*Pages 1--1 from  Microsoft Word - 33396*
 SEPARATE  STATEMENT  OF  COMMISSIONER  JONATHAN  S.  ADELSTEIN 
 Re:  In  re  Revision  of  the  Commission’s  Rules  to  Ensure  Compatibility  with  Enhanced  911  Emergency  Calling  Systems;  CC  Docket  No.  94-  102 
 There  is  no  higher  calling  or  higher  priority  for  us  at  the  Commission  than  improving  911  and  enhanced  911  (E911)  emergency  response  services.  Every  day,  we  confront  issues  that  have 
 millions  of  dollars  at  stake;  but  nothing  we  do  is  more  important  than  911  and  E911  services.  Unlike  a  lot  of  issues  we  handle  that  get  so  much  attention,  this  literally  is  a  matter  of  life  or 
 death. 
 The  Commission  always  can  do  more  to  support  the  rollout  of  E911.  In  my  view,  we  can  never  do  enough.  And  we  have  made  great  strides  during  the  last  year:  by  continuing  to  provide  solid 
 regulatory  guidance;  by  improving  our  level  of  collaboration  with  legislators  on  Capitol  Hill,  including  the  leadership  of  the  Congressional  E911  Caucus;  and  through  two  very  well-organized 
 E911  Coordination  Initiatives,  which  were  held  right  here  in  the  Commission  meeting  room. 


 We  continue  these  outstanding  efforts  today  by  providing  a  comprehensive  review  of  our  rules  to  determine  the  applicability  of  E911  requirements  to  a  number  of  different  technologies  and 
 services.  I  believe  that  the  item  strikes  the  right  balance  in  imposing  obligations  on  these  services,  in  that  it  continues  our  work  to  make  emergency  response  better  and  faster  in  America 
 through  the  use  of  both  improved  911  and  E911  services  but  also  recognizes  the  unique  technical  and  service  characteristics  of  the  different  offerings. 


 That  is  why  I  am  particularly  pleased  that  we  adopt  a  measured  approach  to  those  telematics  providers  providing  call-  center  based  services,  which  are  not  also  available  with  commercial 
 mobile  wireless  service.  These  companies  are  offering  their  subscribers  a  service  with  very  real  public  benefits.  There  is  no  reason  to  impose  regulation  on  these  services,  given  their  success 
 and  collaboration  with  the  public  safety  community  to  date. 
 I  also  am  pleased  with  our  decision  to  require  MSS  carriers  to  establish  call  centers  for  the  purpose  of  answering  911  emergency  calls.  Rightly,  we  also  put  these  same  carriers  on  notice 
 that  we  ultimately  intend  to  require  them  to  comply  with  our  E911  requirements,  though  the  record,  at  this  time,  does  not  support  immediate  compliance  with  those  rules. 


 Finally,  I  do  have  a  lingering  concern  that  our  actions  today  with  regard  to  Multi-  Line  Telephone  Systems  (MLTS),  such  as  private  branch  exchanges  (PBXs),  just  are  not  enough.  Consequently, 
 I  regard  our  action  today  as  simply  a  first  step,  and  I  am  very  pleased  with  our  decision  to  continue  our  review  in  this  important  area  through  a  Further  Notice.  It  cannot  be  emphasized 
 enough  how  critical  it  is  that  state  and  local  governments  adopt  rules  requiring  MLTS  E911  implementation,  such  as  the  model  legislation  suggested  by  APCO  and  NENA.  I  am  fully 
 prepared  to  intervene  should  we  not  see  the  timely  adoption  of  these  important  requirements. 
1