NENA, NASNA Detail Complaints With NG-911 Legislation

Courtesy ~ TR Daily

NENA and the National Association of State 911 Administrators have detailed their complaints with next-generation 911 legislation included in the Leading Infrastructure For Tomorrow’s America (LIFT America) Act, including the treatment of NENA’s i3 standard, shortcomings concerning  interoperability and reliability language, and the need for explicit authorization to use grant funds for cybersecurity.

The LIFT America Act, which was introduced by the 32 Democrats on the House Energy and Commerce Committee (TR Daily, March 11), includes $15 billion for grants to fund NG-911 deployment.

The Public Safety Next Generation 9-1-1 Coalition, which is backed by eight major public safety groups, has endorsed the NG-911 provisions (TR Daily, March 18). 

But in a letter dated Friday but not released until today to the leaders of the House Commerce Committee and its communications and technology subcommittee, NENA and NASNA said, “The LIFT America Act recognizes that the governance and control of 911 systems, including NG911, should remain at the State, regional, and local level. At the same time, it establishes a nationwide framework to facilitate cooperation among Federal, State, and local officials and to promote the interoperability and reliability of NG911 systems. NASNA and NENA support these important objectives but believe they would be undermined by some of the Act’s provisions. Congress must act to rectify the following provisions or risk compromising NG911 for many years ahead.”

The groups complained that the legislation “fails to fully account” for NENA’s i3 standard “ecosystem,” noting that it would require the standard to be approved by the American National Standards Institute and “meet the definition of interoperable” in the bill while not requiring other standards to meet that definition. “The result of these distinctions borders on absurd,” NENA and NASNA argued.

The groups said that lawmakers should modify the bill so “‘commonly accepted standards’ means standards followed by the communications industry that enable interoperability, are consensus-based, and are developed by recognized standards development organizations.”

Regarding interoperability, NENA and NASNA called for “an additional explicit requirement in the legislation that NG911 systems be interoperable and that grant applicants take steps to demonstrate in their state plans how they will achieve interoperability.”

Congress should “either make clear in the legislative language that the definition of ‘interoperable’ in the Act only applies to NG911 or, alternatively, to modify the definition of ‘interoperable’ in a way that ensures interoperability between NG911 systems and legacy 911 systems,” they added.

As for reliability, NENA and NASNA said that “the reliability requirements imposed on NG911 grant recipients should be consistent with the FCC’s rules, as State 911 authorities will necessarily look to NG911 service providers to comply with any grant obligations.”

They also bemoaned the fact that “while the Act generally authorizes the use of NG911 grant funds for ‘implementation of NG911,’ it does not explicitly authorize cybersecurity expenses. NASNA and NENA believe that such expenditures should be expressly permitted. Notably, some states have already implemented an NG911 system but may have plans to establish an emergency communications cybersecurity center (EC3) to provide intrusion detection and protection services for PSAPs in their states. The implementation of State-based EC3s was recommended by the FCC’s Task Force on Optimal PSAP Architecture (TFOPA) as an efficient and effective framework for addressing cyber-based threats; this concept was also endorsed by CSRIC.”

The groups also said that “the Act should require NG911 grant applicants to certify annually that they are employing effective cybersecurity resources to protect NG911 systems and services from cyber-based attacks. While the Act requires applicants to address cybersecurity resources in their State plans, we believe that annual certification from the grant recipient that effective measures are being employed will provide additional assurance that NG911 systems will be protected.”

NENA and NASNA said they “oppose the establishment of a Federally managed security operations center (SOC) to manage cybersecurity on behalf of the nation’s PSAPs. While the security of our nation’s 911 systems is vital, the solution outlined in the Act would undermine State and local control of 911 systems, inject significant and complex privacy, technical and legal challenges into the NG911 implementation and operations process, and impose additional costs and administrative burdens on the National 911 Program — all without a clear roadmap for success.”

NENA and NASNA also said there is no need to establish an NG911 Advisory Board. If lawmakers keep such a provision in the legislation, any board should have NG-911 experts, the board should not add costs to the grant process, the board should only advise on grant guidelines, and the board should not be exempt from the Federal Advisory Committee Act, according to the groups. —Paul Kirby,

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