 911 Authority must do in order to submit a valid request, but it does not state any requirements for the 911 Authority as far as the type of technology they are using to meet the Phase 1 and 2 requirements.

Does the Report and Order require PSAPs to have a compliant call handling system?

No. The order does not speak to call handling system requirements or place any call handling system requirements upon 911 authorities.

Does the Report and Order require NGCS providers to interoperate between each other using NENA accepted standards?

No. The order does not speak to any requirements for interoperation between 911 call routing / NGCS service providers.

Does the order eliminate legacy selective routers?

No. The order does not directly force the elimination of the use of legacy selective routers. Even though the order sets timelines for the OSPs to respond to valid 911 authority requests, it does not set a timeline for the 911 authorities or their respective 911 call routing service providers. 

What entity is responsible for the costs to implement the Report and Order?

The Commission states that the OSPs will be responsible for the cost of transmitting 9-1-1 traffic from their end users to the points of interconnection designated by 911 Authorities. 

What are some of the differences between Phase 1 and Phase 2?

Where the requirement for Phase 1 is more generic, i.e., a SIP connection, Phase 2 is more detailed and requires OSPs to deliver traffic in a format that complies with commonly accepted standards such as, for example, the NENA i3 standard. 

What does a valid request mean?

A valid request for Phase 1 means the 911 Authority has the infrastructure installed and operational to receive 911 traffic in SIP format and then transmit the traffic to the PSAP(s) connected to it.  

A valid request for Phase 2 means the 911 Authority has all of the necessary infrastructure installed and operational to receive 911 traffic in SIP format that complies with NG911 commonly accepted standards and to transmit the traffic to the PSAPs connected to it; and that its ESInet is connected to a fully functioning NGCS network that can provide access to a Location Validation Function (LVF) and interface with the Location Information Server (LIS) or functional equivalent provided by the OSP. 

For both Phase 1 and Phase 2 requests, a 911 Authority must also: identify the specific points for delivery of traffic; certify that it has commitments from a provider to facilitate and complete connectivity testing with OSPs; certify that it is authorized to submit a valid request; and provide the appropriate notification of the request to the OSPs.

How will the 911 Authority identify the NG911 Delivery Points?

NG911 Delivery Points are defined as geographic locations, facilities, or demarcation points where the OSPs transmit 911 traffic to NG911 network facilities or ESInets.  The 911 Authority will designate to the OSPs their desired NG911 Delivery Points when making a valid Phase 1 or 2 request. Unless negotiated otherwise between the 911 Authority, the call routing provider and the OSP, the NG911 Delivery Points must be located within the same state as the PSAPs connected to the ESInet. 

Does the Report and Order affect location-based routing?

The Report and Order does not set forth requirements related to location based routing for either the OSPs or the 911 call routing service providers.  

Does the Report and Order require OSPs to deliver location to the call?

Phase II requirements set forth by the Report and Order do require OSPs to deliver 911 traffic in an IP-based SIP format that complies with NG911 “commonly accepted standards.”  If the commonly accepted format is assumed to be NENA i3, the standard gives OSPs the option on a per-call basis to deliver location by value or by reference, or both, at the sole discretion of OSP. 

Next steps

Motorola Solutions will move expeditiously and work closely with the 911 Authorities we serve to take advantage of the benefits of this order.  

For more information on Motorola Solutions call routing service, visit us at www.motorolasolutions.com/callrouting 

Contact us to find out more about our solutions and services.

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