On October 26, 2018, the Commission published in the Federal Register the Notice of Proposed Rulemaking (“NPRM”) on Kari’s Law and 911 Access and Location Inquiry proceeding, proposing to implement Kari’s Law and Section 506 of RAY BAUM’s Act by adopting direct dial and notification rules governing calls to 911 and requiring dispatchable location for 911 calls, and consolidating the Commission’s existing 911 rules. (FCC 18-132; PS Docket No. 18-261, PS Docket No. 17-239).

The NPRM proposes several regulations regarding direct dialing and notifications for multi-line telephone systems (“MLTS”), and seeks comment on definitions of terms and other provisions to clarify covered entities’ obligations. The NPRM also considers 911 service location requirements for all 911-capable platforms, specifically fixed telephony, mobile telecommunications, interconnected VoIP services, and Internet-based Telecommunications Relay Services (“TRS”). Specific to wireless, mobile carriers and other covered text providers are currently required to obtain location information sufficient to route text messages to the appropriate PSAP, while text providers are not required to convey location information for purpose of location the person sending the text. The NPRM seeks to refresh the record on how enhanced location information can be generated and delivered with text messages to 911, asking if it is technologically feasible to convey dispatchable location information with texts to sent 911, and if not, the timeframes required to achieve such capabilities. If so, the NPRM asks whether it should apply dispatchable location requirements to text-to-911, and inquires in to the costs and any alternative solutions.

The NPRM does not consider further changes to existing dispatchable location requirements for mobile carriers, as the E911 location accuracy rules applicable to mobile 911 voice services are already incorporated into the Commission’s E911 rules for mobile voice carriers.

Comments are due December 10, 2018.

Reply comments are due January 9. 2019.

Please Contact Us if you have any questions.