Historically, the public safety industry loves to talk about innovation… right up until someone asks who’s actually responsible for delivering it?
That’s where things suddenly get very quiet.
But every once in a while, a state steps up and says:
“Enough delays. Enough workarounds. Enough pretending legacy architecture is good enough for the future.”
And right now, Massachusetts appears to be doing exactly that.
There’s a difference between talking about NG911… and actually building for it.
One is PowerPoint.
The other is policy, enforcement, architecture, interoperability, accountability, and frankly, sometimes a little willingness to make people uncomfortable.
The Commonwealth of Massachusetts recently filed comments with the FCC responding to Verizon’s request for additional waiver relief related to NG911 implementation timelines. On the surface, this may look like just another regulatory filing buried somewhere in Washington paperwork.
It isn’t.
What Massachusetts is really saying is something much larger:
“The future architecture already exists. Stop delaying the transition.”
And honestly?
That’s a pretty important message for the entire industry.
This Is Bigger Than Verizon
Let’s get something clear right away.
This isn’t really about any one carrier.
This is about whether the public safety industry is finally willing to move beyond decades of legacy E9-1-1 operational thinking.
Massachusetts appears to be taking the position that:
- direct NG911 connectivity matters,
- dynamic location matters,
- interoperability matters,
- and continuing to lean on legacy PS/ALI aggregation models is slowing the transition to the very architecture the industry claims it wants.
That’s not a small statement.
Especially coming from a state that actually operates an NG911 environment.
Massachusetts Is Pushing Direct-to-NG911 Thinking
One of the strongest themes in the filing is the Commonwealth’s insistence that originating service providers should connect directly to the NG911 infrastructure, rather than relying on layers of third-party workaround architecture.
Operationally, that matters.
A lot.
Because NG911 was never supposed to be:
- “E9-1-1 with more cloud.”
- “ALI records over SIP.”
- or “legacy selective routing with prettier diagrams.”
NG911 was designed to be:
- standards-based,
- IP-native,
- interoperable,
- policy-driven,
- and capable of supporting dynamic, modern emergency communications.
Massachusetts appears to be trying to push the industry toward exactly that.
And frankly, somebody needed to.
The MLTS Industry Should Pay Attention
If you work in the MLTS world, this filing should absolutely have your attention.
Why?
Because Massachusetts is effectively reinforcing something many of us have been saying for years:
Static ALI is no longer enough.
Not for:
- mobile enterprise users,
- hybrid workers,
- soft clients,
- cloud UC,
- large campuses,
- hospitals,
- schools,
- or modern enterprise environments.
The filing repeatedly references dispatchable location expectations tied to:
- Kari’s Law,
- RAY BAUM’S Act,
- and NG911 i3 principles.
That’s important because it signals a state-level recognition that:
modern emergency communications requires dynamic, validated location delivery.
Not just a billing address and a prayer.
This Is What Progressive NG911 Leadership Looks Like
Now let me say something that probably needs to be said more often:
Massachusetts deserves credit here.
Because this filing shows something rare in public safety:
- technical understanding,
- operational clarity,
- and a willingness to challenge legacy assumptions.
They’re not arguing against public safety.
They’re arguing against delay.
That’s a very different thing.
The Commonwealth appears to recognize that continuing to bolt modern NG911 requirements onto decades-old architectures creates:
- unnecessary complexity,
- interoperability problems,
- operational confusion,
- and ongoing cost burdens.
And honestly… they’re right.
At some point, the industry has to stop building temporary bridges to systems we already know are being replaced.
The Bigger Issue: Accountability
One of the strongest underlying themes in the filing is accountability.
Massachusetts appears frustrated that:
- deadlines continue slipping,
- workaround architectures continue expanding,
- and the operational burden continues falling on the public safety side of the equation.
Again… that’s not an unreasonable concern.
Public safety agencies are often the ones forced to:
- maintain hybrid environments,
- absorb additional complexity,
- pay for interim solutions,
- and explain why “Next Generation 911” still sometimes behaves like 1998 technology wearing a SIP badge.
Meanwhile, the expectations placed on ECCs continue growing:
- multimedia,
- dynamic routing,
- mobility,
- IoT,
- enterprise integration,
- and increasingly complex operational workflows.
At some point, the originating side of the ecosystem has to modernize too.
This Matters Beyond Massachusetts
That’s the other important part here.
This filing may influence:
- FCC enforcement direction,
- OSP implementation expectations,
- MLTS deployment models,
- and broader NG911 migration strategy nationwide.
Because if states begin aggressively insisting on:
- direct ESInet delivery,
- dynamic location standards,
- and reduced dependency on legacy ALI aggregation,
the industry architecture conversation changes significantly.
And personally?
I think that’s overdue.
The Bottom Line
Massachusetts appears to be doing something the NG911 industry desperately needs more of:
Pushing the conversation forward instead of managing around the past.
Not recklessly.
Not emotionally.
Not politically.
Operationally.
The filing recognizes a reality many of us have understood for years:
NG911 is not simply a new transport mechanism for old ideas.
It’s a fundamentally different operational architecture.
And if we keep trying to preserve every legacy dependency forever, we may never fully realize what NG911 was actually supposed to become.
The Commonwealth of Massachusetts deserves credit for trying to move that conversation forward.
Because progress in public safety doesn’t happen when everyone stays comfortable.
It happens when somebody finally says:
“The future architecture already exists. Let’s stop pretending otherwise.”
AI generated propaganda slop. Just look at Intrado’s comments on the FCC’s website and you can see Mass. has no idea what they’re talking about
Far from ‘AI generated slop’, however everyone is entitled to an opinion, even you. If you have a specific reference to a particular FCC comment, I’m happy to review, consider and debate its relevance.
If your post isn’t AI generated I’ll eat my shoe. The image you used for the audio version video thumbnail is clearly AI-generated and your post reads like every other LinkedIn post I see nowadays.
Here’s the Intrado filing from the ECFS: https://www.fcc.gov/ecfs/search/search-filings/filing/105111589000703
This seems to be political. I don’t mean left/right, but Mass public safety authorities seem to want to make a name for themselves rather than actually working with OSPs to ensure NG911 workability. Why else would they be as inflexible as Verizon’s and Intrado’s filings seems to indicate? No other public safety authority is behaving this way. Illinois even rescinded their Phase 2 filing a couple of weeks ago (see https://www.fcc.gov/ecfs/search/search-filings/filing/10522735508938).
Massachusetts isn’t willing to accept delays for implementation of Phase 1 despite recently-uncovered PS/ALI concerns that were not considered when the Phase 1 and 2 filings were submitted by Mass. Implementing NG911 with these concerns would likely break 911 location services for a substantial number of Mass residents and obviously has implications for subscribers outside of the state as well (see section 2C of the Intrado filing). Here’s a bullet point list of MA’s shortcomings:
– They don’t know their own system (see section 2A and 2B).
– They don’t understand 911 compliance readiness status (see section 3).
– They don’t understand the role of vendors vs. OSPs (see section 4C).
– Despite requiring OSPs to be phase 2 compliant, they themselves have equipment that is unable to conform to the standards they’re requiring from OSPs concerning NG911 (see section 4D, “Non-i3-Conforming CHE” and “Lack of ESInet Support for Real-Time Text.” subheads)
– They don’t understand how dispatch locations are maintained (see Verizon’s comments in this filing: https://www.fcc.gov/ecfs/search/search-filings/filing/10511034352868).
Don’t confuse bullheadedness with leadership.
As for an AI generated IMAGE – yeah, I use AI tools to generate graphics based on creative content I specifically prompt. Do I use AI to summarize a long document? Sure, I also use assistance for grammar, spelling, and fact-checking. The written portion is text generated from me. My typical blog prompt is 2,500 to 3,000 words, all of which is my original thought.
What you posted is appreciated, however, it is a comment from someone who disagrees. So what is stated there may or may not be fact. What it is, is an opinion. Something everyone’s entitled to, and the entire purpose of the proceeding.
There are 3 sides to every story:
1. The right side
2. The wrong side
3. The truth, which is usually somewhere in the middle
The purpose of these proceedings is to collect number one and number two, and then determine exactly where number three is located.
Thanks for commenting. It shows that someone is actually thinking about all of this. At the end of it, neither you nor I will be charged with making the final decision.
Best,
Fletch