647C!Congre~~ of tbe mlniteb ~tate~ 
masbington. J\1[ 20510 
The Honorable Ajit Pai, Chairman 
Federal Communications Commission 
455 12th St. , SW 
Washington, D.C. 20554 
Dear Chairman Pai, 
July 28, 201 7 
Received & ln~nected 
AUG 0 3 2017 
FCC Mail Room 
As Members who are actively engaged on 911 issues, we write regarding steps the Federal Communications 
Commission (FCC) could take to make 911 services available to more Americans in times of emergency. 
Today many Americans use over-the-top (OTT) technologies to make voice calls over data networks. 
WhatsApp has reported that its users make more than 100 million voice calls per day and Skype reports that its 
users make more than three billion minutes of voice calls per day. Consumers who rely on these technologies 
may not be aware that they do not support 911 calls. 
New technologies could fill this gap. For example, we understand that a company called Onvoy has developed a 
technology that would allow OTT voice calls to be routed into the 911 system when cellular connections are not 
available. The technology requires access to certain number resources to work seamlessly for both consumers 
and public safety access points (PSAPs ). Current FCC rules require a company to have cell towers in each local 
jurisdiction in order to access the necessary number resources. This rule was put in place before technologies 
like Onvoy's were viable, and in this case we are concerned could be needlessly standing in the way of a life­
saving technology. Onvoy has applied for a waiver from the FCC, and the docket shows broad support from the 
public safety community, including the Association of Public-Safety Communications Officials (APCO) and 
the [' ,:-ational Emergency Number Association (NENA). 
While access to the 911 system for OTT voice callers who do not have cellular service available would 
undoubtedly increase public safety, it is important to note that the current technology is not a full replacement 
for traditional 911 calls. Although the OTT technology can provide some location information to the PSAP, it is 
not as accurate as the location provided by cellular or landline phones. Additionally, PSAPs will not have the 
ability to call back an OTT caller in the event that the call is prematurely terminated. While consumers should 
be aware of these limitations, they do not outweigh the potential benefit of making 911 access available in 
situations where it is currently unavailable. 
We appreciate your consideration of our views on this important matter. 
Sincerely,