Notice & Comment

Text-to-911 Possible by End of 2014?, by Elisabeth Ulmer

The Federal Communications Commission (FCC) seeks comment on a proposed rule relating to the timing and different aspects of implementing text-to-911.  Given the FCC’s core mission of “promoting the safety of life and property of the American public through the use of wire and radio communications,” it has a vested interest in ensuring that the technologies with which Americans are most comfortable are the ones available to them in emergencies.

While subscribers’ monthly voice usage between 2009 and 2011 decreased, U.S. mobile data traffic between 2010 and 2011 increased by 270 percent.  Moreover, 81 percent of adult American cell phone owners use texting, and 63 percent of teens text daily.  All of these statistics reflect a “continued evolution from a predominantly voice-driven medium of communication to one based more on data transmissions.”

Thus, according to the FCC, as the use of texting applications increases, the 911 system must evolve to accommodate the use of this technology.  Text-to-911 will “vastly enhance the [911] system’s accessibility for over 40 million Americans with hearing or speech disabilities” and will “provide a vital and lifesaving alternative to the public in situations where 911 voice service is unavailable or placing a voice call could endanger the caller.”  Furthermore, implementing text-to-911 will aid in the transition of the current 911 system to a Next Generation 911 system.  The NG911 system is expected to enable Public Safety Answering Points (PSAPs) to receive not only texts but also photos, videos, and data.

In its proposed rule, the FCC first invites comment on its deadline of December 31, 2014, by which all text providers must provide text-to-911 capability.  AT&T, Sprint Nextel, T-Mobile, and Verizon – the four largest wireless carriers – have committed to making text-to-911 available by May 15, 2014 (Carrier-NENA-APCO Agreement).  They initially intend to use SMS-based text.  The FCC is looking into text-to-911 for other IP-based text applications as well.

Second, the FCC seeks further comment on the following issues, as discussed in the proposed rule:

  1. Developing the capability to provide Phase II-comparable location information in conjunction with emergency texts;
  2. Delivering text-to-911 over non-cellular data channels; and
  3. Supporting text-to-911 for consumers while roaming on Commercial Mobile Radio Service (CMRS) networks;

Comments were due on April 4, 2014, but interested parties are invited to submit reply comments by May 5, 2014, by any of the following methods:

  • Federal Communications Commission’s Web site:
  • Mail: Federal Communications Commission, 445 12th Street SW., Washington, DC 20554

All comments must include PS Docket No. 10-255, and PS Docket No. 11-153.

This post was originally published on the legacy ABA Section of Administrative Law and Regulatory Practice Notice and Comment blog, which merged with the Yale Journal on Regulation Notice and Comment blog in 2015.

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