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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At the next open meeting on September 26th, the FCC Commissioners will vote on a Notice of Proposed Rulemaking (“NPRM”) aimed at improving the nation’s 911 system and Americans’ ability to access emergency services. The proposed rule changes are largely intended to implement directives from Congress in two bills that were signed into law earlier this year. Importantly, the proposed rules will apply not only to traditional providers of telecommunications service, but also equipment manufacturers and other vendors in the communications supply chain, as well as businesses and other entities that operate communications systems that allow users to dial 911. Given the potentially broad reach of these proposed rules, we encourage our readers to monitor this proceeding carefully and be prepared to offer feedback to the FCC on proposed changes that will impact your business.

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