Innovating 911 Compliance Testing

This case study explores how Keysight VisionWorks transformed 911 compliance testing and assurance for a Tier 1 North American communications service provider (CSP). Faced with increasing regulatory pressure from the Federal Communications Commission (FCC) and the operational challenges associated with maintaining reliable emergency communications services, the CSP sought a more efficient and scalable approach to validating 911 call routing, connectivity, and compliance across its national network.

Under FCC regulations outlined in Title 47, Section 4.9(h) of the Code of Federal Regulations, communications service providers are required to notify impacted 911 Public Safety Answering Points (PSAPs) within 30 minutes of discovering an outage affecting emergency services infrastructure. Providers must quickly communicate the nature of the outage, its geographic scope, the best-known cause, and estimated restoration timelines. Failure to comply with these requirements can result in significant financial penalties ranging from hundreds of thousands to millions of dollars. Beyond the financial implications, service outages can severely impact customer trust and require substantial operational resources to investigate and remediate.

The CSP’s challenge emerged during a major infrastructure modernization initiative involving the migration of 911 traffic from legacy Time Division Multiplexing (TDM) trunks to IP-based trunks. Historically, all 911 calls, including 4G VoLTE emergency calls, were routed through legacy switching systems that depended on TDM infrastructure. As the provider decommissioned its 3G network, these legacy systems remained operational solely to support 911 routing, creating inefficiencies related to cost, power consumption, cooling requirements, and physical infrastructure utilization.

To complete the migration and secure FCC approval, the CSP was required to demonstrate that at least 10% of emergency calls within each market were correctly routed to the appropriate PSAPs, delivered clear voice quality, and transmitted accurate location information. Traditionally, the CSP relied on third-party field technicians who traveled to multiple markets, physically visited test locations, and placed live 911 calls to validate compliance. This process was costly, time-consuming, and operationally challenging, especially in geographically remote regions, restricted-access locations near military facilities, or areas affected by severe weather conditions.

Keysight addressed these challenges by leveraging its VisionWorks service assurance platform to create a remote and automated testing solution. The solution utilized VisionWorks Controllers and virtual test agents (VTAs) that enabled CSP-designated personnel to remotely initiate and validate test 911 calls from anywhere in the United States. Instead of relying on live over-the-air testing, the system simulated calls from designated eNodeBs and verified successful routing to the correct PSAPs. The platform validated routing accuracy, confirmed audio quality through two-way voice testing, and ensured that routing digits and location information such as longitude and latitude were properly transmitted.

By eliminating the need for large-scale field deployments, the CSP significantly reduced operational expenses associated with compliance testing. Remote testing also enabled validation in previously inaccessible locations, improving coverage and accelerating deployment timelines while maintaining confidence in network performance and regulatory compliance.

Following successful FCC compliance validation, the CSP expanded its use of VisionWorks to address a broader operational challenge: continuous 911 assurance testing. Prior to automation, the provider lacked an efficient mechanism to repeatedly validate emergency call routing and connectivity across its nationwide network. While outages affecting emergency services were infrequent, they represented high-severity operational risks that could expose the CSP to regulatory penalties and reputational damage if not identified and resolved quickly.

Keysight worked with the CSP to convert the virtual test agents into automated 911 assurance agents capable of running nightly test cycles. During overnight testing windows, multiple VTAs simultaneously placed thousands of automated 911 test calls across the network. These tests continuously verified routing accuracy, call completion, audio quality, and PSAP connectivity, providing the CSP with ongoing confidence that emergency services remained operational and compliant.

The case study also highlights how VisionWorks supports the evolution toward Next Generation 911 (NG911) architectures. As NG911 deployments expand, the solution enables automated end-to-end testing using recorded voice messages delivered through NG911-enabled PSAPs. The platform validates routing paths, measures voice quality, confirms successful call delivery, and supports comprehensive reporting for emergency services testing and assurance.

Ultimately, the collaboration between Keysight and the CSP demonstrates how automated, remote testing can modernize emergency services validation while reducing costs, improving operational efficiency, and strengthening compliance readiness. By replacing labor-intensive manual testing with scalable automation, the CSP improved its ability to proactively monitor and maintain reliable 911 services while preparing for the future of NG911 communications infrastructure.