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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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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The Federal Communications Commission’s (“FCC’s” or “Commission’s”) new text-to-911 rules are effective today. As we discussed in a previous post immediately following the adoption of the related order, the FCC has mandated that all messaging services that permit users to send text messages using domestic telephone numbers also enable users to communicate with public emergency response providers via text messages. The FCC adopted its Second Report and Order and Third Notice of Proposed Rulemaking in the Text-to-911 proceeding on August 8, 2014. On September 16, the order and NPRM were published in the Federal Register making the rules effective today and setting the comment deadline on the NPRM for today, with reply comments due on November 17.
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Following on the heels of a voluntary commitment from the four nationwide wireless carriers to support text-to-911, the Federal Communications Commission (“FCC” or “Commission”), on August 8, 2014, adopted a Report and Order and Third Notice of Proposed Rulemaking that will require all wireless carriers and “interconnected” text messaging providers – i.e., over-the-top (“OTT”) text