5 Reasons NG911 Modernization Can’t Wait

Key Takeaways:

• NG911 modernization is no longer optional. FCC 24-78, effective Nov. 25, 2024, calls for originating service providers (OSPs) to deliver 911 traffic in SIP format on request.
• NG911 modernization built to NENA i3 is the difference between a 20-year deployment and a five-year one. The standard defines specific interoperable functional elements (ESRP, ECRF, LVF, BCF, etc.), allowing systems to evolve without a complete overhaul.
• NG911 modernization must account for disaster resilience as a core architecture requirement, not an afterthought. When Livingston Parish’s 911 capability collapsed during the 2016 Baton Rouge flooding, the IT director physically carried a CAD server through rising floodwater as neighboring dispatchers recorded call notes on paper. A pre-positioned mobile emergency voice operations unit would have been a game-changer for emergency response.

In the spring of 1968, a switchboard operator at the Haleyville, Alabama Police Department picked up a ringing line and answered the first 911 call ever placed in the United States. The caller knew where the call was going because they were in Haleyville. The receiver knew where the caller was because the address tied to the phone number on a piece of paper in a binder.

That binder, now in modernized form, still sits underneath most of America’s 911 system. Fifty-eight years later, more than four out of every five 911 calls come from a wireless device. Which means that the phone number is no longer a reliable proxy for callers’ location. And the carrier delivering the call may not be the same carrier behind the infrastructure. As for the “binder” (the Master Street Address Guide and its companion ALI database), it’s performing a job it simply was not engineered for. 

This is the cornerstone problem of every NG911 modernization decision in front of agencies right now. The legacy network is answering calls on borrowed time. And there are five reasons to no longer put it off, and one architecture standard (NENA i3) that determines whether a deployment built today will still work in 2040.

The Five Pressure Points for NG911 Modernization

1. Call volume has shifted, and the architecture has not

Wireless is over 80% of total 911 traffic and rising and Text-to-911 is a reality. INDIGITAL’s network passed text in production in 2013. And Texty now runs in 113 agencies in Indiana alone, where the third quarter of 2025 saw 10,257 inbound and 38,736 outbound text sessions. Meanwhile, traditional voice growth on copper is flat or declining. The legacy selective router built for that traffic is completely outclassed. A network engineered to deliver one call type, from one carrier per region, with location pulled from a flat-file database after the fact, cannot natively support the call mix the public is currently sending.

2. Carriers are sunsetting the underlying transport

The TDM circuits that legacy 911 rides on are being decommissioned by the same carriers that built them. Once a tariffed circuit is gone, it does not come back. For boards still working through their NG911 modernization, the timeline now mirrors the carrier’s decommissioning schedule rather than the board’s own. Putting NG911 modernization off now means waiting for someone else’s sunset notice to arrive.

3. The FCC has set the clock

The Commission’s July 2024 Sixth Report and Order (FCC 24-78) became effective Nov. 25, 2024. It requires originating service providers to deliver 911 traffic in IP-based session initiation protocol (SIP) format on request. So far, INDIGITAL has assisted in submitting 111 Phase-1 requests. The March 2025 Further Notice of Proposed Rulemaking signals that more is coming. Under these rules, the IP transition is no longer something an ECC can defer simply by not initiating it. The carrier will deliver SIP. The question is whether the receiving network is ready to accept it.

4. Cybersecurity is no longer a separate budget line

Ransomware operators have figured out that 911 is high-leverage and sometimes poorly defended. The attack surface of an IP-based emergency network is larger than a TDM one. That is true and unavoidable. Don’t stay on the soon-to-be deprecated TDM (which has its own vulnerabilities). Design for it using certificate-based trust, TLS in production, SOC-audited operations, dual-node architecture, and a real disaster recovery plan. Not every NG911 deployment includes those elements today. And the ones that do are typically built to full i3 conformance from the start.

5. The year-over-year rise in natural disasters outpaces legacy 911 infrastructure

The fifth (increasingly urgent) element shaping next generation 911 is the steady rise in the frequency and severity of natural disasters. NOAA’s billion-dollar disaster record shows the pace climbing year after year. Events once considered “hundred-year” floods, fires, and storms now arrive in clusters, often in the same calendar year. For 911 authorities, it’s a recurring infrastructure stress test that much of the country never engineered toward. What’s more, it’s the reason a deployable, mobile emergency voice operations capability like MEVO has become core architecture.

What an Unmodernized Network Costs You

The case study every PSAP director should keep handy is the August 2016 flooding in the Baton Rouge area.

Over four days, a slow-moving storm dropped more than 31 inches of rain across Livingston Parish. That’s more water than Hurricane Katrina left behind! Despite this, it never earned a hurricane’s name or the federal posture that comes with one.

Local 911 capabilities collapsed to basic voice and radio. The IT director physically waded into the 911 center and carried the CAD server through rising water to higher ground. As a result, calls were rerouted to neighboring East Baton Rouge 911, where dispatchers recorded them on paper because the two CAD systems could not exchange data.

The National Guard, Coast Guard, State Police, and the volunteer Cajun Navy then coordinated rescues from those handwritten lists. Instead of leaving lives in the hands of a clipboard, a pre-positioned MEVO unit (a self-contained, transportable PSAP capability that can be stood up on higher ground in mere hours) would have changed the entire shape of that response, thanks to continuous call answering, native NG911 call delivery, and a working CAD instead of paper.

NENA i3 Requirements (What a Correctly Built NG911 System Does)

Once an agency modernizes, the question becomes: modernize to what? Today, NG911 applies to a wide range of architectures, only some of which conform to the i3 standard. Knowing the difference is what separates a 20-year deployment from five-year deployment.

NENA i3 is the playbook for what an end-state NG911 system looks like. The standard sits at the level of individual functional elements (ESRP, ECRF, LVF, BCF, LIS, PRF, and SI), each interoperable across standardized SIP-based call signaling, a geospatial routing model, and a defined IP backbone and security posture. In other words, i3 describes a set of interoperable building blocks.

Most agencies use “NG911-ready” to refer to their foundational infrastructure (ESInet, NGCS, governance alignment), even if full i3 call-handling and location workflows are not yet operational. That language is now obsolete, thanks to the new federal regulatory framework: FCC 24-78.

Now, when a 911 Authority makes a valid request, OSPs must deliver 911 traffic to designated NG911 Delivery Points using IP-based interfaces. End-to-end NG911 only works when the carrier delivers IP and the receiving network is ready to accept it.

A correctly built NG911 system does five things a legacy network cannot:

• Accepts the call format the public sends: voice, text, image, video, telematics, sensor data
• Routes by location, so a call from a moving vehicle reaches the right PSAP the first time
• Survives a partial failure: an outage in one node, region, or carrier ingress does not silence the system
• Carries multimedia and data on to first responders in the field instead of orphaning it at the call-taker
• Absorbs the next ten years of carrier and device evolution without another forklift upgrade

The Questions for Any NG911 Procurement

While the standard continues to evolve, i3 is operational rather than aspirational. As of today, the NENA i3 standard validates end-to-end in IVV testing, and T-Mobile’s NGES Innovation Lab demonstrated carrier-integrated multimedia sessions.

Our upcoming installments in this series will go deeper into each layer of the NG911 stack. We’ll cover the GIS data discipline and deployment models (statewide, regional, and local) that determine how an architecture scales. Plus, the disaster-recovery posture that grades every other decision when the system performs under stress. 

Follow along via The 911 Wire for the rest of the series.

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