Commenters Support FCC 911 Thrust; Industry Has Dispatchable-Location Concerns
Parties backed an FCC effort to improve 911 calling and location accuracy, noting technical challenges. There was broad support for proposals to implement Kari's Law requirements requiring 911 direct dialing from multiline telephone systems (MLTS) in larger enterprises. Industry resisted some potential regulations, particularly on a Ray Baum's Act (see 1812110052) mandate to consider requiring "dispatchable location" information is conveyed with calls to responders. Telecom and VoIP providers, equipment makers, public safety entities, enterprise groups and others filed over 30 comments in docket 18-261 through Tuesday on an NPRM (see 1809260047).
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Enhance 911 accuracy "in a flexible and effective manner" without imposing "unreasonable burdens, particularly on operators of smaller systems," recommended NCTA. Craft "straightforward" rules focused "on an enterprise’s [MLTS] direct dialing capability while not micromanaging the relationships among different stakeholders," suggested Verizon: "Focus on the characteristics of each particular service to determine whether, how, and when dispatchable location information should be included with a 911 call." NTCA said 911 service for "enterprise and other MLTS users presents complications," as carriers, after initial installation, "lack visibility into any individual user's location to accurately" and quickly "update handset location or other data."
"The best source of location information is the MLTS customer," AT&T said: "MLTS customers managing their own MLTS systems [should] have responsibility for maintaining" information accuracy. MLTS customers should be allowed "to decide whether they want to upload dispatchable location data or to pay someone, like an installer or a third-party vendor, to do so," said USTelecom: "Mandating that installers upload location data and holding them liable ... would unnecessarily increase MLTS costs and stifle ... innovation." The American Cable Association suggested codifying industry dispatchable-location best practices and avoiding "unnecessary burdens on service providers." The Voice on the Net Coalition said fixed interconnected VoIP providers shouldn't be required to provide dispatchable location information, amid nomadic "technical limitations." But Bandwidth sought "uniform federal regulations that compel all necessary parties in ... MLTS environments to ensure effective 911 calling."
The Telecommunications Industry Association said a proposed MLTS definition is overbroad and any requirement that MLTS be "pre-configured" to support 911 direct-dial and notification duties must be practical. A "proposed effective date for providing dispatchable location information for all MLTS emergency calls is not feasible," TIA said. Cisco questioned the definition and "pre-configured" proposals, urging a phased location approach. Seeking "enterprise flexibility," Panasonic urged implementation of direct dialing and notification duties, with further study of "whether, when, and how to impose dispatchable location requirements."
Public safety groups generally backed the NPRM. The National Public Safety Telecommunications Council urged "expeditious implementation of Kari's Law" and Ray Baum's Act dispatchable-location requirements, supporting "many" FCC proposals. APCO backed "direct dial and on-side notifications" for MLTS, "requiring dispatchable location information for 9-1-1 calls regardless of technological platform." The National Emergency Number Association hopes the agency continues "great strides toward making the 9-1-1 experience streamlined, simple, and safe for anyone on any technology -- including real-time text and multimedia." The National Association of State 911 Administrators and others also filed.
Enterprise groups warned against mandating MLTS on-site 911 notification details under Kari's Law. Notification content should be left to operators, said the Ad Hoc Telecommunications Users Committee, citing limitations in transmitting notifications. Hotels need "flexibility to implement the notification requirement," consistent with their technical capability and operational preferences, agreed the American Hotel & Lodging Association. "Clarify that the MLTS rules only apply on-location at sites where MLTS is deployed and the owner controls the network," recommended RingCentral. West Safety Services called FCC Kari's Law proposals "an excellent first step toward a nationwide" E-911 MLTS standard, urging "verified dispatchable location information requirements for other communications services where technically feasible."
On dispatchable location, "there are complexities and costs associated with the validation of street addresses for MLTS, particularly in multi building environments," said ATIS. The FCC doesn't have to impose "complex and expensive regulatory solutions" because innovative "marketplace solutions" can locate 911 callers by leveraging "GPS coordinates, a wireless carrier’s cell site(s), Wi-Fi hotspots, etc.," said Microsoft. Video relay service providers need dispatchable-location flexibility, said Sorenson Communications. Hamilton Relay urged consideration of all telecom relay service 911 issues in a TRS proceeding. An FCC blog post pledged more work on 911 systems next year, including to act on MLTS calling by a September deadline (see 1812110035).