Service Providers Should Be Aware of Next Generation 911 Filings & Deadlines

In 2024, the Federal Communications Commission established new rules governing the provision of Next Generation 911 (NG911) services, including a requirement that originating service providers (OSPs) – defined to include wireline providers, commercial mobile radio service (CMRS) providers, covered text providers, and interconnected Voice over Internet Protocol providers – transition to NG911. As part of this requirement, OSPs must comply within specified time periods with requests for Phase I or Phase II NG911 service submitted by a 911 Authority.

911 Authorities have been filing such requests in FCC Docket No. 25-143, and additional filings continue to be submitted. These requests may identify affected geographic areas, such as counties, but are not required to specify the particular OSPs subject to the request. A summary of requests submitted as of June 15 is attached here.

Rural local exchange carriers and non-nationwide CMRS providers that receive a valid NG911 Phase I request must comply within 12 months of receipt (i.e., the date the request is posted in the FCC’s docketing system). Phase I requires OSPs to deliver 911 traffic in a basic Session Initiation Protocol (SIP) format. OSPs may challenge a request within 60 days of receipt. Providers that anticipate difficulty meeting the applicable deadline should consider whether a waiver request is warranted.

As an OSP, you remain responsible for ensuring awareness of all applicable NG911 requests from relevant 911 Authorities and for timely compliance with associated requirements.

Womble Bond Dickinson is closely tracking NG911 filings and deadlines in this docket. We will continue to provide periodic updates as additional requests are submitted. If you need assistance evaluating a request, assessing compliance obligations, or seeking relief from the FCC, please contact Stephen Sharbaugh at [email protected].