Waivers Necessary if Local 911 PSAPs Can’t Receive Enhanced Location Info

Service providers are working to comply with the FCC’s adopted rules under Section 506 of RAY BAUM’S Act to convey “dispatchable location” information with 911 calls, but not all public safety answering points (PSAPs) can receive this information as the rules require. Discussions with FCC staff determined that the requirements will not be met even if carriers provide dispatchable location information to a PSAP that is not capable of receiving such information. In instances where a local PSAP is not capable of receiving the dispatchable location information, the FCC has said that service providers may need to file a waiver with the Commission.

You will need to check with all the PSAPs that serve your customers and if any of them cannot receive the dispatchable location information or other location information required, JSI encourages you to file a waiver with the FCC.

For full compliance, the PSAP must be able to receive the dispatchable location information conveyed with 911 calls so that first responders can more quickly locate the caller. Dispatchable location information includes the verified street address of the caller and additional information, such as room or floor number, necessary to adequately locate the caller. This additional information is required where the address alone is not enough to locate the 911 caller, for example when calls are made from multistory businesses or large campuses.

These rules apply to the following 911-capable services: fixed telephony, interconnected VoIP services, Internet-based TRS, and mobile text service. As a reminder, the implementation deadlines and corresponding 911 information delivery requirements are as follows:

• Fixed Telephony Compliance Date
  • January 6, 2021 – Providers of fixed telephony service must provide automated dispatchable location information with 911 calls.
• Mobile Text Compliance Date
  • January 6, 2022 – Covered text providers must provide automated dispatchable location information with all 911 text messages routed to a PSAP if technically feasible; otherwise they must either provide (i) end-user manual provision of location information or (ii) enhanced location information that is coordinate-based and consists of the best available location that can be obtained.
• Interconnected VoIP Compliance Date
  • January 6, 2021 – Providers of fixed interconnected VoIP services must provide automated dispatchable location information with each 911 call.
  • January 6, 2022 – Providers of non-fixed interconnected VoIP services and providers of all outbound interconnected VoIP services must provide automated dispatchable location information with each 911 call if technically feasible. Otherwise, they must provide either (i) registered location information, which includes the location the service provider obtained from the customer prior to the initiation of service at which the service is first to be used; or (ii) alternative location information that may be coordinate-based and must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings. Finally, as a last resort, providers may route the caller to the national emergency call center, so long as the provider has made a good faith effort to obtain location data from all available alternative location sources.
• TRS Compliance Dates
  • January 6, 2021 – Providers of fixed VRS, IP Relay and IP CTS must provide automated dispatchable location information with each 911 call.
  • January 6, 2022 – Providers of non-fixed VRS, IP Relay and IP CTS must provide automated dispatchable location information with each 911 call if technically feasible. Otherwise, they must provide either (i) registered location information, including the location that the service provider obtained from the customer, prior to the initiation of service, or (ii) alternative location information that may be coordinate-based and must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings. Finally, as a last resort, providers may route the caller to the national emergency call center, so long as the provider has made a good faith effort to obtain location data from all available alternative location sources.

When and where possible JSI will file group waivers for providers that have similar circumstances as a means to minimize individual companies’ costs.

Please contact Amanda Molina at 321-985-5709 or Chresanthe Staurulakis at 301-459-7590 if you would like more information, would like to participate in a group waiver filing, or would like JSI to file a waiver specific to your company.