On August 4, 2025, APCO submitted comments in response to the FCC’s Further Notice of Proposed Rulemaking on improving interoperability and reliability for NG9-1-1 systems. APCO emphasized the need for a comprehensive, technology-neutral, and forward-looking approach that promotes innovation and flexibility in NG9-1-1 deployments and avoids forcing one-to-one comparisons between legacy and NG9-1-1 infrastructure. APCO reiterated the importance of addressing interoperability and recommended the use of both conformance testing, that remains technology-neutral and focused on commonly accepted standards, and interoperability testing, that reflects real-world situations and applies to all forms of 9-1-1 traffic, to ensure interoperability for NG9-1-1. APCO also expressed general support for extending reliability requirements to NG9-1-1 networks.
