As we noted in September, the Federal Communications Commission proposed new regulations to govern accessibility to the 911 system through Enterprise Communications Systems (ECS), typically associated with communications services offered to enterprise, multi-user business environments. The first step in this process was a Notice of Inquiry (NOI) asking wide ranging questions about the current 911 capabilities of ECS systems, end-user expectations for calling 911, and whether the FCC should fill any gaps in ECS 911 access with new rules.

The comment and reply comment periods for this NOI are now closed, but ECS providers, users, equipment manufacturers, or other entities with an interest in ECS services still have an opportunity to impact the FCC’s decisions. An interested party could still submit an Ex Parte communications to the Commission, and if the Commission does move forward with new rules, it will first have to issue a Notice of Proposed Rulemaking (NPRM), which would require a further round of comments and reply comments.

As we noted in September, there is potential for this proceeding to impact every provider that offers enterprise level communications services, including UCaaS, Hosted PBX, and other VoIP service providers. As a result, we have been monitoring the progress of the proceeding closely.

If your business has any questions about this proceeding, would like to participate and have your voice heard, or simply wish to receive a detailed update on how the industry, public, and state/local government entities are lobbying the FCC (i.e., what does the weight of the comments suggest about the potential new regulations?), please contact Seth Williams at slw@commlawgroup.com or Michael Donahue at mpd@commlawgroup.com.