Framework for Next Generation 911 Deployment, 2297-2309 [2011-565]

Agencies

• FEDERAL COMMUNICATIONS COMMISSION

[Federal Register Volume 76, Number 9 (Thursday, January 13, 2011)]
[Proposed Rules]
[Pages 2297-2309]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-565]


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FEDERAL COMMUNICATIONS COMMISSION

47 CFR Part 20

[PS Docket No. 10-255; FCC 10-200]


Framework for Next Generation 911 Deployment

AGENCY: Federal Communications Commission

ACTION: Notice of inquiry.

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SUMMARY: The Notice of Inquiry (NOI) initiates a comprehensive 
proceeding to address how Next Generation 911 (NG911) can enable the 
public to obtain emergency assistance by means of advanced 
communications technologies beyond traditional voice-centric devices. 
The NOI seeks to gain a better understanding of how the gap between the 
capabilities of modern networks and devices and today's 911 system can 
be bridged and seeks comment on how to further the transition to IP-
based communications capabilities for emergency communications and 
NG911.

DATES: Submit comments on or before February 28, 2011. Submit reply 
comments March 14, 2011.

ADDRESSES: Pursuant to Sec. Sec.  1.415 and 1.419 of the Commission's 
rules, 47 CFR 1.415, 1.419, interested parties may file comments and 
reply comments. Comments may be filed using: (1) the Commission's 
Electronic Comment Filing System (ECFS), (2) the Federal Government's 
eRulemaking Portal, or (3) by filing paper copies. See Electronic 
Filing of Documents in Rulemaking Proceedings, 63 FR 24121 (May 1, 
1998).
     Electronic Filers: Comments may be filed electronically 
using the Internet by accessing the ECFS: https://fjallfoss.fcc.gov/ecfs2/ or the Federal eRulemaking Portal: https://www.regulations.gov.
     Paper Filers: Parties who choose to file by paper must 
file an original and four copies of each filing. If more than one 
docket or rulemaking number appears in the caption of this proceeding, 
filers must submit two additional copies for each additional docket or 
rulemaking number.
     Filings can be sent by hand or messenger delivery, by 
commercial overnight courier, or by first-class or overnight U.S. 
Postal Service mail. All filings must be addressed to the Commission's 
Secretary, Office of the Secretary, Federal Communications Commission.
     All hand-delivered or messenger-delivered paper filings 
for the Commission's Secretary must be delivered to FCC Headquarters at 
445

[[Page 2298]]

12th St., SW., Room TW-A325, Washington, DC 20554. The filing hours are 
8 a.m. to 7 p.m. All hand deliveries must be held together with rubber 
bands or fasteners. Any envelopes must be disposed of before entering 
the building.
     Commercial overnight mail (other than U.S. Postal Service 
Express Mail and Priority Mail) must be sent to 9300 East Hampton 
Drive, Capitol Heights, MD 20743.
     U.S. Postal Service first-class, Express, and Priority 
mail must be addressed to 445 12th Street, SW., Washington DC 20554.

FOR FURTHER INFORMATION CONTACT: Patrick Donovan, Public Safety and 
Homeland Security Bureau, at (202) 418-2413, Federal Communications 
Commission, 445 12th Street, SW., Washington, DC 20554; or via the 
Internet to Patrick.Donovan@fcc.gov.

SUPPLEMENTARY INFORMATION:

I. Introduction

    1. As recommended in the National Broadband Plan, this Notice of 
Inquiry (NOI) initiates a comprehensive proceeding to address how Next 
Generation 911 (NG911) can enable the public to obtain emergency 
assistance by means of advanced communications technologies beyond 
traditional voice-centric devices. In the telecommunications industry 
overall, competitive forces and technological innovation have ushered 
in an era of advanced Internet-Protocol (IP)-based devices and 
applications that have vastly enhanced the ability of the public to 
communicate and send and receive information. At the same time, our 
legacy circuit-switched 911 system is unable to accommodate the 
capabilities embedded in many of these advanced technologies, such as 
the ability to transmit and receive photos, text messages, and video. 
Accordingly, in this proceeding, we seek to gain a better understanding 
of how the gap between the capabilities of modern networks and devices 
and today's 911 system can be bridged. We also seek comment on how to 
further the transition to IP-based communications capabilities for 
emergency communications and NG911.

II. Background

    2. Since AT&T first made the digits ``911'' available nationally in 
1968 for wireline access to emergency services, the American public 
increasingly has come to depend on the service. Today, the National 
Emergency Number Association (NENA) estimates that some form of 911 
service is available to 99 percent of the population in 96 percent of 
the counties in the United States, and 240 million calls are made to 
911 in the United States each year. ``911'' is as well known as any 
popular brand, and is what we routinely teach to children as the way to 
summon help from police, fire, and ambulance services. In more recent 
times, 911 has become increasingly important for homeland security, as 
the means for ordinary citizens--in some ways the true ``first 
responders''--to report suspicious activity or summon emergency 
assistance for themselves and others in times of natural or man-made 
disasters. It should therefore come as no surprise that the American 
public has developed clear expectations with respect to the 
availability of 911 emergency services via certain classes of 
communications devices.
    3. The availability of this critical service is due largely to the 
dedicated efforts of State, local, and Tribal authorities and 
telecommunications carriers, who have used the 911 abbreviated dialing 
code to provide access to increasingly advanced and effective emergency 
service capabilities. Indeed, absent appropriate action by, and funding 
for, states, Tribes, and local jurisdictions, there can be no effective 
911 service.
    4. At the same time, new voice communications technologies have 
posed technical and operational challenges to the 911 system, 
necessitating the adoption of a uniform national approach to preserve 
the quality and reliability of 911 services for such communications 
technologies. This was first recognized following the introduction of 
commercial mobile radio services (CMRS) in the United States, when the 
Commission in 1996 established rules requiring CMRS carriers to 
implement basic 911 and Enhanced 911 (E911) services.
    5. In 1999, Congress continued this recognition when it enacted the 
Wireless Communications and Public Safety Act (911 Act) to promote and 
enhance public safety through the use of wireless communications 
services. The 911 Act directed the Commission to designate 911 as the 
universal emergency assistance number for wireless and wireline calls, 
and to establish a transition period for areas of the country where 911 
was not yet available. In 2000, the Commission adopted an order which 
established 911 as the universal emergency telephone number in the 
United States. In 2003, the Commission revised ``the scope of [its] 
enhanced 911 rules to clarify which technologies and services will be 
required to be capable of transmitting enhanced 911 information.'' In 
adopting rules tailored to specific services, the Commission clarified, 
inter alia, the following matters: (1) Telematics service providers 
offering interconnected CMRS voice calling service may have an E911 
service requirement and need to coordinate with the underlying wireless 
carriers, so that, regardless of the legal relationship between them, 
E911 requirements can be met; and (2) resold and prepaid mobile 
wireless service providers must meet 911 rules to the extent the 
underlying licensee has deployed the necessary technology for E911 
service. The Commission declined, however, to impose E911 requirements 
on: (1) Telematics-only services providers, reserving the right to 
revisit E911 obligations in the future, (2) manufacturers of disposable 
phones or personal data assistants (PDAs) that contain a voice service 
component, and (3) multi-line telephone systems, except for the 
Commission's monitoring of states' progress on implementing E911 for 
those systems.
    6. The next significant step in the evolution of 911 followed the 
introduction of Voice over Internet Protocol (VoIP) services in the 
United States. In this regard, in 2005, the Commission established 
rules requiring interconnected VoIP service providers to supply E911 
capabilities to their customers as a standard feature from wherever the 
customer is using the service.
    7. While the Commission and the 911 industry acted to enable 911 
service availability for wireless and VoIP providers, today's 911 
system remains reliant on increasingly antiquated analog or digital 
circuit-switched facilities. It is thus not capable of supporting 
certain functionalities made possible by a transition to broadband IP-
based communications technologies--functionalities that have become 
commonplace in other communications systems. At the same time, the 
introduction of these new technologies has created the potential for 
development of and transition to NG911 to take advantage of the 
enhanced capabilities of IP-based devices and networks.
    8. In the last few years, there have been several important efforts 
to address the need for a transition to a NG911 network. In the New and 
Emerging Technologies 911 Improvement Act of 2008, Congress tasked the 
National E9-1-1 Implementation Coordination Office (ICO) to develop ``a 
national plan for migrating to a national [Internet Protocol] IP-
enabled emergency network capable of receiving and responding to all 
citizen-activated emergency communications and improving information 
sharing among all

[[Page 2299]]

emergency response entities.'' The ICO, managed jointly by the 
Department of Commerce's National Telecommunications and Information 
Administration (NTIA) and the Department of Transportation's National 
Highway Traffic Safety Administration (NHTSA), released its migration 
plan in September 2009. In March 2010, NENA released a handbook to 
serve as a guide for public safety personnel and government officials 
responsible for ensuring that Federal, State, and local 911 laws and 
regulations effectively enable the implementation of NG911 systems. 
Specifically, the NENA Handbook provides an overview of key policy, 
regulatory, and legislative issues that need to be considered to enable 
the transition to NG911. The NENA Handbook states that ``it is critical 
that State regulatory bodies and the FCC take timely and carefully 
scrutinized action to analyze and update existing 9-1-1, PSTN, and IP 
rules and regulations to ensure they optimize 9-1-1 governing authority 
choices for E9-1-1 and NG9-1-1 and foster competition by establishing a 
competitively neutral marketplace.''
    9. On March 16, 2010, the Commission delivered the National 
Broadband Plan to Congress, which included several recommendations 
related to NG911. Specifically, the Plan noted that the Commission was 
already considering changes to its E911 location accuracy requirements 
and recommended that the Commission expand that proceeding to explore 
how NG911 may affect location accuracy and provision of automated 
location information. The Plan further recommended that the Commission 
initiate a new proceeding ``to address how NG911 can accommodate 
communications technologies, networks and architectures beyond 
traditional voice-centric devices,'' and to ``explore how public 
expectations may evolve in terms of the communications platforms the 
public would rely upon to request emergency services.''
    10. In September 2010, addressing the National Broadband Plan 
recommendation with respect to location accuracy, we adopted a Further 
Notice of Proposed Rulemaking and Notice of Inquiry in our E911 
Location Accuracy proceeding, in which we sought comment on a number of 
issues pertaining to the Commission's location accuracy rules, 
including the impact of NG911 deployments on location accuracy and 
Automatic Location Identification (ALI). The FNPRM and NOI was 
published in the Federal Register at 75 FR 67321, November 2, 2010. In 
the Location Accuracy FNPRM/NOI, we limited the scope of our NG911 
inquiry to location issues in the provision of voice-based services. In 
this Notice of Inquiry, we initiate the broader proceeding recommended 
in the National Broadband Plan concerning the migration to NG911.
    11. Most recently, on October 8, 2010, the Twenty-First Century 
Communications and Video Accessibility Act of 2010 (Twenty-First 
Century Act) was signed into law. The Twenty-First Century Act directs 
the Chairman of the Commission to establish an advisory committee, to 
be known as the Emergency Access Advisory Committee (EAAC), for the 
purpose of achieving equal access to emergency services by individuals 
with disabilities as part of our nation's migration to NG911. The 
Twenty-First Century Act also directs the EAAC to conduct a national 
survey with people with disabilities and make recommendations on the 
most effective and efficient technologies and methods to enable NG911 
access. The EAAC will be composed generally of State and local 
government representatives responsible for emergency management and 
emergency responder representatives, national organizations 
representing people with disabilities and senior citizens, 
communications equipment manufacturers, service providers, and subject 
matter experts.

III. Technical Comparison of Legacy 911 and Next Generation 911

    12. In order to understand the opportunities and challenges 
involved with deploying an NG911 system across the country, it is 
instructive to first briefly review how, as a technical matter, the 
current 911 system operates for wireline, wireless and interconnected 
VoIP 911 calls, and how NG911 will differ from legacy 911 in its 
applications and network architecture. For brevity, the discussion 
simplifies some of the technical details of both legacy and NG911 
systems.

A. Legacy 911

    13. In the United States, legacy 911 service generally falls into 
two categories--basic and enhanced. Basic 911 service transmits 911 
calls from the service provider's switch to a single geographically 
appropriate Public Safety Answering Point (PSAP) or public safety 
agency, usually over dedicated emergency trunks. Basic 911 networks are 
not capable of taking into account the caller's location, but simply 
forward all 911 calls from a particular PSTN switch to the appropriate 
PSAP or public safety agency. E911 service expands basic 911 service by 
not only delivering 911 calls to the appropriate PSAP or agency, but 
also providing the call taker with the caller's call back number, 
referred to as Automatic Numbering Information (ANI), and location 
information--a capability referred to as Automatic Location 
Identification (ALI). Most areas of the country have now implemented 
E911 service.
    14. Wireline E911. In wireline E911, PSAPs are connected to 
telephone switches by dedicated trunk lines. Wireline E911 networks 
generally have been implemented, operated, and maintained by a subset 
of incumbent LECs, and are largely paid for by PSAPs through tariffs. 
Network implementation varies from carrier to carrier and jurisdiction 
to jurisdiction, but usually is based on traditional circuit-switched 
architecture and implemented with legacy components that place 
significant limitations on the functions that can be performed over the 
network. Typically, a wireline E911 network utilizes a selective 
router, which receives 911 calls from competitive and incumbent LEC 
central offices over dedicated trunks. The selective router then 
queries an incumbent LEC-maintained selective router database (SRDB) to 
determine which PSAP serves the caller's geographic area. The selective 
router will then forward the call, along with the caller's phone number 
(i.e., ANI) to the PSAP that has been designated to serve the caller's 
area. The PSAP then forwards the caller's ANI to an incumbent LEC-
maintained Automatic Location Identification database (ALI database). 
The ALI database returns to the PSAP the caller's physical address 
(that has previously been verified by comparison to the MSAG). Wireline 
E911 networks also include a Database Management System (DBMS), which 
provides a method for competitive and incumbent LECs to enter customer 
data into both the SRDB and the ALI Database.
    15. Wireless E911. Under the Commission's wireless E911 rules, 
wireless carriers are obligated to provide the telephone number of the 
originator of a 911 call (i.e., ANI) and information regarding the 
caller's location (i.e., ALI) to any PSAP that has requested that such 
information be delivered with 911 calls. As explained in the VoIP 911 
Order and VoIP 911 NPRM, the mobile nature of wireless technology and 
other IP-enabled services presents significant obstacles to making E911 
effective--in particular the provision to PSAPs of accurate ALI. 
Specifically, the mobility of wireless service renders the use of 
permanent street addresses as a location indicator useless, and often 
requires the

[[Page 2300]]

provision of real-time location updates to the PSAP. In addition, the 
caller's phone number (i.e., the ANI information) may not be usable by 
the selective router for PSAP routing purposes within the specific 
geographic region in which the mobile 911 call was placed. To overcome 
this mobility problem, wireless carriers have developed various 
techniques to provision ANI and ALI to the PSAP that involve 
enhancements or ``add-ons'' to existing Wireline E911 networks.
    16. Interconnected VoIP E911. Under the Commission's rules, 
interconnected VoIP providers must provide E911 service to their 
customers. As with wireless service, the mobile nature of 
interconnected VoIP service presents challenges in making E911 
effective. Since an emergency call may be placed from outside the 
caller's home area code, completing the call may require the use of 
``pseudo-ANI'' (p-ANI). The most difficult challenge, however, is the 
inability of the VoIP device or service provider to determine the 
current geographic location of the caller. As a result, the Commission 
requires interconnected VoIP providers to obtain location information, 
called ``Registered Location,'' from their subscribers, which is either 
entered manually or based on the subscriber's billing record. Under 
this approach, if a VoIP subscriber does not update his or her 
location, the subscriber's 911 call may be routed to the wrong PSAP, 
which may delay the emergency response.
    17. Beyond the basic functionality above, the Commission imposes 
additional obligations on interconnected VoIP service providers. Under 
the Commission's rules, interconnected VoIP providers must forward all 
911 calls made over their interconnected VoIP service, as well as a 
call back number and the caller's Registered Location for each call, to 
the appropriate PSAP. These calls must be routed through the use of ANI 
and, if necessary, and similar to wireless carriers, p-ANI, via the 
dedicated wireline E911 network, and the caller's Registered Location 
must be available from or through the ALI Database. Additionally, 
interconnected VoIP providers must comply with several customer 
notification requirements that include apprising their subscribers of 
any limitations in providing E911 service.

B. Next Generation 911

    18. Next Generation 911 relies on IP-based architecture rather than 
the PSTN-based architecture of legacy 911 to provide an expanded array 
of emergency communications services that encompasses both the core 
functionalities of legacy E911 and additional functionalities that take 
advantage of the enhanced capabilities of IP-based devices and 
networks. NENA defines NG911 as ``a system comprised of hardware, 
software, data and operational policies and procedures * * *, to: 
Provide standardized interfaces from call and message services; process 
all types of emergency calls including non-voice (multi-media) 
messages; acquire and integrate additional data useful to call routing 
and handling; deliver the calls/messages and data to the appropriate 
PSAPs and other appropriate emergency entities; support data and 
communications needs for coordinated incident response and management 
provide a secure environment for emergency communications.''
    19. In an NG911 environment, IP-based technologies and applications 
are used to provide call identification, location determination, call 
routing, and call signaling for emergency calls. Call identification 
determines that a call (which may be a voice call or some other form of 
communication) is indeed an emergency call, mapping a user-visible 
identifier (such as the digits 911 or 112) to a network-standard 
uniform emergency call identifier, such as an emergency service Uniform 
Resource Name (URN). Location determination provides the civic or 
geospatial location of the caller to the initiating call router, which 
will then use the emergency call identifier and the location 
information, along with other information, to route the call to the 
nearest IP-enabled PSAP.
    20. The NG911 architecture also redefines the functions and 
capabilities of PSAPs, who receive and process emergency calls by means 
of Emergency Services IP Networks (ESInets). An ESInet is an IP-based 
network used by the PSAP and other agencies that may be involved in 
responding to an emergency. Emergency calls can be delivered to an 
ESInet from several types of originating networks, including both NG911 
networks and legacy 911 networks. The ESInet, in turn, completes the 
call to the appropriate PSAP. The call signaling uses the same standard 
protocols as non-emergency calls, but user devices may use other 
protocols via gateways.
    21. The nature of NG911 technology and architecture leads to 
certain key differences when compared to legacy 911, as detailed in the 
paragraphs below:
     NG911 networks can be accessed by a wide variety of end 
users and devices, many of which will have identifiers other than 
telephone numbers.
     NG911 networks are capable of supporting multiple voice 
and non-voice services, whereas legacy 911 supports voice only.
     In NG911, the difference between mobile, nomadic, and 
fixed services is blurred, because a single device may operate in 
mobile, nomadic, and fixed configurations at different times and 
locations.
     In NG911, network access and communications service may be 
provided by separate entities rather than the same entity.
     NG911 network services can be provided by servers largely 
independent of location.
    22. As pointed out by the Internet Engineering Task Force, 
Emergency Context Resolution with Internet Technologies (IETF-ECRIT) 
working group, the use of the Internet rather than circuit-switched 
networks changes the requirements and operating conditions of IP-based 
emergency calling. For example, in an NG911 call scenario, the caller's 
provider of Internet access services may not be the same entity that 
provides voice calling services, i.e., that routes calls and bridges 
them to the PSTN when needed. Moreover, the voice service provider may 
be located far away from the caller, possibly in another country, while 
the Internet access provider remains, by physical necessity, local to 
the caller. The voice service provider may also not be a traditional 
telecommunications provider, particularly as the need to interconnect 
with the PSTN diminishes.
    23. Unlike communications systems that interconnect with the PSTN, 
IP-based communication systems are media-neutral, i.e., they can 
transport any digital information, regardless of content, and are not 
limited to voice or voice-band data (TTY). As a result, a wide variety 
of voice and non-voice services can share the same Internet 
infrastructure. Moreover, while wireless or wireline E911 network users 
need no special capabilities to dial 911, current standards-based 
architectures for NG911 envision a more active role for end-user 
devices and systems in identifying emergency calls and acquiring the 
caller's location information. This makes it easier for NG911 networks 
to add media beyond voice, although it also creates additional 
challenges such as security.
    24. NG911 will also require a new and more multi-faceted approach 
to caller identification. In legacy E911 networks, all callers have 
telephone numbers as identifiers, most of which are domestic (+1) 
numbers. Initially, most users of IP-based systems (e.g., 
interconnected VoIP) will also have telephone numbers,

[[Page 2301]]

but an increasing percentage of these users are likely to have 
international rather than domestic numbers. Moreover, in the longer 
term, as IP-based networks support an increasing diversity of non-
interconnected and non-voice services, potential NG911 end users and 
devices are less likely to have any type of telephone number and more 
likely to have identifiers such as email addresses, Session Initiation 
Protocol (SIP) URLs or service-specific ``handles.''
    25. In contrast to the device-specific connection protocols in 
legacy 911 networks for wireline, wireless, and interconnected VoIP 
phones, NG911 will need to provide IP-enabled devices with multiple 
means of accessing the NG911 network, resulting in a blurring of the 
difference between stationary, nomadic and mobile devices. For example, 
an IP-enabled mobile device may be capable of accessing the Internet 
via a Wi-Fi hotspot, a cable modem, or a 4G wireless broadband network. 
NG911 networks will need mechanisms to recognize which form of access 
the device is using when an emergency call is made and to provide the 
appropriate caller identification, location determination, call 
routing, and call signaling in each case.
    26. NG911 also provides far more flexibility to provide network 
services that are not constrained by the location of the caller or the 
nearest PSAP to the caller. In circuit-switched networks, the location 
of many types of network services is constrained by the network 
topology. For example, a selective router has to be relatively close to 
the PSAPs it serves. For NG911, since call routing and media transport 
are completely disjoint, almost any network server can be located and 
replicated anywhere. As an example, a SIP proxy that routes call can be 
in a different part of the country, incurring only a few milliseconds 
of additional packet propagation delays.

IV. Discussion

    27. While, as detailed above, the 911 system has been adapted to 
accommodate wireless and interconnected VoIP services, the success of 
the 911 system, combined with the antiquated aspects of today's 911 
infrastructure and the development of advanced IP-based devices and 
applications in the telecommunications industry overall, creates a gulf 
between consumer assumptions about the system's robust capabilities and 
its actual limitations. Indeed, there is widespread concurrence among 
academics, industry experts, and politicians that ``the current 
communications landscape is a far cry from the one for which the 
current 9-1-1 system was engineered'' and, furthermore, that ``our 
emergency communications networks are unable to accommodate what is 
increasingly viewed as basic functionality inherent in many of today's 
technologies.'' In short, because 911 service was designed to succeed 
in the legacy wireline telephone environment, there are unmet consumer 
expectations concerning emergency service capability and reliability 
across new communications technologies (such as text messaging requests 
for help, sending IP-based information, including medical data, photos, 
videos, car collision telemetry, environmental sensors, gun shot 
sensors, etc. via smartphones, and delivering precise location 
information from behind MLTS systems).
    28. The deployment of and transition to NG911 presents multiple 
opportunities for the benefit of public safety and homeland security. 
First, replacing today's system with a broadband-enabled, IP-based 911 
network will offer far more flexibility, resilience, functionality, 
innovation potential, and competitive opportunities than is presently 
possible. NG911 holds the promise to bridge the gap between traditional 
means of voice-based communications and the advanced capabilities 
already in widespread use by consumers using smartphones, netbooks, and 
advanced wireless 4G. In particular these digital devices have powerful 
processor and storage capabilities and are capable of transmitting not 
only voice communications, but also text, data, telemetry, image, and 
video signals, which have benefits to particular communities such as 
persons with disabilities. Unlike the circuit-switched technology that 
lies at the heart of the legacy 911 system, today's wireless networks 
increasingly use all-digital packet switched technology based upon the 
Internet Protocol suite. Thus, while these networks are capable of 
conveying text, data, image, and video in addition to voice, the legacy 
911 systems are not capable of receiving or processing these 
communications, and will not be until NG911 is deployed across the 
country.
    29. The adoption of broadband IP-based technology also creates the 
potential for our 911 system to accommodate a full range of specialized 
devices and functionalities tailored to particular emergency response 
scenarios. For example, NG911 could permit the simultaneous 
transmission of critical health data along with a 911 call for help, 
both from the ``caller'' seeking assistance to a dispatcher, and back 
out from a dispatcher to a first responder arriving on scene or to an 
emergency room receiving the patient. Likewise, a vehicle's Automatic 
Collision Notification System could automatically call for help while 
conveying other relevant information such as the vehicle's location and 
the severity of the crash. NG911 will also enable 911 call routing 
based on caller characteristics, not just the location of the call. For 
example, a 911 call might be made via a video-enabled device by a deaf 
caller whose native language is American Sign Language. In this 
situation, rather than routing the call to the ``geographically 
appropriate'' PSAP, it may be preferable to enable the 911 system to 
route the 911 call to a PSAP that is video-enabled and has a 911 call 
taker prepared to respond to the caller using the caller's native sign 
language. NG911 will permit this to happen. NG911 will also create the 
ability to utilize a ``virtual PSAP.'' Today's 911 system generally 
requires a call taker to answer a 911 call from within the walls of a 
physical PSAP. In a NG911 network, however, a call taker will be able 
to answer a 911 call from virtually any location. This capability will 
be particularly advantageous during disasters and high call volume 
situations. NG911 will also complement the deployment of related next 
generation emergency communications networks, such as next generation 
alerting systems and advanced public safety broadband networks.
    30. In this proceeding, we seek to gain a general understanding of 
NG911 and the applications that it supports. We examine and seek 
comment about how the applications and architecture of NG911 will 
affect the interface with the general public, the internal workings of 
PSAPs, and the interface with Emergency Medical Services (EMS) and 
other first responder organizations, including dispatch and database 
access. We then look at issues associated with implementing NG911 and 
how the transition from legacy 911 will impact the current 
architecture, structure, and costs of today's PSAPs over time. Finally, 
we seek comment on the proper roles of the FCC, other Federal agencies, 
and State, Tribal, and local governments in developing NG911 elements 
and facilitating the transition to NG911 over time.

A. NG911 Capabilities and Applications

    31. In this section, we review the potential capabilities that the 
deployment of NG911 systems will provide to the public, and the likely 
architecture of NG911 networks. We seek comment on each of these 
elements as a component of NG911. Are there core elements that should 
be part of every NG911 system and standardized

[[Page 2302]]

across all NG911 deployments? Are there non-core elements that could be 
part of NG911 but are optional or can be varied locally? How will these 
elements (both core and non-core) be affected by future technological 
change?
1. Potential Media Types in an NG911 Environment
    32. Because NG911 architecture is IP-based, NG11 networks have the 
potential to support a variety of non-voice communications applications 
or ``media types.'' There is broad consensus in the public safety 
community that NG911 should include some combination of non-voice media 
types, and to this end, NENA, the IETF, and others have been actively 
engaged in developing and harmonizing technical standards to support 
such IP-based NG911 solutions. In addition, the U.S. Department of 
Transportation and other Federal agencies have engaged in the 
development of standards in this area. We identify and discuss the most 
likely media types below, and seek comment on the potential for each of 
the media types to be supported in the development and deployment of 
NG911 networks. We also seek comment on whether there are any 
additional media types that we should consider for inclusion in NG911.
    33. Message-Based Text. When using message-based text, two or more 
parties have the ability to send complete, typically short, text 
messages to each other. Examples include Short Message Service 
(``SMS''), instant messaging (``chat'') sessions, or web-based tools. 
To send a message-based text, a user must make an explicit action, such 
as hitting an SMS send key, or the return key on a keyboard. Chat 
sessions are bidirectional through their protocol definition. While 
services such as SMS consist of independent messages, they may be 
presented to the user as a thread of back-and-forth messages.
    34. Real-Time Text. ``Real-Time Text (RTT) is conversational text 
that is generally sent and received on a character-by-character basis. 
The characters are sent immediately (in a fraction of a second) once 
they are typed and are also displayed immediately to the receiving 
person(s). This functionality allows text to be used in the same 
conversational mode as voice.'' RTT is viewed by many in the disability 
community as a replacement for the dated TTY technology and preferable, 
from a human interface perspective, to message-based text, as it more 
closely approximates the speed and flow of human voice conversation. 
RTT also prevents messages from crossing each other during a call, and 
for this reason may be preferred over SMS as a means of facilitating 
the exchange of information between the caller and the PSAP dispatcher.
    35. Still Images (Photos). Still images are captured by a digital 
camera, typically encoded into a compressed file format, such as JPEG, 
and made available as a single data object (file). Still images may 
help 911 call takers and first responders assess the severity of an 
incident or apprehend a criminal suspect.
    36. Real-Time Video. Real-time (live) video may be captured by a 
webcam, a camera built into a mobile phone, a networked security 
camera, or another video-capable device. The live nature of real-time 
video distinguishes it from streaming video, which is typically used 
for watching entertainment content. Real-time video will help first 
responders better gauge the scope and nature of an incident and will 
also help determine a caller's precise location.
    37. Telemetry Data. Telemetry data includes all sensor measurements 
that quantify physical, chemical, or biological phenomena. Examples 
include vehicular information (such as current speed and crash-related 
data), biological and environmental sensors that measure wind and 
temperature, and physiometric sensors that measure human pulse rates.
    38. Auxiliary Medical and other Personal Data. Auxiliary data would 
include relevant information about the caller's medical conditions and 
particular treatment needs, as well as information related to those 
categories. Such information could be provided on a prior-consent basis 
to the PSAP for forwarding to EMS personnel or other first responders.
2. Primary vs. Secondary Usage of Media Types
    39. We also seek comment on the degree to which each of the media 
types discussed above will be used as a primary versus a secondary form 
of communication on NG911 networks. By ``primary'' media, we refer to 
media that provide the basic communications link between the 911 caller 
and the PSAP during the emergency call. By ``secondary'' media, we 
refer to media that may convey additional information between the 
caller (or the device used by the caller) and the PSAP to augment the 
primary communication. Primary media will likely include voice, RTT, 
and text-based messaging (SMS, instant messaging), because to differing 
degrees, all of these media types will permit live conversations 
between the 911 caller and the PSAP. Thus, primary media can also be 
considered ``conversational media.'' Primary media will likely be used 
to convey the nature and location of an emergency to a PSAP. In some 
cases, primary media may not be available to a 911 caller (e.g., due to 
network congestion or end system limitations). In these cases, we seek 
comment on whether e-mail or social network status pages could possibly 
be used as the primary means of contacting a PSAP. Secondary media will 
likely include transmission of photos, live video, and sensor data 
(e.g., data acquired from sensors commonly found in mobile devices, 
vehicles, and medical monitoring systems). We envision a PSAP most 
frequently using secondary media to acquire supplemental information 
from a 911 caller or the caller's device.
    40. The Commission seeks comment on what primary and secondary 
media types PSAPs and service providers will likely support. Should 
individual PSAPs be able to choose the media types that they will 
support, or should all PSAPs be expected or required to support a 
specific set of media types? Should different standards or requirements 
apply to primary conversational media as opposed to secondary non-
conversational media? If secondary non-conversational media include the 
capability to transmit sensitive personal data, what privacy protection 
concerns are raised and how should they be addressed? Would changes in 
current laws, regulations, tariffs, and overall policies be needed to 
enable NG911 to support these media types and system features?
3. SMS for Emergency Communications
    41. In light of the popularity and ubiquity of SMS, many consumers 
may assume that they are or will soon be able to text to 911. Indeed, 
consumer use of SMS has exploded in the past decade and billions of SMS 
messages are sent each day. Also, unlike some of the other media types 
discussed above, SMS is readily available on most mobile phones, and 
thus its implementation into the NG911 network may be one of the first 
steps in moving beyond a voice-only emergency calling framework. SMS, 
however, has limitations that will need to be addressed if it is to 
become a reliable means for emergency communications. For example, a 
recent study noted that SMS is an asynchronous messaging service that 
does not provide a means for the sender to know whether and when the 
message has reached its destination. In addition, the study noted that 
because each SMS is independent of its predecessors, it is difficult to 
ensure that messages within

[[Page 2303]]

the same logical conversation are routed to the same destination.
    42. Given these limitations, we seek comment on how the increasing 
use of SMS may impact emergency communications and whether NG911 
networks should be configured to support SMS emergency communications. 
For example, are there any proposed technical standards or approaches 
that would sufficiently address routing and location concerns? Further, 
will it be possible to use the existing short code system to reach 
PSAPs? Are there measurement results for mobile-to-fixed messaging that 
indicate the reliability and delay of SMS delivery under specified 
circumstances? Would it be possible to add location information to SMS 
messages to help in routing such messages and, if so, how? Would it be 
possible to maintain session continuity across messages, e.g., at the 
gateway between the cellular network and the IP network? Can end-system 
SMS applications address some of the location-related issues, e.g., 
waiting to send an emergency SMS until location information has been 
acquired? Have there been trials or operational experiences using SMS 
within the NG911 architecture? Should SMS be considered primarily as a 
fall-back mechanism when voice communications are difficult or 
impossible to transmit? As wireless systems evolve to IP based 4G 
architectures, can the reliability and features of SMS messaging be 
improved for the purposes of emergency communications and if so, how?
    43. We also seek comment on existing and future public expectations 
related to the use of SMS for emergency communications. Do consumers 
understand that currently available SMS generally does not support 
sending text messages to 911? Could the implementation of NG911 lead to 
changes in consumer expectations and public misunderstandings about SMS 
capabilities? Is there a need for programs to educate the public about 
the limitations of SMS for emergency communications, and if so, what 
entity should be responsible for developing such programs? Are there 
liability issues that could arise if consumers unsuccessfully attempt 
to use SMS for emergency communications?
4. NG911 Applications for Persons with Disabilities and Special Needs
    44. According to the ICO Plan, ``[t]he biggest gap between the 
technologies used for daily communication and those that can access 9-
1-1 services is that for the deaf and people with hearing or speech 
impairments.'' As noted in paragraph 11, supra, the Twenty-First 
Century Act directs the Commission to form the EAAC with the purpose of 
determining the most effective and efficient technologies and methods 
by which to enable access to NG911 emergency services by individuals 
with disabilities. Moreover, the Twenty-First Century Act provides that 
``[t]he Commission shall have the authority to promulgate regulations 
to implement the recommendations proposed by the [EAAC], as well as any 
other regulations, technical standards, protocols, and procedures as 
are necessary to achieve reliable, interoperable communication that 
ensures access by individuals with disabilities to an Internet 
protocol-enabled emergency network, where achievable and technically 
feasible.'' In addition, the National Broadband Plan recommended that 
NHTSA include ``an analysis of the needs of persons with disabilities 
and should identify standards and protocols for NG911 and for 
incorporating VoIP and `Real Time Text' standards.'' ICO has noted that 
when it analyzed trial deployments of IP-enabled emergency networks, 
texting access through various IP-devices, RTT, and third-party 
conferencing was successfully demonstrated. Additionally, streaming 
video and SMS were successfully demonstrated, but with key 
shortcomings.
    45. The Commission seeks comment on what media types and devices 
(e.g., text, video) persons with disabilities will likely use to make 
an emergency call in an NG911 environment. We understand that some 
people with hearing and speech disabilities make emergency calls 
directly; others use telecommunications relay services (TRS), a more 
indirect method to make these calls. How can the Commission ensure that 
persons with disabilities receive the appropriate benefits from the 
NG911 system? What, if any, technical or accessibility requirements 
should be imposed to ensure that persons with disabilities have the 
necessary access to the NG911 system? To what extent can real-time 
text, which permits the live exchange of information with a PSAP during 
a call, assist individuals with hearing or speech disabilities who wish 
to call 911 directly? Finally, the Commission requires IP-based text 
and video relay providers to ensure the prompt and automatic call 
handling of emergency calls. What considerations are necessary to 
ensure effective access to NG911 services for callers who continue to 
rely on IP-based relay services for their 911 calls? Are there 
different considerations for individuals who continue to use PSTN-based 
relay services?
    46. The Commission recognizes the significant public safety 
interest in ensuring that non-English speakers have access to emergency 
services. We seek comment on what media types non-English speakers 
likely will use to make an emergency call in an NG911 environment. What 
types of devices may non-English speakers use to make an emergency call 
in an NG911 environment? How can the Commission ensure that non-English 
speakers receive the appropriate benefits from the NG911 system?
    47. The ability to share information--including medical 
information--could be of particular value to EMS and other first 
responders. Should such information be provided in the ordinary course 
to EMS and other first responders in a manner similar to the provision 
of medical condition information described in paragraph 37, supra? 
Since privacy protection concerns would seemingly be implicated in this 
case, as in the case of transmitted medical information, how should 
such concerns be addressed?
    48. Independently of the Commission's efforts in connection with 
the EAAC, we seek comment on whether the Commission should conduct a 
separate rulemaking to ensure that individuals with disabilities have 
access to an Internet protocol-enabled emergency network, where 
achievable and technically feasible.

B. NG911 Network Architecture

1. Transport Mechanisms in an NG911 Environment
    49. In this section, we seek comment on the mechanisms that will be 
used to transport digital content across NG911 networks. In an IP-based 
NG911 architecture, unlike a circuit-switched architecture, a variety 
of protocols can be used to transport media types across the network 
from the 911 caller to the PSAP. For example, still images can be 
carried: (1) As Multimedia Messaging Services (MMS) sent by mobile 
devices, (2) as attachments to Internet e-mail, (3) within instant 
images and uploaded to social network services, or (4) on other web 
services. We note that a diverse mix of physical infrastructures, 
networking protocols, applications, and devices may facilitate the 
carriage of potential NG911 media types from a 911 caller to a NG911-
enabled PSAP. For example, some carriage scenarios may rely solely on 
``pure'' IP-based solutions, some may rely heavily on existing legacy 
infrastructure, and some may rely on gateway packet-based 
communications

[[Page 2304]]

between callers and PSAPs. We seek comment on each of these technical 
approaches and request that commenters discuss operational, business, 
and other policy strengths and weaknesses of each approach. For 
example, while application of IP-based approaches has generally led to 
robust and unexpected innovations in communications technologies, PSAPs 
could face operational and funding burdens from supporting a large 
number of IP-based NG911 architectures, and resources could be diverted 
from technical solutions that incorporate standardized features and 
implementation approaches. Similarly, introduction of operational 
requirements such as reliability, scalability, and standardized 
technology could result in tradeoffs between various legacy, 
proprietary, end-to-end open-standard, or other approaches for IP-based 
NG911 systems. We request that commenters identify these tradeoffs, or 
other relevant tradeoffs, and discuss the relative strengths and 
weaknesses of these technical approaches.
2. NG911 Participants
    50. In the traditional 911 system, only a small number of entities 
participated in the provisioning of emergency calling services because 
an E911 call would originate from an end user device that was in 
practice tightly-coupled, both technically and administratively, with 
the service provider's transport network. Examples include a 
conventional wireline phone, a mobile phone, and an interconnected VoIP 
phone.
    51. In a NG911 environment, however, end user devices are far more 
likely to be liberated from a particular transport network. This 
treatment acknowledges important industry trends, such as the 
increasing portability of devices among service providers, open access 
possibilities, and the increasing use of user-selected IP-based devices 
that may exploit widely-available sources of Internet access. As such, 
the number of participants in an NG911 environment will increase 
dramatically. The table below lists the potential NG911 participants 
and their possible roles in an NG911 environment.

----------------------------------------------------------------------------------------------------------------
                                    Media transport      Call/Message          Location          Call/Message
     Participant/Affected by         and encodings      identification       provisioning           routing
----------------------------------------------------------------------------------------------------------------
PSAPs...........................                  X                   X                   X                   X
VSP and application service       ..................                  X   ..................                  X
 providers......................
Residential ISP.................  ..................  ..................                  X   ..................
Non-traditional ISP (hotels,      ..................  ..................                  X   ..................
 coffee shops, community
 networks, etc.)................
Enterprise IP-PBX...............                  X                   X                   X                   X
UE vendors......................                  X                   X                   X                   X
Communication software                            X                   X                   X                   X
 developers.....................
Home gateway manufacturers......  ..................  ..................                  X   ..................
----------------------------------------------------------------------------------------------------------------

    52. Currently, only devices that provide telephone services are 
capable of transmitting 911 calls. In the future, however, most 
electronic devices will have communication capabilities, ranging from 
televisions, in-car systems, portable music players, tablet computers, 
and game consoles. We seek comment on what devices can usefully provide 
emergency calling services. Should every consumer device with Internet 
or cellular connectivity and a suitable user interface have the ability 
to request emergency assistance? Should such devices be certified and 
labeled as 911-capable? How will a user of a device or software be able 
to tell whether a device or communication software is capable of 
placing 911 calls? If this capability is conditional, e.g., on 
properly-configured network connectivity, can the user or device test 
911 reachability?
    53. In the E911 Scope Order, the Commission established the 
following four criteria for determining which licensees should be 
subject to the wireless enhanced 911 obligations: Those licensees that 
(1) offer real-time, two-way switched voice service, interconnected 
with the PSTN, either on a stand-alone basis or packaged with other 
telecommunications services; (2) whose customers clearly expected 
access to 911 and E911; (3) that competed with analog and broadband PCS 
providers; and (4) where it is technically and operationally feasible 
to provide enhanced 911 service. Should the Commission consider 
expanding or modifying the four criteria from the E911 911 Scope Order 
to apply to additional NG911 participants? For example, should hot-spot 
providers that are not traditional communications providers, such as 
coffee shops, hotels, bus lines, and public parks be expected to play a 
role in the deployment of NG911?
3. Interoperability and Standards
    54. Many potential NG911 media types permit a range of encoding and 
performance parameters. For example, photos are typically compressed 
using the JPEG standard, but may also use other formats. Photos may 
also include meta data (EXIF), ranging from camera settings to embedded 
geographic location. Further, camera images can range from low-
resolution web cam photos with less than one megapixel to professional-
quality images with more than 15 megapixels and several megabytes in 
size. For text, accented and foreign language characters can be 
represented in a range of character encodings with Unicode in its UTF-8 
encoding among the most popular. While a wide variety of digital 
formats are potentially available for encoding such information, NG911 
will require use of compatible formats across the network, so that 
PSAPs can receive and process the text, photos, and other digital 
information that are sent by the public. We seek comment on how best to 
ensure such compatibility in the formatting and coding of text, photos, 
and other digital information. Should there be standards for media 
encodings? Should we specify minimal performance ranges, e.g., minimum 
file sizes for digital images, that NG911 networks must support and 
PSAPs be able to accept?
    55. If there is a need to develop standards for digital information 
transported on NG911 networks, what entity should set and update these 
standards, or assist in their coordination? Should the standards be 
national or international? Are there standards efforts currently under 
way that could form the basis for future evolution in this regard? 
Should specific technical standards or architectures be mandated? How 
can the interoperability of end user devices and PSAP devices be 
ensured (e.g., through interoperability testing)? Should there be a 
certification process that indicates

[[Page 2305]]

whether a device or downloadable software application is compliant with 
certain standards? If so, what form of certification seems to be the 
most suitable, e.g., self-certification or approved certification 
organizations? Should all devices of a certain class be required to 
meet the certification criteria? As more people--especially within the 
disability community--begin to make video-based telephone calls, are 
there steps needed to ensure that NG911 networks interoperate 
seamlessly with the video software and applications being utilized in 
smart phones, tablets, computers and other devices? Similarly, are 
there steps needed to ensure interoperability with the video 
communication services provided by all video relay service providers?
4. PSAP Functions in an NG911 Environment
    56. As noted earlier, IP-based technology removes many of the 
location constraints of traditional circuit-switched technology. In 
particular, a PSAP no longer has to be in a single building at a fixed 
location. Call takers that are organizationally part of a single PSAP 
can be located virtually anywhere an Internet connection can be found, 
and a single call taker could be supporting multiple PSAPs. Such 
``virtual PSAP'' arrangements may allow more flexible and efficient 
staffing and may allow PSAPs to better recover from major disasters by 
temporarily relocating operations. We seek comment on the potential for 
development of virtual PSAPs as part of the transition from legacy 911 
to NG911. Are current technologies sufficient to support virtual PSAPs? 
Are there regulatory or legal barriers changes that are necessary to 
facilitate the development and operation of virtual PSAPs? Are there 
current PSAP databases that would need to be standardized to support a 
remote ``virtual PSAP''? How could local data that is contained in 
current Computer Aided Dispatch Data Bases, MSAGs, and other 
repositories that are necessary for an efficient response by emergency 
personnel be distributed on a timely and reliable basis for use by non-
local PSAPs?
    57. While emergency service networks and PSAPs will continue to be 
operated and managed regionally, the deployment of NG911 may require a 
set of national infrastructure components. Based on the current NENA 
NG911 architecture, these may include: (1) A national PSAP and ESInet 
lookup directory, called the LoST ``forest guide''; (2) a public-key 
cryptography certificate to ensure that other NG911 entities can 
authenticate PSAPs and to ensure that PSAPs are capable of receiving 
access to sensitive information; and (3) interconnection to an IP-based 
national network to ensure that emergency calls can be routed amongst 
PSAPs without PSAPs losing information. The Commission seeks comment on 
whether it is necessary to establish a national set of infrastructure 
components to ensure the deployment of NG911. If it is necessary, what 
entity should operate this national set of infrastructure components?

C. Other Specialized NG911 Applications

    58. Device-Initiated Services for Emergency Communications. In an 
IP-based network architecture, emergency calls can be placed not only 
by human beings, but by a variety of automatically triggered devices. 
Examples of such devices include environmental sensors capable of 
detecting chemicals, highway cameras, security cameras, alarms, 
personal medical devices, telematics, and consumer electronics in 
automobiles. We seek comment on how the deployment of NG911 will 
facilitate the ability of device-initiated emergency services to reach 
PSAPs. What steps are needed to facilitate such deployment? Is there a 
need to modify existing laws, regulations, or tariffs to ensure that 
device-initiated emergency services have access to the NG911 network?
    59. Social Media for Emergency Communications. How have consumers 
used social media to report an emergency or contact public safety 
during an emergency? How will consumers expect to use social media for 
emergency purposes in the future? To what extent might State and local 
public safety jurisdictions employ social media tools as a way to 
interact with the public? How will these tools impact the deployment of 
NG911?
    60. N11 Numbers and Other Services for Emergency Communications. 
The basic functionality of NG911 is similar to many other location-
based information and assistance services, such as 211 (community 
information and referral), 311 (non-emergency city services), 511 
(traffic information), poison control, call-before-you-dig, and other 
similar services. Since these services share much of the same technical 
functionality, it may be possible to reduce cost and improve service by 
integrating some of these services to use a common technology platform. 
Further, callers may need to be transferred from one service to 
another, e.g., from 911 to 311 or 211. Can such coordination and 
integration be helpful and cut costs? How will the deployment of NG911 
address N11 numbers, including N11 services such as 311, which is 
designated for non-emergencies? How will the deployment of NG911 impact 
other emergency services, such as poison control centers using 800 
services? How will the deployment of NG911 affect TRS that use 711?
    61. Auxiliary Data. NG911 offers the opportunity to provide 
additional data to PSAPs and first responders, such as the caller's 
medical history, a description of the caller's residence or business 
location, and related data, including building floor plans, information 
about hazardous materials, and building occupants with special needs. 
This data will often be maintained and provided by third parties, such 
as health care organizations that maintain electronic medical records 
or commercial landlords that maintain floor plans. How should the PSAP 
be informed about the availability of this data? What entity should 
associate this information with the call or message, such as the 
application service provider or a third party? Is there a need for 
regulations that require an application service provider to supply 
these services, e.g., by providing the appropriate call signaling or 
lookup functionality? Is there a need for standards to ensure that 
PSAPs and first responders receive access to this data without every 
PSAP having to make individual arrangements with each data source? 
Since this auxiliary data may be considered part of the 911 call record 
and therefore subject to public disclosure, is there a need to protect 
the privacy of this data differently than the remainder of the call 
information?
    62. Disaster Planning and Recovery. How will NG911 facilitate 
disaster planning and recovery? How will NG911 interact with existing 
and future public alerting systems? Can national security be enhanced 
by the consistent implementation of interoperable NG911 systems across 
the nation? What key NG911 elements should be the focus for consistent 
implementation and interoperability?
    63. MLTS for Emergency Communications in an NG911 Environment. 
Currently, MLTS operators are not subject to the FCC's E911 
regulations. In 2003, the Commission found that economic and 
competitive factors existed that rendered it impracticable to adopt 
E911 requirements for MLTS. The Commission, however, sought comment on 
its ``jurisdiction over MLTS operators, in light of the Commission's 
earlier interpretations of its section 4(i) authority and its prior 
statement that

[[Page 2306]]

`the reliability of 911 service is integrally related to our 
responsibilities under section 1 of the Act.' '' In light of NG911's 
potential impact on MLTS, we seek comment on whether the Commission has 
the jurisdiction to regulate MLTS operators. How will the deployment of 
NG911 improve emergency services for MLTS users? Will MLTS operators be 
able to provide improved location information in an NG911 environment?

D. Issues Related to NG911 Implementation/Transition

    64. We seek comment on the potential operational, technical, and 
other challenges associated with the transition to NG911. As both the 
ICO Plan and the National Broadband Plan highlight, the transition to 
NG911 will be an evolutionary process, involving technological, 
economic, and institutional challenges. The ICO Plan also noted that 
``a timetable for national deployment of NG9-1-1 is difficult to 
estimate due to the lack of:
     Consistent funding for planning, training, deployment and 
implementation;
     Complete set of standards and time required to develop 
them; and
     Coordinated planning and implementation efforts by 
stakeholders at all levels (e.g., government, industry, OSPs, standards 
organizations).''
    65. In light of these challenges, what actions should the 
Commission take to encourage the deployment of NG911? Have there been 
any recent developments that provide additional details on a potential 
timeline for NG911 deployment? Have there been any coordinated 
management efforts by State, Tribal, or local governments? Should there 
be a national set of milestones that provide a planning horizon? If so, 
what entity or entities should set those milestones, measure progress, 
and disseminate the measurement results? What are the milestones that 
will be useful to accelerate and measure NG911 deployment? What changes 
will need to take place in the emergency communications governance 
structures, at both the Federal and non-Federal levels, to facilitate 
NG911 planning and implementation? What policies can be established to 
enable and instigate the development and deployment of shared State-
wide ESInet, and related cooperative working agreements between 
Federal, State, Tribal, and local agencies, as a fundamental 911 and 
emergency communications policy objective? Will waivers of certain 
rules and regulations be necessary during the transition to NG911? 
Should the FCC provide certain criteria for consideration of waiver 
grants?
1. Disparate PSAP Capabilities in an NG911 Environment
    66. Because the transition to NG911 is likely to be gradual rather 
than a large scale