21-479 — Comment Digest

The necessity and scope of certification and testing for ensuring NG911 interoperability are debated.

Filers split on: “The Commission should mandate annual interoperability testing and certification for NG911 providers.”

• Colorado Council of Authoritiessupport — The organization views this requirement as essential for ensuring that CSPs prioritize interoperability, which is crucial for the effective functioning of NG911.p. 3
• Palmetto Broadband Coalitionsupport — The commenter emphasizes the life-or-death nature of NG911 calls and the importance of ensuring that networks are resilient and interoperable. They argue that these requirements should apply to all providers involved in NG911 services to ensure proper oversight.p. 1
• APCO International APCO NG9 1 1support — The organization believes that these testing methods are essential to ensure that emergency communications centers can effectively transfer 911 calls and data across different networks.p. 4
• Home Telephone ILECsupport — Home supports the need for interoperability to maintain a reliable 911 system and suggests that federal certification should include fail-over interoperability capabilities.p. 12
• Brian Rosensupport — The commenter believes that trusting suppliers is insufficient and that auditing and certification are essential to ensure reliability in NG9-1-1 systems.p. 2
• Verizon 09 17 2025 Verizon NG911 Reliabilityoppose — Verizon argues that the proposed new certifications would not significantly enhance 911 reliability and would instead create additional regulatory challenges. They advocate for flexibility in applying any new standards.p. 4

The process and requirements for sharing reliability certifications with 911 Authorities are debated.

Filers split on: “The Commission should require CSPs to share reliability certifications with 911 Authorities.”

• DATAMARK Technologies DATAMARKsupport — The commenter expresses support for the FCC's initiatives aimed at enhancing the reliability of 911 services, indicating a commitment to improving public safety communications.p. 3
• Lumen 250804 Lumenmodify — Lumen believes that while access to reliability certifications is important for enhancing oversight and collaboration in the NG911 ecosystem, it should not impose unnecessary burdens on Communication Service Providers (CSPs) by requiring direct sharing with 911 Authorities.pp. 13, 14
• Home Telephone ILECsupport — Home believes that such a system would enhance visibility into the reliability of national aggregators and transport providers, benefiting state authorities and PSAPs.p. 3
• Palmetto Broadband Coalitionsupport — The commenter believes that applying these requirements to all relevant providers will enhance oversight and accountability in emergency services. They commend the Commission's efforts to establish these standards.p. 1
• Colorado Council of Authoritiessupport — The organization highlights the necessity of clear and reliable information from Communication Service Providers (CSPs) for effective operational planning by 911 Authorities, and underscores the importance of adopting changes that have received support from various public safety commenters, reflecting a consensus on the need for these improvements.pp. 2, 6
• Boulder Regional Emergency Telephone Service A — The Commission should ensure that any new service has a reliable method for delivering emergency calls to PSAPs before it is allowed to operate.p. 13

The adequacy and impact of proposed reliability benchmarks for NG911 systems are contested.

Filers split on: “The Commission should revise the proposed reliability requirements for NG911 systems.”

• Industry Council for Emergency Response Technooppose — iCERT argues that the proposed reliability requirements do not reflect the realities of NG911 systems and could lead to non-compliance findings even when CSPs are following best practices.p. 7
• Intrado Life Safetyoppose — The commenter believes that the current regulatory framework under Part 4 is sufficient for overseeing the OSP network without the need for expanded definitions or new benchmarks, and argues that the proposed reliability benchmarks fail to account for the technical realities of IP networks and the interdependencies between providers, advocating for a more flexible approach that aligns with the unique characteristics of NG911 deployments.pp. 6, 9
• Lumen 250917 Lumenoppose — Lumen emphasizes that existing requirements already ensure compliance and that additional requirements would not enhance the reliability of 911 calls.p. 9
• Kelly Daniels Docket 21 479modify — The commenter points out that the existing systems fail to track unsuccessful calls within the originating carriers' networks, which compromises the reliability goals set by the FCC and endangers public safety.p. 4
• Comtech Telecommunicationsmodify — Comtech emphasizes that any new reliability benchmarks must be flexible and based on current industry standards to remain relevant.p. 17
• NENA The 9 1 1 Association NENA NG911modify — NENA reiterates its call for a formal task force to develop best practices for reliability, highlighting broad consensus on this need among stakeholders.p. 5

The scope of the definition of Covered Service Providers (CSPs) and its implications are debated.

Filers split on: “The Commission should simplify the CSP definition to prevent redundancy and confusion.”

• NCTA The Internet Television Association 09172oppose — The commenter believes that including all indirect service providers in the CSP definition would unnecessarily increase compliance costs and complicate the reliability certification process without adding value.p. 5
• DATAMARK Technologies DATAMARKsupport — DATAMARK argues that the Commission's proposed updates to the CSP definition should simplify existing rules to prevent redundancy and confusion among service providers.p. 4
• Industry Council for Emergency Response Technomodify — iCERT emphasizes that CSPs should not be required to certify aspects of network architecture that are outside their control, as this imposes unrealistic obligations.p. 13
• Public Knowledge PK NG911 FNPRMmodify — Public Knowledge insists that the Commission must ensure that CSPs are held accountable for protecting consumer information, including requiring annual certifications and oversight.p. 7
• Verizon 08 04 2025 Verizon NG911 Reliabilityoppose — Verizon argues that the current rules provide regulatory certainty and effectively delineate responsibilities between Originating Service Providers (OSPs) and Covered Service Providers (CSPs). They believe that the proposed changes introduce unnecessary uncertainty.p. 3
• NENA The 9 1 1 Association NENA NG911modify — NENA insists that the CSP should be defined as the entity that has a direct contract with the 9-1-1 authority, including any subcontractors.p. 5

Whether iTRS providers should be subject to the same reliability requirements as other service providers is debated.

Filers split on: “The Commission should exempt iTRS providers from NG911 reliability requirements.”

• ClearCaptionssupport — ClearCaptions contends that iTRS providers should not be held accountable for compliance with technical rules since they do not manage the routing and delivery of 911 calls, and they express concern that the proposed changes may impose reliability requirements on iTRS providers that they are unable to fulfill due to their dependence on third parties.pp. 3, 4
• Hamilton Relaymodify — Hamilton points out that TRS providers, including itself, already have obligations to handle 911 calls, which should be taken into account when considering new rules.p. 3
• CTIA 250917 CTIA NG911 Reliability FNPRMoppose — CTIA contends that existing enforcement mechanisms are sufficient and that a new regime could create inconsistencies and hinder collaboration.p. 12
• Industry Council for Emergency Response Technomodify — iCERT stresses the importance of aligning reliability requirements with commonly accepted standards to avoid conflicts and ensure adaptability as technology evolves.p. 15
• Intrado Life Safetymodify — Intrado raises concerns that disclosing detailed network information could pose security risks and suggests limiting the information shared to protect sensitive data.p. 22

The timing and potential impact of introducing new NG911 requirements are debated.

Filers split on: “The Commission should delay new NG911 requirements to allow existing frameworks to take root.”

• USTelecom The Broadband Association 2025.9.17 support — USTelecom contends that stakeholders require time and flexibility to implement existing rules before introducing additional mandates, emphasizing that a rushed approach could divert resources and hinder the transition to NG911. The comment also notes a consensus among stakeholders advocating for the Commission to allow the current NG911 transition framework to establish itself before imposing new requirements, which could create unnecessary burdens.pp. 1, 2
• Intrado Life Safetysupport — Intrado highlights that many stakeholders, including service providers and public safety organizations, express concerns about adopting the Commission's proposals without a deeper understanding of operational issues. They argue that rushing into regulation could lead to inflexible rules that do not adequately address the needs of the NG911 environment.p. 1
• Alliance for Telecommunications Industry Solutsupport — ATIS believes that many areas are still in the early stages of transitioning to NG911, and introducing new requirements could hinder progress and impose unnecessary costs.p. 6
• Bandwidthsupport — Bandwidth argues that the current focus on NG911 is misplaced as the industry is still grappling with fundamental issues related to the PSTN's viability during the transition to NG911.p. 1
• The Alarm Industry Communications Committee AImodify — AICC emphasizes the need to balance the introduction of new technologies with the operational realities faced by PSAPs to maintain public trust in emergency services.p. 10

The method for achieving interoperability in NG911 networks is debated.

Filers split on: “The Commission should adopt a hybrid model for NG911 interoperability.”

• T Mobile USAsupport — T-Mobile recommends a hybrid model for achieving interoperability that combines structured requests from 911 Authorities with flexible, standards-driven development. This approach is intended to ensure that interoperability is based on real-world needs rather than theoretical scenarios.p. 6
• Motorola Solutions Connectivityoppose — Motorola Solutions Connectivity, Inc. believes that industry-led efforts are essential for achieving interoperability in NG911 networks, as local needs vary and can be better addressed through collaboration rather than prescriptive regulations.p. 1
• USTelecom The Broadband Association 2025.8.4 Umodify — USTelecom argues that a functionality-based definition will ensure that rules are effective and adaptable to the evolving NG911 ecosystem, avoiding overly broad classifications that could hinder innovation.p. 6
• Alliance for Telecommunications Industry Solutmodify — The organization argues that RCS operates in an 'over the top' model, creating compatibility issues with existing emergency voice systems and prioritization standards, and stresses the need to defer technical and standardization issues to the industry for resolution through open, consensus-based processes.pp. 4, 5