There's a pattern emerging among smaller ILECs and rural carriers grappling with FCC 24-78 and the transition to NG911. Many look at Phase 1 (delivering 9-1-1 traffic via SIP to their local 9-1-1 Authority) and see it as something manageable that can be handled in-house. Can it be done? The answer in many cases is yes. But perhaps a better question is, “Will we be set up for success during Phase 2?”
Phase 1 is a relatively contained technical problem that looks like familiar territory for a carrier that has been managing its own infrastructure for decades: convert TDM to SIP, establish the right connections, and load your records. But Phase 2 requires full NENA i3-compliant delivery and represents a complete reimagining of how 9-1-1 traffic is routed and managed. A DIY approach comes with hidden costs and challenges that become abundantly clear during Phase 2.
A Two-Step Problem You Might Not See Coming
Many wireline carriers are already mid-transition, converting legacy TDM copper infrastructure to VoIP. With FCC 24-78 entering the picture, the VoIP transition suddenly has a deadline attached.
Phase 1 compliance involves two distinct moves:
1. Convert TDM to SIP and establish ingress circuits to route 9-1-1 traffic to the local ESInet
2. Migrate ALI database records to a next generation ALI, since legacy records don’t carry over automatically
Both steps are technically achievable. But when Phase 2 arrives, you have to do it all again.
That means migrating ALI records a second time, re-establishing connections, and rebuilding infrastructure to meet the i3 standard. Compliance with FCC 24-78 is a two-step journey, and carriers have to plan ahead to ensure that Phase 1 lays the foundation for what comes next.
Phase 2 Is Not Phase 1 Plus a Few Extra Steps
Phase 1 is a connectivity and format requirement: deliver 9-1-1 traffic via SIP as your 9-1-1 Authority specifies. Phase 2 is more challenging because it requires full NENA i3-compliant delivery, which includes Emergency Call Routing Functions (ECRF), Location Information Servers (LIS), Location Validation Function (LIS), geospatial data formatting, and more. The entire system behind the call changes, not just the transport layer.
Non-nationwide carriers do have twelve months for each phase, but as we noted in a previous blog that time moves fast. If Phase 1 is treated as a quick fix, that groundwork likely won’t transfer when Phase 2 arrives.
What Looks Like Savings Often Isn't
Larger carriers with dedicated network engineering teams, established vendor relationships, and the capacity to absorb a multi-month infrastructure project may be able to execute a Phase 1 DIY approach effectively.
But for most small ILECs and rural carriers, the math is less favorable on closer inspection.
Circuit costs: One appeal of DIY is avoiding what looks like the overhead of a managed solution. But standing up your own Phase 1 connection still requires ingress circuits to your local ESInet – circuits you'll need to provision, manage, and re-provision during Phase 2. However, if you bring in an i3-ready solution during Phase 1, you can avoid the purchasing, provisioning, and management of circuits.
The Phase 2 reset: Carriers who self-manage Phase 1 need to consider new integrations and migrations required to comply with Phase 2. The upfront savings of DIY get eroded by the time and expense of doing everything twice.
Staffing reality: Some of the people who know how to manage ALI databases and navigate 9-1-1 infrastructure are approaching retirement. The institutional knowledge that makes DIY feasible today may not be there when Phase 2 arrives.
Time pressure: Monitoring the FCC docket, coordinating with PSAPs, and managing interoperability testing are tasks that displace other work.
With NG Nexus, you can avoid circuit costs and loading records twice - send us your records and we take care of the rest. And you're backed by an expert team that handles certificate management, project management, interoperability testing, and more.
Don't Wait for the Request to Show Up
Some LECs are already on the clock. Service requests under FCC 24-78 are filed through the FCC's Electronic Comment Filing System and don't always arrive as a formal notice. If you're not monitoring the ECFS docket, a compliance timeline could have started without your knowledge.
As of the date this article published, Alabama, Arizona, Michigan, New Mexico, North Carolina, North Dakota, Tennessee, and Washington have filed statewide Phase 1 RFSs, bringing the nationwide total to 2,151 PSAPs requesting Phase 1 services. Meanwhile, Massachusetts went straight to a Phase 2 service request.
Our teams have proactively established Phase 1 connectivity to 3,504 PSAPs (at the time of publishing), well beyond the number of submitted RFSs. And because we track service requests across the country, we can tell you exactly where your service area stands.
Don’t hesitate! Reach out with the form on this page to start the conversation and explore how we can support your Phase 1 and Phase 2 FCC 24-78 compliance journey.
Related reading:
NG9-1-1 for Small and Rural Carriers: Why 12 Months Go Faster Than You Think
FAQs: NG9-1-1 Compliance and FCC 24-78
The Power of Public Safety Partnerships
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