The FCC's wireless Enhanced 911 (E911) rules seek to improve the effectiveness and reliability of wireless 911 services by providing 911 dispatchers with additional information on wireless 911 calls. The FCC's wireless E911 rules apply to all wireless licensees, broadband Personal Communications Service (PCS) licensees, and certain Specialized Mobile Radio (SMR) licensees.
The FCC has divided its wireless E911 program into two parts - Phase I and Phase II. Under Phase I, the FCC requires carriers, within six months of a valid request by a local Public Safety Answering Point (PSAP), to provide the PSAP with the telephone number of the originator of a wireless 911 call and the location of the cell site or base station transmitting the call.
Under Phase II, the FCC requires wireless carriers, within six months of a valid request by a PSAP, to begin providing information that is more precise to PSAPs, specifically, the latitude and longitude of the caller. This information must meet FCC accuracy standards, generally to within 50 to 300 meters, depending on the type of technology used. The deployment of E911 requires the development of new technologies and upgrades to local 911 PSAPs, as well as coordination among public safety agencies, wireless carriers, technology vendors, equipment manufacturers, and local wireline carriers.
The FCC maintains a Master PSAP Registry with information on PSAP names and locations.
Waivers and Reports
In its orders, the FCC has addressed requests for waivers of the Phase II rules, granting some subject to certain conditions and reporting requirements. For information on the Phase II deployment by large and mid-size carriers, see the most recent quarterly report.
E911 Enforcement Actions
The FCC has adopted rules requiring the deployment of Enhanced 911 (E911) by wireless carriers. There are two primary methods to notify the FCC of violations by carriers of E911 Phase 1 or Phase 2 Implementation Requirements.
One method is to informally notify the FCC or the Public Safety and Homeland Security Bureau about violations. The second method is to file a formal complaint, pursuant to Section 208 of the Communications Act, with the FCC's Enforcement Bureau.
Persons who do not wish to file a formal complaint, but who wish to inform PSHSB of evidence of a violation of the E911 Implementation Requirements may contact the PSHSB Policy Division. Contact Dave Siehl at (202) 418-1313 to discuss such matters.
When contacting the staff, please provide as much factual information and substantiation concerning the alleged violation as possible. Documentary materials (copies of letters, e-mails, etc.) or testimonial evidence in the form of sworn affidavits is particularly helpful. It is also useful to identify particular provisions of the statute or the rules that you believe may have been violated.
Please keep in mind that this process does not require any ultimate decision by the FCC.
Formal Section 208 Complaints
Persons interested in filing a formal Section 208 complaint alleging violation of an E911 rule should take the following steps:
Call the FCC's Enforcement Bureau
Persons interested in filing a formal Section 208 complaint should contact the FCC Enforcement Bureau's Market Disputes Resolution Division at (202) 418-7330 before filing.
There are many advantages to contacting the staff before filing a complaint.
The staff has stepped up its efforts to mediate disputes between industry participants before a complaint is filed. In many cases, the staff can discuss the dispute together with the potential complainant and the potential defendant and help facilitate a private settlement acceptable to both even before the filing of a complaint.
Even if mediation does not resolve the dispute, talking to the staff first can help answer any questions concerning procedures, emphasize certain requirements that must be satisfied, and help focus the key issues in any complaint that is filed.
Read the Rules
Please feel free to contact the staff to discuss these procedures and ask any questions.
The rules governing formal complaints are found in Code of Federal Regulations at 47 C.F.R. Sections 1.720-1.736 (1999).
For additional information, please see the FCC's Report and Order that adopted these rules, which is published in the FCC Record at 12 FCC Rcd 22497 (1997).
A filing fee is required for all formal complaints. See 47 C.F. R. section 1.1105 (1999).