The FCC intends to launch a new proceeding to examine issues related to 911 capabilities of enterprise-based 911 services provided over multi-line telephone systems (MLTS) and IP-based systems (collectively referred to as “Enterprise Communications Systems” or “ECS”).

Last week, the FCC released a draft Notice of Inquiry (“NOI”) examining the 911 capabilities of MLTS and IP-based systems such as cloud-based services that support voice communications.  In the NOI, the FCC seeks to “identify the reasons that the 911 capabilities of ECS appear to have lagged behind those of wireless, wireline and interconnected VoIP . . . [and] potential ways to ensure that ECS keep pace with technological developments and meet consumer expectations with respect to 911 access, routing, and location information.”

The NOI asks detailed questions regarding the ECS industry, including questions about vendors, equipment, services, business arrangements and the E911 and Next Generation 911 capabilities of ECS.  The FCC asks commenters to discuss the costs and benefits of “provisioning ECS to support 911 access, routing, and location information.”  Finally, the FCC seeks comment on potential ways to improve ECS support of 911 access, routing and location, including the implementation of industry standards or possible regulatory action.

The FCC will vote on the NOI at its next open meeting, on September 26, 2017.  The NOI does not propose any new obligations or rules but the FCC may do so as this proceeding progresses.  The NOI also indicates that the FCC is taking an enhanced interest in enterprise communications systems’ 911 service obligations.  We will continue to monitor this proceeding.