On August 9, APCO filed comments with the Federal Communications Commission (FCC) regarding proposed rules to facilitate the transition to NG9-1-1 by requiring originating service providers to deliver 9-1-1 traffic in IP-format. APCO encouraged the FCC to adopt a comprehensive view of NG9-1-1 that aligns with federal legislative proposals and public safety’s vision of an end-to-end, interoperable system. APCO recommended that the FCC’s rules provide ECCs with the flexibility they need to pursue innovative solutions for implementing NG9-1-1 and that the FCC not place costs and responsibilities on the 9-1-1 community that better rest with the service providers and vendors. Key among APCO’s points was to urge the FCC to adopt rules requiring the service providers to achieve interoperability.