In response to the evolving landscape of wireless services and concerns raised by public safety advocates and the public, the Federal Communications Commission (FCC) has unveiled a new set of rules designed to improve the accuracy of 911 call routing. The Commission seeks to address the issue of “misrouting-“ where calls made near jurisdiction borders are often redirected to the nearest tower, potentially located in a different jurisdiction, and not the jurisdiction of the 911 call center that serves the caller’s location. The new rules apply to all wireless telephone service providers, including mobile virtual network operators, mobile virtual network enablers, and, potentially, even mobile virtual network aggregators, to the extent these providers have control over the network infrastructure used to route 911 calls.

The key directive involves compelling wireless carriers to integrate location-based routing technology for wireless 911 voice calls and Real-Time Text (RTT) communications. This mandate extends across their Internet Protocol (IP)-based networks, encompassing 4G LTE, 5G, and subsequent IP generations. Wireless carriers are obligated to employ location-based routing when the caller’s location information is verifiable within 165 meters at a confidence level of at least 90%. In cases where these conditions are not met, alternative routing methods, including device-based or tower-based location information, are deemed acceptable.

Timeline for Implementation: The FCC has outlined a comprehensive timeline, giving nationwide wireless service providers six months and non-nationwide providers twenty-four months after the rules’ publication in the Federal Register to implement location-based routing for wireless 911 voice calls. Additionally, all wireless service providers are granted a 24-month window to implement location-based routing for RTT communications to 911. Within 60 days of the compliance deadlines, wireless service providers are required to certify and furnish evidence of compliance. This includes a one-time live call data report detailing routing methodologies, along with a certification of the privacy measures in place for location information.

Future Considerations: The FCC has communicated its decision to defer consideration of proposals related to Short Message Service (SMS) texts to 911 and the IP-formatted delivery of wireless 911 voice calls, texts, and associated routing information. These matters will be subject to examination in the Commission’s ongoing Next Generation 911 (NG911) Transition docket (PS Docket No. 21-479—Facilitating Implementation of Next Generation 911 Services).

CommLaw Group Can Help!

For wireless service providers navigating the compliance process or any service provider looking to comment on these further issues and proceedings before the Commission, Marashlian & Donahue’s telecom attorneys stand ready to provide guidance. Our experienced wireless telecom attorneys assist companies with regulatory, litigation, intellectual property, and transactional issues in the wireless market. We help companies acquire spectrum and related assets, navigate mergers and acquisitions, deploy nationwide networks, negotiate facilities access and siting agreements, navigate the complex regulatory and tax environment, respond to day-to-day operational issues, launch new products and services, develop business strategies, and prosecute and defend against lawsuits and audits involving wireless communication law.

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Jonathan S. Marashlian – Tel: 703-714-1313 / E-mail: jsm@CommLawGroup.com
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com