911 Adminstrators Still Absorbing NPRM

Bailey told us on Tuesday. Several LECs we contacted were also still reviewing the NPRM and had no comment. The notice deals with changes it says have made providing 911 more “complex.” While legacy 911 services were provided by ILECs, a growing number of system service providers (SSPs) have become involved, offering “specialized components … within the chain of connectivity previously provided by a single entity,” the NPRM said. “A growing number of disruptions to 911 service are caused by software malfunctions, database failures, and errors in conversion from legacy to IP-based network protocols,” the proposal said. The SSPs can be located in a different state than public safety answering points (PSAPs), and “have the potential to affect many states at once, or even all of a service provider’s customers nationwide,” the NPRM said. The seven-state 911 outage in April (see 1410170057) was caused by a software coding error at an SSP’s call routing facility, it said. In response, the NPRM proposes a policy statement that it “encourages and supports” local authority over 911. But in saying the commission has a responsibility to oversee “the increasingly complex component pieces of the nation’s 911 infrastructure,” it proposes a greater role for the agency. It would expand rules on 911 reliability to cover “all entities that provide 911, E911, or NG911 capabilities … regardless of whether they provide such capabilities under a direct contractual relationship with a PSAP.” The NPRM also proposed expanding requirements on providers to mandating “the reliability and testing of software and databases used to process 911 calls.” The NPRM also seeks comment on whether service providers should be required to notify the commission and the public of any major changes to the providers’ 911 network architecture or services, and whether to require commission approval to “discontinue, reduce, or impair” 911 services. States would continue to have authority to certify new 911 providers in their areas, but given the impact providers can have across state lines, the NPRM also proposed requiring new providers to certify to the commission they have the “technical and operational capability to provide reliable 911 service.” The new providers, though, would not be subject to commission approval, it said. The NPRM was approved on a party-line vote, with both commissioners Mike O’Rielly and Ajit Pai saying in dissents that the FCC was overstepping its authority into what’s been a local responsibility. “Replacing state and local governance with Washington-knows-best bureaucracy will leave 911 systems less nimble and responsive to the needs of local communities,” said Pai, who opposed the certification process. He asked, “How many 911 providers will simply decide not to offer an innovative, new capability because of the FCC’s all-encompassing process?” O’Rielly said the notice “does not even bother to attempt a cost-benefit analysis for this greatly expanded regulatory scheme.”