The FCC Seeks Comment on 911 Access in Enterprise Communications Systems

Last week, the FCC released a Notice of Inquiry (NOI) seeking comment on a variety of issues related to 911 capabilities and Enterprise Communications Systems (ECS). While you may not be familiar with the term "Enterprise Communications Systems," you are certainly familiar with the concept. As the FCC's NOI explains, ECS are telecommunications systems that support multiple users at individual telephone stations across a single enterprise, such as an office building, a campus, a hotel, etc. If you're like me, you use an ECS every day by picking up your office phone or by ordering room service from your hotel room, or maybe you find a colleague's use of your office's ECS absolutely unbearable.

These ECS have been widely deployed for several years, although they have evolved from circuit-switched time-division multiplexing technology to Internet Protocol (IP)-based platforms, utilizing VoIP technology for internal communications and outbound calls-including calls to 911.

Regardless of technology, consumers expect to have access to usual 911 capabilities in their ECS in case of an emergency: they expect to dial 911 and immediately get routed to the appropriate Public Safety Answering Point, which in turn will retain information about the caller's location and callback phone number to ensure prompt dispatch.

However, according to the FCC, 911 capabilities on ECS appear to lag behind those of traditional wireline, wireless, and VoIP systems. Now the FCC wants to know how serious the ECS/911 issue really is and what steps should be taken going forward.

Historically, the FCC has chosen to take a backseat in the provision of 911 by ECS, deciding back in 2003 that the issue was best left to state and local authorities. Last week's NOI revisits the issue, noting that 24 states had enacted, or had pending, legislation implementing E911 standards for ECS. These state statutes vary in their substance, but direct 911 access and location accuracy requirements are common themes.

Now, the FCC is surveying the ECS landscape again, seeking comment on a number of broader issues, including the reasons the 911 capabilities of ECS have appeared to lag behind other systems, consumers' expectations in accessing 911 from ECS, and potential solutions to these issues. Many of the questions posed by the FCC are directed toward ECS operators and vendors. To name a few examples, the Commission seeks input on the current accepted industry standards for ECS E911 delivery, the typical commercial arrangements for the provision of ECS and their impact on 911 capabilities, and the impact of the IP-based NG911 transition on ECS. (There are numerous other issues up for comment in the NOI - too many to list here. Those who are interested, and especially those who might want to provide feedback, can view the full NOI here.)

While comments in this proceeding will provide the FCC with greater insight, the Commission is not at this point committing to regulatory action as a solution. Plus, the NOI contemplates whether updated industry standards and service/implementation best-practices could be potential solutions.

The deadline for submitting comments is November 15, 2017, with reply comments due December 15, 2017. Comments should be submitted under Docket No. 17-239.