For decades, emergency calls in the US and Canada have gone through an analog 911 infrastructure that primarily only supported voice and teletype calls. This was a functional system, but lacked many of the features available in IP-based systems such as multi-media (voice, chat, video), precise geo location, and advanced routing capabilities that have become possible in recent years. In response, US and Canadian regulators have announced new mandates for the organizations that receive and transfer these emergency calls to their local respondents to update their 911 infrastructures to an IP-based next generation 911 (NG911) infrastructure.
According to 911.gov, this work needed to achieve NG911 compliance under these new orders is far from a simple shift in technology: “the transition to NG911 involves much more than just new computer hardware and software.” In fact, orders from the Federal Communications Commission (FCC) in the US and the Canadian Radio-television and Telecommunications Commission (CRTC) establish specific standards for implementation and performance that must be met and maintained to avoid millions of dollars in fines.
To help you avoid these penalties and ensure NG911 compliance, we’ve put together a quick overview of NG911 standards, NG911 testing requirements, and how Hammer can help you achieve (and maintain) NG911 compliance.
Why is an NG911 transition being mandated?
The NG911 mandate has been a long time coming. Planning for an updated, IP-based infrastructure began in 2000. In 2019, bills were introduced in the US Congress to provide funding to support NG911 implementation nationwide. This mandate for NG911 upgrades was delayed due to the COVID pandemic, however, and is only now returning as a priority for regulators in North America.
Through all of these iterations of the NG911 mandate, the reasoning has remained the same: an increasingly wireless mobile society needs an improved public emergency communications service. According to the FCC’s NG911 Report and Order, “In its end state, NG911 will facilitate interoperability and system resilience, improve connections between 911 call centers, and support the transmission of text, photos, videos, and data to PSAPs [Public Safety Answering Points] by individuals seeking emergency assistance.”
What testing requirements need to be met for NG911 compliance?
The FCC is mandating a nationwide deployment of NG911 in two key phases, both of which feature significant testing requirements:
Phase 1
The FCC requires Originating Service Providers (OSPs) to conduct connectivity testing to confirm that the 911 Authority receives 911 traffic in the IP-based SIP format. This testing ensures that the connection from the OSP to the 911 Authority is implemented correctly – proving NG911 compliance with mandated delivery of 911 traffic to ESInets. Because the ability of OSPs to complete testing within the required time period depends on cooperation between OSPs, NG911 vendors, and 911 authorities, NG911 vendors need to be on-boarded to demonstrate connectivity by the compliance deadline.
Phase 2
In Phase 2, OSPs are required to complete connectivity testing to confirm that the 911 Authority receives traffic in accordance with the IP-based SIP format and commonly accepted standards requested by the 911 Authority. The FCC also adopts a condition prerequisite that 911 Authorities secure commitments from NG911 vendors during Phase 2 to ensure that vendors are available to complete connectivity testing by the compliance deadline applicable to the OSP.
As an industry leader in the CX testing and monitoring space, Hammer has the technical capabilities to help NG911 vendors meet these NG911 compliance commitments and ensure their connectivity testing is in place ahead of the deadlines they’re confronting.
Importantly, each US state and Canadian province is tasked with establishing their own reasonable timeline for deploying NG911 and establishing the SLAs in contracts with the providers that service emergency communication relays. That said, the National Emergency Number Association (NENA) developed an “i3” best practice set of requirements to help standardize capabilities that fit within NG911 compliance and 911.gov has released guidelines for developing a state NG911 plan.
On a federal level, the FCC holds Originating Service Providers (OSPs) responsible for delivering emergency 911 calls to PSAPs and requires all OSPs to notify downstream PSAPs within 30 minutes of any outage. Similarly, in Canada, the CRTC has levied fines against companies including Bell Canada, Rogers, and Telus for failing to provide reliable emergency 911 services and failing to notify PSAPs within a 1-hour period.
What are the penalties for NG911 noncompliance?
No universal penalty for NG911 noncompliance has been established at the time of publication. That said, past fines for 911 outages and delays have reached as high as $19.5 million in recent years. Beyond significant noncompliance penalties due at the time of discovery, there’s a strong possibility that regulators like the FCC and CRTC will impose additional daily penalties for each day that they remain in non-compliance.
How can I make sure I’m NG911 compliant?
Hammer testing solutions enable organizations to emulate users generating and answering IP-based SIP emergency calls through OSP networks, NG core emergency services IP networks (ESInet), and PSAP locations, both at scale prior to go-live and operationally to assure on-going availability and compliance. With Hammer On-Call and VoiceWatch, OSPs, ESInet providers, and PSAP operators can test that their new NG911 deployments are performing properly, transferring all required caller information, and maintaining NG911 compliance consistently, regardless of call volume or origin.
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