At its August Open Meeting, the FCC adopted a Report and Order (“Order”) implementing portions of two recent statutes—Kari’s Law and the RAY BAUM’s Act—that address ensuring greater access to 911 and emergency services for members of the public. Kari’s Law requires multi-line telephone systems (“MLTS”), like those in hotels and offices, to have the capability for a user to dial 911 directly without having to press “9” (or some other access code) first to call out.  Section 506 of the RAY BAUM’s Act requires the FCC to consider adopting rules to ensure a 911 caller’s dispatchable location is properly conveyed from an MLTS to the public safety answering point (“PSAP”). The Commission took the opportunity of implementing these two Acts to also expand 911 dialing requirements for certain VoIP, TRS and mobile text-to-911 services.

With these new requirements, the FCC continues its trend of expanding the availability of emergency services calling to newer technologies. As these new forms of communication become more mainstream – and as they grow as replacements for, rather than complements to, traditional telecommunications services – the FCC has been inclined to make emergency services a “must have” feature of the service. Providers of new communications technologies should carefully review their service offerings to determine how to handle customer attempts to reach emergency services.


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Spectrum issues will once again take center stage at the FCC’s next open meeting scheduled for March 15, 2019. In a jam-packed agenda, the FCC plans to create a new category of experimental licenses for operations in spectrum above 95 GHz and potentially make more than 21 gigahertz available for unlicensed use in these so-called “spectrum horizons.” The agency also anticipates launching a rulemaking to permit broadband operations in a portion of the 900 MHz band that currently is used for two-way radio operations. In addition, the FCC expects to seek input on improving spectrum partitioning, disaggregation, and leasing arrangements. These spectrum proposals follow similar FCC actions designed to improve access to mid- and high-band frequencies, and could jump-start a new wave of innovation in next-generation, short-range technologies. Rounding out the major actions on the March agenda, the FCC plans to propose new wireless E911 location accuracy requirements and adopt service quality standards for intermediate service providers to improve rural call completion. If adopted, these proposals would impose significant obligations on carriers of all sizes and could potentially lead to serious fines in the event of noncompliance.

You will find more details on the significant March meeting items after the break:


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At its March 15 Open Meeting, the FCC intends to vote on a Fourth Further Notice of Proposed Rulemaking (“FNPRM”) in its Wireless E911 Location Accuracy Requirements proceeding that would consider adoption of a vertical, or z-axis, location accuracy metric. Currently there is no z-axis metric, despite proposals by the Commission going back to as early as 2014. The FNPRM, if adopted, would propose a z-axis metric of +/- 3 meters relative to the handset for 80 percent of wireless E911 calls, the same metric proposed in a Third Further Notice in the proceeding. The Commission deferred promulgation of a specific metric for lack of sufficient test data in a 2015 order that established benchmarks and timetables for the deployment of z-axis in the top 50 Cellular Market Areas (“CMAs”).

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stock_05032012_0769Yesterday, the Federal Communications Commission (“FCC” or the “Commission”) released its final public notice of updates to the Commission’s Public Safety Answering Point (PSAP) Text-to-911 Readiness and Certification Registry (Text-to-911 Registry).  The Text-to-911 Registry contains the effective readiness date of the PSAPS to receive texts to 911, as well as point of contact information for providers to use to contact PSAPs for coordination purposes.

As stipulated in the FCC’s Text-to-911 Order from August 2014, Commercial Mobile Radio Service (CMRS) providers and other providers of interconnected text message service (collectively, “covered text providers”) must begin routing 911 text messages to requesting PSAPS within six months of notification that the PSAP is ready.  The notice can come directly from a PSAP or by listing the PSAP on the Text-to-911 Registry posted on the FCC’s website.


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