Final 911 Rules Largely the Same as Draft Proposal

the rules last week over partial dissents by Jessica Rosenworcel and Geoffrey Starks (see 1908010011). The rules also apply dispatchable location requirements to MLTS, fixed telephone service, VoIP, telecommunications relay services and mobile texting. The order released Friday includes comments by Commissioner Mike O’Rielly, who had reservations about the FCC’s approach. Submissions in the record discussed “the possible unintended consequences of requiring the delivery of outbound-only interconnected VoIP calls to 911,” O’Rielly said. “When such calls have connected to emergency call centers, the calls have been of very short duration, indicating possible misdials or nefarious activity.” The concern was that the FCC could create a problem similar to that with non-service initialized (NSI) phones, unconnected mobile phones that “public safety has recognized are used in a high percentage of fraudulent 911 calls,” he said: “Instead of dismissing these concerns, the Commission should have considered this further, because, as we have learned with NSI phones, once you implement these rules, it is hard to undue them without concerns being raised about the one legitimate call that was could be missed and the legal liability that can result if it is not connected to a call center.” O’Rielly also complained the cost-benefit analysis “primarily discusses what we stated in the Notice, which is mostly based on comparing the potential cost against the benefit of a hypothetical number of lives being saved based on the flawed 'Value of a Statistical Life' metric. Now that the Office of Economic and Analysis is up and running, we must do better.”