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A Message From the NENA Board of Directors About the i3 Standard

Wednesday, March 22, 2017   (0 Comments)
Posted by: Chris Nussman
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The i3 Standard – A Response to the APCO Statement by the NENA Board of Directors

Click here to download a .pdf version of this statement, here to download a statement from the Industry Council for Emergency Response Technologies (iCERT), and here for the statement by the National Association of State 9-1-1 Administrators (NASNA).

NENA’s i3 architecture standard is accepted and supported by industry and public safety practitioners around the world. Hundreds of developers, including members of NENA and APCO and many commercial partners, have worked diligently to develop both the i3 standard itself, and the broader family of NG9-1-1 standards built on the i3 architecture. These efforts have paid off spectacularly: The i3 standard is the universally-acknowledged basis for public safety deployments of NG9-1-1 systems.

On March 17, 2017, APCO sent a statement to its membership entitled, The Vision for Next Generation 9-1-1 and the Role of Standards. In the message, APCO references language in a draft Next Generation 9-1-1 Act of 2017 bill, prepared by Senators Nelson (D-Fla.) and Klobuchar (D-Minn.), which calls for an “accredited, non-proprietary, consensus-based, standards approach for all aspects of NG9-1-1 services.” NENA and APCO have both announced support for this language in the draft legislation.

However, APCO’s statement attempts to cast doubt on NENA’s NG9-1-1 architecture standard, Detailed Functional and Interface Standards for the NENA i3 Solution (or “i3”, for short), which is the universally-supported standard in the field, and which will meet the draft legislation’s requirements.

In short, APCO’s characterizations of the i3 standard are simply wrong.

By sowing doubt about the best way forward, APCO has endangered the timely roll-out of NG9-1-systems for the American public whom we serve.

The facts about i3:

  • i3 is a non-proprietary, consensus-based standard, developed according to strict process requirements. This standard describes protocols, interfaces, and systems to locate users who contact 9-1-1 via voice, video, text, data, and other means, route their “calls” to the appropriate Public Safety Answering Point (PSAP), and allow for easy transfers, failovers, and multi-party calls.
  • NENA standards are developed by dedicated public safety professionals from PSAPs and private companies alike. We welcome any participant who is willing to contribute to our standards work, without review or pre-approval, and without requiring participants to sign non-disclosure agreements.
  • The current revision of i3 (revision 2), was developed using NENA’s ANSI-accredited standards processes, ensuring openness, inclusivity, fairness, and due process to all stakeholders. However, NENA chose not to make revision 2 a candidate American National Standard, because we wanted more experience with ANSI processes before submitting a standard of i3’s complexity.
  • The NENA Development Group is actively working on i3 revision 3, using the same ANSI-accredited process. As an American National Standards Institute (ANSI)-accredited Standards Development Organization, NENA notified ANSI in 2015 that this revision will be a candidate American National Standard.
  • i3 leverages global standards to accelerate innovation, enable economies of scale, and provide seamless interoperability between public safety networks, hardware, software, and databases, in carrier and system-service provider networks, within the PSAP, and in the field responder community.
  • The i3 standard is universally accepted by PSAPs, 9-1-1 authorities, states, regional authorities, and private-sector companies as the standard for NG9-1-1.
  • Industry is producing products and services based on the i3 standard. Each of these efforts underscores the wide acceptance and recognition of i3 as the NG9-1-1 standard.
    • i3 has been adopted, by the CRTC, as the standard for NG9-1-1 in Canada.
    • i3 was used as the basis for Europe’s NG1-1-2 standard.
    • i3 has been referenced in many FCC documents.
    • Dozens of RFPs have been issued by public safety agencies for i3-compliant NG9‑1‑1 systems, networks, hardware, and software.

Here is where APCO’s statement misses the mark:

  • APCO states that the i3 “standard” [sic] is “not accredited” (emphasis original). The statement goes on to say that “APCO will…advocate for…NG9‑1‑1 networks that are…based on accredited, non-proprietary, consensus-based standards.”
    • Many current standards used by public safety, and advocated-for by APCO, were not developed by accredited SDOs. For example, APCO has publicly endorsed the transition to IP- and LTE-based networks for public safety.[i] Yet neither the IETF, which develops IP, nor the 3GPP, which develops LTE, is an accredited SDO.
    • Although APCO notes that the US organization responsible for standardizing IMS, known as ATIS, is accredited, the IMS 9-1-1 standard itself is not: ATIS has never filed a “PINS Notice” required to initiate development on a Candidate American National Standard or “ANS.” (This is a common practice among SDOs.[ii]) Thus by APCO’s definition, IMS 9-1-1 does not meet the requirements of the draft Bill.
    • Just like ATIS, NENA developed early versions of the i3 standard without the full formality of a candidate-ANS process. In mid-2015, however, NENA filed the required paperwork: i3 revision3 will be an accredited American National Standard.
    • Though APCO implies that i3 is not a “consensus” standard, industry and public safety support for the standard suggest otherwise: Years before i3 v1 was first published, AT&T’s comments to the FCC concerning the National Broadband Plan extensively referenced i3 as the architecture standard for NG9-1-1.[iii] Later, when i3 v1 was first published, APCO published a press release from major public safety vendors supporting the standard.[iv] In 2016, AT&T released its ESInet product, stating that it “meets the latest National Emergency Number Association (NENA) i3 standards.”[v] These announcements show robust, consistent, and industry-wide consensus that i3 is the standard for NG9-1-1.
    • APCO’s statement also represents a significant reversal, since, according to then-president Gregg Riddle: “APCO has endorsed the architecture of Next Generation 9-1-1 as described in the “‘Detailed Functional and Interface Standards for the NENA i3 Solution.’”[vi]
  • APCO next attempts to negatively characterize the i3 standard as “incomplete.” Though technically true, this statement is also extremely misleading: i3 is still undergoing intense development, and will be revised and extended over time just as all complex technical standards are.
    • For example, LTE is currently moving to its 15th release, and more releases are expected in the future. NENA has been explicit that i3 would follow a similar path ever since version 1 was approved in 2011.[vii]
    • “Incomplete” standards are foundational to much of what APCO does. Their own P25 radio standard has been in active development for more than 27 years, with work still ongoing, and with no warning from APCO against its adoption or use. To be clear, the i3 standard is intentionally designed to be iterative and evolutionary, in order to best meet the needs of 9-1-1 in an ever-changing world of technology. This is a strength, not a flaw.
    • i3’s continued evolutionary path is a strength that APCO previously recognized: In an FCC filing dated December 12th, 2011, APCO’s then-President, Gregg Riddle stated that “APCO understands that the i3 Stage 3 architecture is not yet a build-to specification and that development efforts will continue to evolve as has been the case with other complex, open standard communications architectures” (emphasis added).[viii]
  • Finally, APCO states that “completed standards in the global marketplace can provide the NG9-1-1 solution,” and goes on to extensively praise the 3GPP / ATIS-developed IMS standard, saying that it “will play a key if not leading role for meeting the goals and requirements of the draft bill and providing the path needed to realize a full NG 9-1-1 deployment.” Again, this statement contains a kernel of truth: NENA has long recognized the need to ensure interoperability between IMS-based originating networks and i3-based NG9-1-1 systems.[ix] But IMS is not a replacement for i3, and was never meant to be.
    • In 2011, 4G Americas, a carrier interest group aligned with ATIS, told the FCC that “The National Emergency Number Association (“NENA”) i3 solution for Public Safety Answering Points (“PSAPs”), in conjunction with the compatible 3GPP Session Initiation Protocol/IP Multimedia Subsystem (“SIP” and “IMS”)-based solutions now being specified in 3GPP, is the best long-term approach for texting to 911. 4G Americas recommends that the Commission encourage industry and the PSAP community to focus on NENA i3 with 3GPP’s SIP/IMS-based solution for the long-term, since that approach will deliver the most robust multimedia solution for PSAPs and the public they serve.”[x]
    • More recently, ATIS told the National Public Safety Telecommunications Council in 2015 that its IMS work included “Definition of specific functional elements that are functionally equivalent to the existing NENA i3 architecture with compatible interfaces to support the delivery of emergency calls to legacy and NG9-1-1/i3 PSAPs.”[xi]
    • Even if none of this were true, however, these 3GPP / ATIS standards would still fail APCO’s test: Contrary to APCO’s statement, 3GPP is not “internationally accredited.” In fact, it isn’t accredited at all. And while ATIS is accredited in the United States by ANSI, it did not develop IMS or IMS 9-1-1 as candidate American National Standards.
    • i3 and IMS share a common heritage. They are compatible and complementary standards. Contrary to APCO’s statement, they are not competitors. While NENA expects that some carriers will choose to implement IMS-based functions in their networks, that does not mean that 9-1-1 authorities should fear implementing i3-based NG9-1-1 systems now, or in the future. i3 represents the consensus standard for NG9-1-1 systems in the public safety community, and the clear path forward for NG9-1-1.

APCO’s statement attempts to both cast doubt on the work of dedicated standards developers, and sow confusion in a public safety market that needs certainty, now more than ever.

NENA hopes that the facts laid out here will set the record straight once and for all.

[i]    Ball, Guy, LTE: An Overview of the Technology and the Benefits to Public Safety, APCO Public Safety Communications 29 (Nov./Dec. 2016) (available at:

[ii]   The National 911 Program, Next Generation 911 (NG911) Standards Identification and Review, (Mar. 2016) (available at:

[iii]  In re Public Safety, Homeland Security, and Cybersecurity Elements of National Broadband Plan; National Broadband Plan Notice #8, AT&T, Comments at 25-31, FCC GN Docket Nos. 09-47, 09-51, 09-137; PS Docket Nos. 06-229, 07-100, 07-114; WT Docket No. 06-150; CC Docket No. 94-102; WC Docket No. 05-196 (Nov. 12, 2009) (available at: AT&T’s comments mention i3 eleven times with respect to NG9-1-1, and IMS only twice, both in reference to cybersecurity.

[iv]   Public Safety Industry Leaders Support NENA Next Generation 9-1-1 Architecture Interface Standard known as i3 (May 3, 2011) (available at: (naming 911 Datamaster, Avaya, Cassidian Communications (now Airbus DSC), Digital Data Technologies, Inc., GeoComm, RedSky Technologies, Solacom, and TeleCommunications Systems (now Comtech)).

[v]    AT&T Launches Next Generation IP Network Service for 9-1-1 (Feb. 29, 2016) (available at:

[vi]   In re Facilitating the Deployment of Text-to-911 and other Next Generation 911 Applications & Framework for Next Generation 9-1-1 Deployment, APCO Int’l, Comments at 19, FCC PS Docket Nos. 11-153 & 10-255 (Dec. 12, 2011) (available at:

[vii] NENA: The 9-1-1 Association, i3 v. 1 cover note, passim (Jun. 2011) (available at:

[viii] Supra, n.3, at 19.

[ix]   In re Facilitating the Deployment of Text-to-911 and other Next Generation 911 Applications & Framework for Next Generation 9-1-1 Deployment, NENA, Comments at 22, FCC PS Docket Nos. 11-153 & 10-255 (Dec. 2011) (available at:

[x]    In re Facilitating the Deployment of Text-to-911 and other Next Generation 911 Applications & Framework for Next Generation 9-1-1 Deployment, 4G Americas, Comments at 2-3, FCC PS Docket Nos. 11-153 & 10-255 (Dec. 2011) (available at:

[xi]  NPSTC: Full NPSTC Meeting Slide Deck for the IWCE / Las Vegas meeting, ATIS Presentation 53, 66 (Mar. 20, 2015) (available at: