NARUC Telecom Committee Advances E911 Resolution

BALTIMORE – The Telecommunications Committee of the National Association of Regulatory Utility Commissioners (NARUC) today unanimously passed a resolution addressing enhanced 911 (E911) access and enterprise communications systems during its 2017 annual meeting and education conference being held here this week.

Two other proposed resolutions – dealing with the federal Lifeline fund – were withdrawn and were not considered by the committee today.

The passed resolution aims to ensure that direct dialing for 911 can move forward. The proposed resolution supports federal and state actions to require enterprise communications systems (ECS) manufacturers, installers, and operators “to design and configure ECS to allow direct dialing of 911, route 911 calls to the proper PSAP regardless of the particular location of the extension used to call 911, provide the PSAP with location information accurate enough for first responders to locate the caller, and to support on-site notification.”

The resolution (TC-1), which is sponsored by Commissioner Wendy Moser of the Colorado Public Utilities Commission, states that “consistency, uniformity, and ubiquity of service is highly desirable in the dialing of 911” and that “voluntary efforts among ECS manufacturers, installers, and operators are laudable but may leave many 911 callers vulnerable.”

According to the draft resolution, any federal action should be mandatory for all ECS manufacturers, installers, and operators, and federal requirements regarding ECS “must not be written or implemented in such a way that it preempts states from imposing additional requirements as they see fit, presuming that such additional requirements do not contradict or conflict with federal requirements.”

During today’s telecom committee meeting, South Carolina Public Service Commissioner Elliott Elam questioned whether the language of the resolution would allow states to impose additional requirements to enable direct dialing to 911.

In response, Commissioner Moser said that the resolution allowed “for states to adjust for their specific needs for the state.”

“This resolution helps us support Congress’ efforts and specify that states can provide their own [requirements] … to address specific local implementation,” Commissioner Moser explained.

Meanwhile, two other resolutions that were slated to be considered by the telecommunications committee were withdrawn by their sponsors on Nov. 10.  One of the draft resolutions, which was sponsored by Commissioner Crystal Rhoades, a member of the Nebraska Public Service Commission, would have urged the FCC to continue to allow non-facilities based carriers to receive Lifeline funds “because they have been crucial in ensuring that low-income households are connected to telecommunication services.”

The Lifeline draft resolution was largely in response to a draft notice of proposed rulemaking released on Oct. 26 by the FCC for a vote at this Thursday’s meeting. Among other things, the FCC is seeking comment on discontinuing Lifeline support for non-facilities-based services. But according to the draft resolution, non-facilities-based Lifeline providers make up a large portion of the Lifeline market, while “facilities-based providers are only 25% of the market and in each year their Lifeline customers have decreased.”

Another proposed resolution was withdrawn last week by sponsor Commissioner Betty Ann Kane, chair of the District of Columbia Public Service Commission.  That proposal sought to commend the FCC for its tentative decision to: “(1) eliminate the stand-alone Lifeline Broadband Provider designation, (2) reverse its preemption of state regulatory authority to designate eligible telecommunications carriers, and (3) adjust its plans for the Lifeline broadband service program to include a requirement that Lifeline broadband service providers must also provide voice services, which are vital for the public to access E911 and other emergency, health, and public safety services and also urges the FCC to eliminate the forbearance that allows non-facilities-based carriers to receive Lifeline funds.”

At the same time, the draft resolution found that “the FCC’s grant of forbearance from the Telecommunications Act of 1996 section 214(e) requirement for participants in the federal Lifeline program to use their own facilities to provide service removes any incentive for companies to invest in and to build voice-only or voice and broadband-capable facilities and, thereby, subverts the Act’s principle of promoting access to advanced telecommunications services as set forth in section 254(b).”

NARUC’s board of directors meets tomorrow to vote on the E911 resolution approved today. -Carrie DeLeon,

Courtesy TRDaily