Lumen and Intrado told Colorado’s ESInet user group on a special call that their NextGen 9‑1‑1 core is already able to accept SIP call traffic for the FCC’s phase 1 migration, and that the next steps are for the state to name two points of interconnection and to distribute a formal valid‑request form to originating service providers.

The clarification came after Paul Bridal, Lumen’s public policy director for regulatory compliance on 9‑1‑1, opened the presentation by saying, "The conversation today will center around Lumen as an OSP, regarding this upcoming NG 9 1 1 to facilitate phase 1 and phase 2 evolution." Bridal and Doug Cunningham, Lumen’s solution architect for NextGen 9‑1‑1, described an existing Lumen backbone and two prepared, geographically diverse SIP points of interconnection (POIs) that Lumen said are capable of receiving SIP today.

Why it matters: the FCC’s Report and Order requires originating service providers (OSPs) to begin transitioning to IP delivery after receipt of a valid request from a 9‑1‑1 authority; Colorado’s network contains more than 90 PSAPs, and the state asked Lumen and Intrado to clarify whether OSPs must connect to each PSAP individually or to shared POIs. Jennifer Kirkland of the state 9‑1‑1 program and Daryl Branson agreed to act as state points of contact to consolidate PSAP readiness and to publish the designated delivery points so OSPs can be instructed how to connect.

Lumen and Intrado described a two‑phase approach. For phase 1, they said, the core will accept basic SIP call delivery now and can continue to deliver calls to PSAPs using existing egress formats (including media converters where PSAPs still require TDM/CAMA). Doug Cunningham said, "Today, the entire solution for the state of Colorado is already SIP capable. It is already receiving SIP traffic ... The traffic ... is converted via the Lumen LNGs. And we bring that into our next gen 9 1 1 provider, Intrado VSF." Rich (Intrado) added that "a hundred percent of the calls that go into the Intrado core today are already being converted with LNG. That means that we are performing what we call a PIF function. We're converting your TDM SS7 traffic in our LNGs, and we're converting that and delivering it into Intrado via SIP."

Phase 2 — full i3/PIDF‑LO (PINTFlow) delivery and end‑to‑end IP feature sets — will require additional PSAP CPE work, tariff language and core configuration. Participants cautioned that i3 readiness is uneven across PSAPs. As one participant summarized, "I3 is a bigger undertaking ... [and] will require CPE changes and updates and also will require changes, configurations [and] update within the core infrastructure itself." Lumen staff said a tariff filing will be needed to offer i3 services and that CenturyLink/Lumen intends to refile after the rulemaking clarifies requirements.

On the process, Lumen advised that once the state names the two POIs and publishes ordering/contact details, Lumen will craft and distribute an OSP connection letter and work with individual OSPs to provision ports and trunking at those POIs. Joe Benkert and other participants pressed for clarity about whether OSPs could be requested to convert traffic on a PSAP‑by‑PSAP basis; Lumen and Intrado said OSPs can begin moving individual counties/PSAPs as those authorities are ready, provided the state publishes the POIs and the valid‑request form is issued.

Participants asked for technical language PSAPs can use when querying CPE vendors about i3 readiness. Intrado and Lumen agreed to provide standard wording and a list of CPE versions they have tested; Rich and Steve (Intrado/Lumen representatives) committed to send sample language and a readiness summary within one week. The group scheduled a follow‑up discussion and agreed to use the standing ESInet user group meeting to continue.

The meeting left several open items: the state must publish the two designated POIs and the valid‑request form; Lumen/Intrado must provide test/requirements language for PSAPs and CPE vendors; and tariff and configuration details for i3 remain to be finalized. Participants emphasized that phase 1 is primarily an ingress change (how OSPs hand off SIP into the ESInet) and does not force PSAPs to retire legacy gateways immediately.

Quotes in context: Jennifer Kirkland, with the state 9‑1‑1 program, asked for clarity early in the call: "Did I hear you correctly that you are presenting from CenturyLink's position as an OSP? Because we thought we were here to talk to you about CenturyLink's readiness as our basic emergency service provider." Lumen staff responded that they were prepared to discuss both roles but that a separate, focused session on BESP readiness would be scheduled.

Next steps and timeline: Lumen and Intrado said they can accept SIP at the two POIs today and will provide the requested technical language within one week. The ESInet user group will continue the discussion at its next standing meeting to set a date for a part‑2 session to finalize POI designation, form distribution, and a migration schedule.

Ending: The call concluded with agreement to continue the conversation at the standing ESInet user group meeting in two weeks, and with Lumen/Intrado agreeing to provide written materials and sample language for PSAPs and CPE vendors before the next session.