A Kari’s Law Update: FCC Launches Inquiry on 9-1-1 Capabilities

A Kari’s Law Update: FCC Launches Inquiry on 9-1-1 Capabilities

At Avaya, we continue to shine a light on the progress of making Kari’s Law a global reality. Just this week, the U.S. FCC (Federal Communications Commission) considered a Notice of Inquiry (NOI) that seeks comment on the provision of 9-1-1 by enterprise communications systems that serve businesses, hotels, educational institutions, and government entities.

This NOI was heard under Public Safety and Homeland Security Docket 17-239 and addresses issues raised by Avaya on behalf of Hank Hunt. Hunt created the petition after the tragic death of his 31-year-old daughter Kari Hunt, on December 1, 2013, in Marshall, Texas. Kari’s 9-year old daughter knew to dial 9-1-1 from the hotel room phone but was unable to connect because a 9 was needed first to reach an outside line. Versions of the Bill have passed the House and U.S. Senate and are ready to be joined and sent to the White House. Around the world, there are over 600,000 supporters of Kari’s Law on Change.org.

In addition to the important aspects defined by Kari’s Law, Direct Access, On Site Notification, and Routing without Interception, this new FCC NOI covers affordable implementation, and management and testing of solutions.

Summaries of the Report & Order (R&O) are published in the Federal Register. The Federal Register summary will tell you when a rule change will become effective. It is not quite as entertaining as the general legislative process—there’s no fun “I’m just a Bill” song—but the process is efficient, and most importantly gets public and commercial input, as well as the contribution of specific experts to the legislation at the very start. During the September Open Meeting, Chairman Ajit Pai said, “Of course, we are not laboring alone in these fields. Each House of Congress has unanimously passed a version of the Kari’s Law Act of 2017. This legislation would help ensure direct access to 911. I hope Congress can quickly resolve these bills and send final text to the President.”

To keep up on the FCC proceeding, you can watch a replay of the Open Meeting. To learn more about Kari’s Law, visit the Kari Hunt Foundation to read her story, and learn what can be done to ensure a child is never again unable to dial public safety.

Understanding the Process (and the Government’s Alphabet Soup)

I manage Avaya’s public safety solutions portfolio and give guidance about public safety answer points. I also dedicate time to furthering public safety standards across America and the world—I participate on Federal Advisory Committees assisting the FCC and several recognized standards development organizations.

But, most important are the global standards that assist in advancing the vast telecommunications infrastructure used to deliver connectivity to the masses. These guidelines and best practices establish a baseline and set the stage for legislative guidance within the industry.

In the United States, the FCC regulates interstate and international communications that take place by radio, television, wire, satellite, and cable in all 50 states, the District of Columbia, and US territories. The Commission, overseen by Congress, is the designated federal agency that is responsible for implementing and enforcing America’s communications law and regulations.

To make that a bit clearer, each time that Congress wishes to pass a piece of legislation affecting telecommunications, the FCC is tasked with developing rules to implement any specific law needed to codify the legislation. To carry out its work, the FCC takes specific regulatory steps to formulate and enforce these rules. Fortunately, none of this takes place in a vacuum, and consumers are afforded an opportunity to submit comments for consideration by the FCC during deliberations of a docket item. The entire decision-making process is well defined, although it can reveal a whole new ingredient in the alphabet soup served as a daily special at Chez’ Telecom.

A Quick Guide to FCC Rulemaking

  • NOI (Notice of Inquiry): The Commission releases an NOI to gather information about a broad subject or as a means of generating ideas on a particular issue. NOIs are initiated either by the Commission or an outside request.
  • NPRM (Notice of Proposed Rulemaking): After reviewing comments from the public, the FCC may issue a Notice of Proposed Rulemaking. An NPRM contains proposed changes to the Commission’s rules and seeks public comment on these proposals.
  • FNPRM (Further Notice of Proposed Rulemaking): After reviewing your comments and the comments of others to the NPRM, the FCC may also choose to issue an FNPRM regarding specific issues raised in comments. The FNPRM provides an opportunity for you to comment further on a related or specific proposal.
  • R&O (Report and Order): After considering comments to a Notice of Proposed Rule Making (or Further Notice of Proposed Rule Making), the FCC will issue a Report and Order. The R&O may develop new regulations, amend existing rules or make a decision not to do so.
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