February 11, 2019

ACA Supports Proposed 911 ‘Dispatchable Location’ Rule for Multi-Line Telephone Systems

Rule Would Advance Public Safety While Preserving a Vibrant Marketplace for Enterprise Voice Services
For Immediate Release
Contact: Ted Hearn
(202) 713-0826
[email protected]

PITTSBURGH, February 11, 2019 – The American Cable Association supports the Federal Communications Commission’s proposal that multi-line telephone systems be configured to convey “dispatchable location” – granular location data, which may include a room or floor number – when a user places a 911 call. The rule will make it easier for first responders to locate office workers, hotel guests, students and other users of enterprise voice systems when they seek emergency assistance.

“ACA applauds the FCC for taking up Congress’ call to address this critical public safety issue. The FCC’s proposal that MLTS be configured to provide dispatchable location will improve access to emergency services in enterprise environments. At the same time, the rule as drafted preserves flexibility for customers to use MLTS that meet their needs, and it encourages further innovation in the marketplace,” ACA President and CEO Matthew M. Polka said.

ACA addressed the FCC’s proposed rule in reply comments filed on Feb. 8. In its filing, ACA described practices that member companies follow today that involve obtaining location information from MLTS customers and instructing them how to update it as necessary.

“These practices are similar to the process by which providers register 911 locations for residential VoIP customers, and they work well,” Polka said.

ACA asked the FCC to affirm that practices such as these are a means of “configuring” an MLTS to provide dispatchable location consistent with the proposed rule.

ACA recognized in its filing that some technologies may be available that provide dispatchable location by extracting location data from user devices, but these technologies may be overkill for smaller enterprises with modest-sized offices. ACA encouraged the FCC to clarify that providers are allowed to meet the proposed dispatchable location rule by different means, depending on the preferences of the customer.

Finally, ACA urged the FCC to ensure that its adoption of a dispatchable location rule for MLTS does not add complexity to providers’ regulatory obligations.

“Tracking compliance with the patchwork of state laws that govern MLTS 911 service is already burdensome for ACA members, and the burden would only increase if additional states were to adopt such requirements,” Polka said.

To that end, ACA encouraged the FCC to take steps to harmonize the 911 requirements that govern MLTS nationwide.

About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing more than 700 smaller and medium-sized, independent companies that provide broadband, phone and video services to nearly 8 million customers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA’s members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit: https://acaconnects.org/