In July the FCC released a Report and Order about Next Generation 911 services (NG911) and it contains a lot of rules for Originating Service Providers – which at first glance look quite concerning.
For example:
Today, we require OSPs to complete in two phases all translation and routing to deliver 911 traffic, including associated location information, in the requested IP-based format. In Phase 1, OSPs will be required to deliver 911 traffic in a basic SIP format, thereby implementing the fundamental IP translation or transport that is a prerequisite for the delivery of 911 traffic in SIP format that complies with commonly accepted standards. In Phase 2, OSPs will be required to deliver 911 traffic in SIP format that complies with NG911 commonly accepted standards.
In other words:
- For Phase 1, you need to send 911 calls over SIP.
- For Phase 2, you need to add location information (e.g. PIDF-LO) into those SIP messages.
However, it’s easy to overlook the fact that none of this is relevant unless your local “911 Authority” (typically the state) updates all their 911 infrastructure and then sends you a request to move to NG911.
There are some states that have already undertaken large projects to move over to NG911, but others haven’t really gotten started.
Does this FCC ruling mean that everyone’s going to switch to NG911 in the near future?
No. From what I’ve read, the purpose of this FCC report and order is to make clear to originating service providers that you are obligated to comply when the local 911 Authority tells you they’re ready.
I couldn’t find anywhere in the report where the FCC required the local 911 Authority to move to NG911 on any specific timescale – the local state bodies have a lot of say in both when and how they move to NG911 – the FCC is merely saying that “when the state is ready, you need to go along with their plan”.
We encourage OSPs and 911 Authorities to collaborate throughout the transition to NG911. To facilitate such collaboration, and consistent with our proposals in the NG911 Notice and LBR Notice, we permit 911 Authorities and OSPs to enter into mutual agreements specifying requirements, timetables, and other terms that are different from the Phase 1 and Phase 2 rules adopted in this Order.
Do I need to do anything?
Unless you’ve been notified of a new 911 requirement from your state, this FCC ruling doesn’t seem to require any action on your part.
However, if you have a TDM-only switch, then you need to beware that you may soon need to send 911 calls over SIP. You might want to consider upgrading your switch to something more modern, or potentially adding a media gateway that can convert from TDM to SIP for these calls. Please reach out to us to learn more about how TelcoBridges media gateways could help out with this situation.
Phase 2 of the NG911 roll-out (as foreseen by the FCC) would require the inclusion of location information (e.g. the SIP PIDF-LO header) on 911 calls. The Metaswitch CFS supports passing through these headers when provided by a SIP client – functionality that is focused on compliance with Ray Baum’s Act for soft-clients on moveable devices. For fixed lines the location information has typically been provided from the ALI database, which is used by the PSAP to map DNs to an address – rather than being sent in the voice signaling. I’m not clear whether local 911 Authorities are going to change that requirement, but the FCC seems to be expecting the OSPs to figure that out for phase 2 of the NG911 roll-out.
OSPs must also install and put into operation all equipment, software applications, and other infrastructure necessary to use a LIS or its functional equivalent for the verification of its customer location information and records, or else to acquire such services.
If anyone has done this already, please contact me to share your experiences, because we haven’t yet worked with a scenario where the PIDF-LO was being fed into the switch from a LIS database. Hopefully we’ll get it all figured before the first 911 Authority mandates this approach!
