Revisiting E-911 Location Accuracy Requirements

Regulation Watch

Revisiting E-911 Location Accuracy Requirements

By William B. Wilhelm, Regulation Watch  |  August 10, 2016

Issues regarding the provisioning of E-911 services have been around for as long as VoIP. In the early years, VoIP service providers routed calls to the main number of the local emergency service provider. Following the issuance of Federal Communications Commission rules, however, VoIP providers were required to obtain the subscriber’s address, route calls dynamically to the local public safety answering point, and provide customer disclosures regarding the differences between traditional E-911 and the services provided by VoIP providers. In the years since these rules were issued, the FCC (News - Alert) has periodically asked if new technologies such as GPS or other systems could improve VoIP E-911 delivery.

Separately, the FCC and Congress have examined if E-911 delivery to multi-line telephone systems could be improved. Specifically, there have been instances where callers have tried to reach a PSAP but, because they were dialing from a MLTS, they were unable to reach an emergency operator. This typically occurs because in many MLTS configurations the caller is required to first dial a number before reaching an outside telephone number. If callers don’t know how the MLTS system is configured, they may be delayed or unable to contact E-911.

On May 13, 2016, Congresswoman Anna Eshoo (D-Calif.), ranking member of the House Communications and Technology Subcommittee and co-chair of the Congressional NextGen (News - Alert) 9-1-1 Caucus, introduced the Requesting Emergency Services and Providing Origination Notification Systems Everywhere (or, RESPONSE) Act, which would require the FCC to complete a proceeding requiring all MLTS to provide first responders with the precise location of a 911 caller. This could include room number, floor number, or other positioning information. According to the bill, the FCC would determine the degree of accuracy required.

Although Republicans currently control the House of Representatives, both Republican and Democratic members of Congress have expressed concern about E-911 capabilities in MLTS equipment. While the proposed legislation does not expressly target enterprise VoIP systems, any legislation and rules promulgated by the FCC could have a tremendous impact on both traditional MLTS equipment providers and enterprise VoIP providers insofar as each would likely need to redesign and reconfigure their systems to comply with the new requirements.

William B. Wilhelm (News - Alert) is a partner and Jeffrey R. Strenkowski is of counsel at the global law firm of Morgan Lewis & Bockius LLP (

Edited by Alicia Young