On July 18, 2024, the Federal Communications Commission (FCC) adopted a Report and Order (Order) to facilitate the transition from a traditional circuit-switched 911 system to an Internet Protocol (IP)-based system. An IP-based 911 system – known as Nest Generation 911, or NG911 -- will support new 911 capabilities, including text, video, and data, and also improve 911 interoperability, security, and system resilience. 

A 911 system has two critical actors: (1) an originating service provider (OSP), which is typically the communications carrier originating a 911 caller’s call, and (2) a 911 Authority, which is the state, local or Tribal entity responsible for operating or overseeing the network facilities used for receiving 911 calls from the OSP and delivering them to Public Safety Answering Points (PSAPs). For the NG911 transition to occur, both OSPs and 911 Authorities will need to upgrade their facilities and improve their communications and coordination with one another. The FCC’s Order is aimed at kick-starting that process by adopting the first nationwide NG911 transition rules that define OSPs’ responsibilities to implement NG911 capabilities on their networks and deliver 911 calls to NG911 systems. The new rules also set deadlines for OSPs to fulfill those obligations. 

The Order requires an OSP, in response to valid requests from a 911 Authority, to complete all protocol translation and routing required to deliver 911 traffic, including associated location information, to the requesting 911 Authority in IP-based format. This process has two phases. 

Phase 1 Upon receipt of a 911 Authority’s valid Phase 1 request, an OSP must:

• Deliver all 911 traffic bound for the relevant PSAPs in the IP-based Session Initiation Protocol (SIP) format requested by the 911 Authority;
• Obtain and deliver 911 traffic to enable the Emergency Services IP Networks (ESInets) and other NG911 network facilities to transmit all 911 traffic to the destination PSAP;
• Deliver all such 911 traffic to one or more in-state NG911 Delivery Points designated by the 911 Authority, and 
• Complete connectivity testing to confirm that the 911 Authority receives 911 traffic in the IP-based SIP format requested by the 911 Authority.

For a Phase 1 request to be valid, the requesting 911 Authority must certify that it has all of the necessary infrastructure installed and operational to receive 911 traffic in a basic SIP format and transmit such traffic to the PSAP(s) connected to it. The completion of Phase 1 is a prerequisite to Phase 2.

Phase 2 Upon receipt of a 911 Authority’s valid Phase 2 request, an OSP must:

• Deliver all 911 traffic bound for relevant PSAPs to NG911 Delivery Points specified by the 911 Authority;
• Ensure all 911 traffic is delivered in an IP-based SIP format that adheres to NG911 commonly accepted standards as specified by the 911 Authority;
• Embed location details in call signaling using Presence Information Data Format – Location Object (PIDF-LO) or its functional equivalent, ensuring accurate location data transmission;
• Install and activate necessary equipment, software applications, and other infrastructure to support the use of a Location Information Server (LIS) or equivalent system;
• Use the LIS or its equivalent to verify customer location information and records, ensuring accuracy in emergency response; and 
• Conduct comprehensive connectivity tests to verify that the 911 Authority receives all 911 traffic in the specified IP-based SIP format compliant with NG911 standards.

For a Phase 2 request to be valid, the requesting 911 Authority must certify that it has installed all of the necessary infrastructure and is operational to receive 911 traffic in SIP format that complies with NG911 commonly accepted standards and to transmit such traffic to the PSAP(s) connected to it. The 911 Authority also must certify that its ESInet is connected to a fully functioning Next Generation 911 Core Services (NGCS) network that can provide access to a Location Validation Function (LVF) and interface with a LIS or its functional equivalent provided by the OSP.

Phase 1 and Phase 2 Notifications. A 911 Authority’s Phase 1 and Phase 2 requests can be provided to OSPs by either: (1) submission to the FCC-provided registry, or (2) direct written notification to individual OSPs.

Challenging the Validity of a Phase Request. If an OSP believes that a 911 Authority has submitted an invalid or premature Phase 1 or 2 request, it may submit a petition challenging the 911 Authority’s request. The petition must be submitted within 60 days of receipt of the request, must be signed by a director or officer of the OSP, and must document the basis for the OSP’s assertion that the request does not satisfy a requirement or requirements of a Phase 1 or 2 valid request.

Timelines. The Order establishes timelines for OSPs to implement Phase 1 and Phase 2 following a 911 Authority’s valid request. Depending on the type of OSP, compliance is required within 6 or 12 months of such request. 

If an OSP provides more than one type of service across its communication network, and as a result, is subject to both the 6- and 12-month timelines, the OSP may comply with its Phase 1 and Phase 2 obligations under the later of the two deadlines. 

Responsibility for Costs. The Order establishes default rules regarding the allocation of cost responsibility for the NG911 transition. OSPs will be responsible for the cost of transmitting 911 traffic from their end users to the points of interconnection designated by 911 Authorities (i.e., NG911 Delivery Points). OSPs must also bear the cost of compatibility testing. 911 Authorities are responsible for the cost of transmitting calls from NG911 Delivery Points to PSAPs or for any reformatting or call translation within the NG911 network beyond the point where the OSP has handed off the call. 

Modification of Order Requirements under Mutual Agreement. The Order acknowledges the need for flexibility throughout the NG911 transition process. Accordingly, the Order allows OSPs and 911 Authorities to enter into mutual agreements specifying requirements, timetables, and other terms that are different from the Phase 1 and Phase 2 rules. If, and when, OSPs and 911 Authorities enter into an alternative agreement, OSPs must notify the FCC of the agreement and its pertinent terms within 30 days of the execution date.

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