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The legacy 911 emergency system in the United States was developed to facilitate audio communication with emergency personnel. In practice this meant that only voice communications were supported, and that users with hearing and/or speech disabilities were required to use TTY equipment or a TRS to enable communication with 911 calltakers. These methods pose a number of limitations, the primary ones being speed of communication and the fact that TTY is a legacy technology that is not as commonly in use by individuals with hearing and speech disabilities, especially over mobile networks. Many individuals with hearing and speech disabilities today communicate using more modern forms of technology than TTY such as text messaging, instant messaging and sign language via broadband video. Text-to-911 enables those reporting emergencies to address a short message service (SMS) or other form of text message to the 911 short code over the telephone network. The message is routed to the local 911 call center, otherwise known as a Public Safety Answering Point (PSAP) in the same manner as if a call had been placed to 911. Text-to-911 is currently only available in certain markets where PSAPs possess the capability to receive emergency text messages from the public. The FCC has published a list of markets where text-to-911 is available (MS Excel spreadsheet). The FCC advises consumers that in areas where PSAPs accept text-to-911, it serves as a complement to traditional 911 voice calls and not as a substitute for them. Those wishing to report an emergency should place a voice call to 911 whenever possible until greater coverage for text-to-911 exists. Calls placed to 911 provide additional information for locating the caller that is not currently provided via text including enhanced location information. The FCC recently took steps to make text-to-911 more widely available throughout the United States. On August 8, 2014, the FCC adopted order FCC 14-118 implementing rules for text-to-911 technologies. These rules are also published in 47 CFR 20.18 (q). The Commission also issued a third Further Notice of Proposed Rulemaking seeking comment on technical issues related to the provision of enhanced location information, support for text-to-911 while roaming and capabilities of future texting services.

Requirements for Text Messaging Providers

The FCC defines covered text providers to include “all CMRS providers, as well as all providers of interconnected text messaging services that enable consumers to send text messages to and receive text messages from all or substantially all text-capable U.S. telephone numbers, including through the use of applications downloaded or otherwise installed on mobile phones.” A Commercial Mobile Radio Service, or CMRS, is a carrier that provides wireless mobile calls over the public switch telephone network. Services that allow texts to be sent to U.S. phone numbers using Internet Protocol that are then relayed to a CMRS are known as interconnected text messaging services. Interconnected text services include E-mail gateways, websites and mobile apps such as those provided by your telephone carrier that can send texts to or receive texts from a U.S. telephone number. Products, apps and services that cannot send texts to U.S. phone numbers including Whatsapp, Google Hangouts and social media sites are not considered covered text providers and therefore are not subject to text-to-911 requirements. All U.S. wireless carriers and text messaging providers that are not already supporting text-to-911 must be capable of doing so and must respond to PSAP requests to deliver text-to-911 by June 30, 2015 or six months from the date of a PSAP request, whichever is later. The four major wireless carriers (AT&T, Sprint, T-mobile and Verizon) have already begun voluntarily providing text-to-911 in areas served by their networks where PSAPs are prepared to receive texts. Where the local PSAP does not accept text-to-911 or where the covered text provider does not support text-to-911, text messaging providers are required to respond to texts sent to 911 with an automatic “bounce-back” message as of September 30, 2013. The bounce-back message must advise the consumer that text-to-911 is not available and that the consumer should contact emergency services by another means such as placing a voice call or using a Telecommunications Relay Service if the consumer has a hearing or speech disability. The bounce-back requirement is intended to minimize the risk of a consumer mistakenly believing that emergency personnel received a text-to-911 in areas where the capability does not yet exist. Carriers are not required to provide automatic bounce-back messages for situations that are beyond the control of the carrier and for devices where the consumer does not have texting service with the carrier such as non-initialized handsets. 911 call centers are not obligated by the FCC to accept text-to-911 but are encouraged to do so. The FCC has published information on best practices from public safety organizations and PSAPs that have already implemented text-to-911.