FCC Issues FNPRM Seeking Comment on E911 Rule Changes


On September 23, 2010, the Federal Communications Commission (“FCC”) released its Further Notice of Proposed Rulemaking (“FNPRM”) and Notice of Inquiry (“NOI”) regarding E911 rule changes and extension of existing rules to additional VoIP and wireless services.  The FCC requests suggestions to improve wireless location accuracy and comments on extension of E911 rules to VoIP services not interconnected with the Public Switched Telephone Network (“PSTN”), and the application of E911 rules to additional wireless services, devices and applications.

Specifically, the FCC seeks comment on ways to improve location accuracy for services currently subject to these requirements, including interconnected VoIP; whether it should apply similar requirements on “nomadic” VoIP; and whether VoIP providers should be required to automatically provide geographic location information for their customers and what technologies exist to do so. Further, the NPRM asks whether the FCC should redefine “interconnected VoIP” or whether it should create a new definition specifically for VoIP services subject to 911/E911 requirements.

In addition, the NPRM addresses a number of issues relating to Next Generation (“NG”) E911 including modifications to its location accuracy and Automated Location Identification (“ALI”) requirements to account for the deployment of NG911 systems; the expected impact of NG911 deployments on the existing wireless location accuracy and ALI requirements; the current state of NG911 deployments and what is in the planning stage; what technological or operational changes might service providers, applications developers, and device manufacturers implement that would complement NG911 Capabilities; and the specific considerations the FCC should heed as NG911 systems are deployed throughout the country.

The FCC also seeks comments on its authority to impose suggested requirements and technological impediments to complying with proposed obligations.   Comments will be due 60 days after publication in the Federal Register, expected within the next few weeks.  The FNPRM can be found at:  FNPRM.  Clients with questions about this Advisory should contact the attorney assigned to their accounts.

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