Seven industry and public safety entities have proposed to the FCC principles to help address governance and accountability issues related to the deployment of next-generation 911 (NG-911) systems. They say they are continuing to work on “a more specific statement of needs and objectives, considerations, and proposed actions, including timeframes related to those proposals” and expect to have it ready in September. “The principles are designed to aid the FCC’s efforts to address the complex governance, accountability, and reliability issues presented by today’s evolving 911 systems and services, and to respond directly to the FCC’s challenge to industry and public safety to collaborate on best practices,” according to a news release.
The following entities submitted an ex parte filing yesterday in PS dockets 14-193 and 13-75 outlining their work and including the principles and items under consideration for the follow-up recommendations: the National Emergency Number Association, the National Association of State 9-1-1 Administrators, the Industry Council for Emergency Response Technologies, the Alliance for Telecommunications Industry Solutions, the U.S. Telecom Association, the Texas Commission on State Emergency Communications, and the Texas 9-1-1 Alliance.
The entities’ filing came in a proceeding in which the FCC has proposed requiring 911 communications carriers to provide public notice of major service outages and requiring potential new providers to certify their technical and operational qualifications. The Commission also adopted a policy statement along with its notice of proposed rulemaking.
In response to the NPRM, a myriad of industry entities criticized the proposed FCC mandates, while some state, 911, and public safety entities said that while they support some of the FCC’s proposals, they oppose any action that would usurp state and local control over public safety answering points (PSAPs) (TRDaily, March 24). “The undersigned group of public and private sector 9-1-1 stakeholders have been collaborating on issues raised in the Commission’s 9-1-1 Governance Notice of Proposed Rulemaking (‘NPRM’) in the above-referenced proceedings since before initial comments were filed in the matter,” according to yesterday’s filing. ”
The general purpose of this collaboration has been to seek alternatives and specific suggestions consistent with the Commission’s articulated Policy Statement framework for the ongoing migration and transition towards Next Generation 9-1-1 (‘NG9-1-1’). After some initial discussions, the group’s collaborative efforts have become organized into two separate but interrelated parts. The first part is a set of high-level principles (‘Principles’), and the second part is a more specific statement of needs and objectives, considerations, and proposed actions, including timeframes related to those proposals (‘Considerations & Proposed Actions’).”
The filing said the coalition hopes the principles and recommendations can be considered as “possible alternatives to additional federal regulations or, at a minimum, [offer] a new perspective on what the group believes should be well considered in the Commission’s open proceeding.” It also said the entities hope their output will be “adopted by the industry as a form of Best Practices with attendant commitments thereto which would signal to the Commission that the industry recognizes its special role in protecting the public interest and lives and property of Americans and the need to act voluntarily on these issues at this historic time.”
The filing added, “Work on the Principles has been completed, and they are included here as a separate attachment. However, the issues included in the Considerations & Proposed Actions are many and complex; therefore, work on the Considerations & Proposed Actions is ongoing, and more work needs to be done before more specific technical recommendations on suggested paths forward are ready to be submitted by the group. The intent is that the Considerations & Proposed Actions will be shared as a separate, follow-up ex parte filing. The group has targeted September, 2015 for completion of the Considerations & Proposed Actions and believes it will meet this target.”
The groups said that items being discussed for recommendations “include: (1) An update on the reliability and impairment issues that should be the focus of future development work as 9-1-1 services continue to transition to NG9-1-1; (2) A clarification of key terms and concepts in order to promote clear, accurate, and effective communications among stakeholders and more effective 9-1-1 governance; (3) A clarification of the scope of service providers’ and PSAPs’ monitoring and situational awareness reporting roles and responsibilities, whether through existing Network Operations Center functions or some other appropriate method; (4) The facilitation of coordinated resolution processes and support capabilities on a nationwide basis; and (5) The facilitation of improvements in standards to support the effective transition of 9-1-1 to NG9-1-1 systems and services and methods to appropriately verify and document to interested 9-1-1 stakeholders that new deployments meet those standards.
“Both the Principles and the Considerations & Proposed Actions would potentially benefit from additional 9-1-1 stakeholder discussion in public fora – such as in a Commission Workshop or in a NENA Critical Issues Forum,” the filing continued.
“The group strongly urges the FCC to support such additional collaborative discussions and commits to support such initiatives should they be utilized.” The principles cover the IP transition and NG-911, 911 governance, and 911 reliability.
“Efforts should be made to accelerate the continued development and implementation of NG911 standards and systems, while assuring reliability (including where systems serve diverse geographic areas),” the document said.
As for 911 governance, it noted that government authorities at all levels, 911 service providers, and other providers have roles regarding ensuring 911 reliability, and it said these roles should be evaluated with the deployment of NG-911 services. It also said that “terminology that applies to NG911 should be fine-tuned,” and that while 911 service providers are “accountable for the reliability of their services,” vendors can help achieve their goals.
“Recommendations for further enhancements to the governance of 911 systems and services should be developed by an advisory committee comprised of NARUC, NASNA, NENA, APCO, and other organizations representing state, local, regional 911, and industry officials, whose recommendations would be augmented by public comment,” the document added. As for 911 reliability, it said the NG-911 transition must be done in a way that doesn’t undermine the system.
It also said that an FCC rule change on covered service providers (CSPs) to include subcontractors “should evaluate the relative effectiveness of regulation as compared to contract provisions between the CSP and its subcontractors.” “Collaboration and consensus-based forums should be used to develop and finalize voluntary best practices for providing public safety grade NG911 services, including examining overall monitoring, reliability, notifications, and accountability in NG911 environments, which should be accomplished in an appropriate and timely manner,” the document said.
In its comments on the NPRM, NENA expressed support for the policy statement and a number of the FCC’s proposals while suggesting that it was worth exploring whether a consensus proposal with industry could be developed, similar to the way NENA and the Association of Public-Safety Communications Officials-International negotiated agreements with major wireless carriers in the FCC’s text-to-911 and 911 location accuracy proceedings. APCO is not among those working on NG-911 principles and recommendations. In response to a question about why it is not part of the coalition, APCO Executive Director Derek Poarch said in a statement, “We appreciate the work done by the groups on this matter and will continue to monitor developments. APCO’s positions have been stated in its publicly filed comments in this proceeding.”- Paul Kirby, paul.kirby@wolterskluwer.com