My role at Avaya is to manage the product various offerings as they pertain to public safety solutions in the enterprise. Additionally, this includes public safety answer points. From a legislative and regulatory perspective, I work with various agencies. These include the Federal Communications Commission, as well as recognized standards development organizations, known as SDOs, like NENA, the National Emergency Number Association, EENA, the European Emergency Number Association, and APCO International, the Association of Public Safety Communications Officials.
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This particular work is probably the most important of what I do. It sets the stage for legislative guidance within the industry, ensuring that best practices and technically feasible solutions are specified and deployed.
In the United States, the Federal Communications Commission 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 FCC is an independent US government agency that is overseen by Congress and has been designated as the federal agency that is responsible for implementing and enforcing America’s communications law and regulations.
So how does Rulemaking work at the FCC?
Each time that Congress wishes to enact a particular piece of legislation that affects telecommunications in the United States, the FCC is tasked with developing rules to implement any specific law required to codify that legislation. To carry out its work, the Commission will then take specific regulatory steps to formulate and enforce these rules.
Fortunately for US Citizens, these steps offer consumers an opportunity to submit comments as well as reply comments to the FCC to be considered during the process.
The Commission’s decision-making process is well defined, albeit brings forth a whole new chapter in the ‘Alphabet Soup’ served as a daily special served at Chez’ Telecom. Here is a quick guide to understanding the “alphabets” of the FCC.
- Notice of Inquiry (NOI): 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.
- Notice of Proposed Rulemaking (NPRM): 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.
- Further Notice of Proposed Rulemaking (FNPRM): 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.
- Report and Order (R&O): 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.
Summaries of the R&O are published in the Federal Register. The Federal Register summary will tell you when a rule change will become effective. Not quite as entertaining as general legislation, and we have no “I’m just a Bill” theme 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.
On Tuesday, September 26, 2017, Chairman Ajit Pai has announced that the September Open Meeting will include an agenda item:
911 Access, Routing, and Location in Enterprise Communications Systems
The Commission will consider a Notice of Inquiry that seeks comment on the provision of 911 by enterprise communications systems that serve businesses, hotels, educational institutions, and government entities.
This will be heard under Public Safety and Homeland Security Docket 17-239 and is a direct result of the issues raised by Avaya on behalf of Hank Hunt, Kari’s Dad. Around the world, this is commonly known as Kari’s Law and has over 650,000 supporters on Change.Org after 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 because a ‘9’ was needed for an outside line. Versions of the Bill have passed the House and US Senate and are ready to be joined and sent to the Whitehouse.
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 additional important aspects, including affordable implementation, management and testing of solutions. For more information on the FCC Proceeding, you can watch the September Open Meeting LIVE on the Internet at http://fcc.gov/live, and the public is welcome to attend in person at the FCC, 445 12th Street SW, Washington, DC 20554.
For more information about Kari’s Law, you can visit the Kari Hunt Foundation at https://www.KariHuntFoundation.com where you can read the story, and contribute to their cause in educating the public so a child is never faced with the situation where 911 will not reach public safety on the phone.
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