On September 8, APCO filed reply comments with the Federal Communications Commission (FCC) regarding the FCC’s proposed rules to facilitate the transition to NG9-1-1. APCO highlighted aspects of its initial comments and showed how other parties’ comments support APCO’s positions that the FCC should adopt a comprehensive approach to NG9-1-1, require service providers to achieve interoperability, and avoid placing responsibilities and costs on the 9-1-1 community that better rest with service providers. APCO also identified areas that warrant further examination by the FCC, such as the tradeoffs of delivering 9-1-1 traffic over traditional dedicated lines rather than a cloud-based Internet connection.