Wireless RERC Comments on the Accessibility of Next Generation 911 Deployment and Application

April 9, 2013 — The Wireless RERC submitted reply comments to the Further Notice of Proposed Rulemaking: “Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications” [PS Docket No. 11-153] and “Framework for Next Generation 911 Deployment” [PS Docket No. 10-255]. The Wireless RERC expressed their continued support for obligatory rules concerning the deployment of text-to-911. The Wireless RERC recommended that pre-installed messaging applications be included in any text-to-911 mandates, as it could help “pave the way for transitioning to an all-IP environment.” Regarding the timetable for text-to-911 deployment, the Wireless RERC agreed with the National Emergency Number Association’s (NENA’s) recommendation that the FCC make May 15, 2015 the deadline for small and rural carriers to meet the text-to-911 requirements. The Wireless RERC supported AT&T’s recommendation to officially require 911 to be used as the short-code and those devices that “cannot send a three digit short code should be phased out of the market.”  Finally, the Wireless RERC concurred with NENA’s recommendation that a five year timeframe be established to further evaluate the implications of sun-setting mobile TTY requirements.