WTA Seeks Clarity and Provides Context on NG911 NPRM

On August 9, WTA filed comments in response to the FCC’s Notice of Proposed Rulemaking on Facilitating the Implementation of Next Generation 911 Services. In its comments, WTA sought clarity on whether the FCC and/or state and local authorities will: (a) require NG911 calls to be transported to ESInets and PSAPs over dedicated SIP lines; or (b) permit NG911 calls to be transported over dedicated SIP lines or standard Internet facilities and routes.

WTA also provided insight on how some states or ESInet operators in the process of consolidating or planning to consolidate multiple selective router locations into a single statewide ESInet location or a small number of regional ESInet locations and thoughts on how the FCC can coordinate with state entities and assist providers in minimizing cost burdens.

Finally, WTA expressed opposition to the NPRM proposals for a default demarcation point for NG911 cost allocation purposes and the placement of the responsibility for NG911 call delivery costs upon service providers unless states and localities agree to different arrangements. WTA proposes that the FCC create and implement a support mechanism like the TRS, NANPA and LNP funds to help carriers recover substantial additional NG911 transport and associated costs.