STATEMENT OF
COMMISSIONER MICHAEL J. COPPS
Re: Amending the Definition of Interconnected VoIP Service in Section 9.3 of the 
Commission’s Rules, Notice of Proposed Rulemaking, GN Docket No. 11-117; Wireless 
E911 Location Accuracy Requirements, Third Report and Order, PS Docket No. 07-114; 
E911 Requirements for IP-Enabled Service Providers, Second Further Notice of 
Proposed Rulemaking, WC Docket No. 05-196
I was pleased to receive this item. E911 is a matter of ongoing and high priority attention 
for the Commission and today’s proceeding is another step in the right direction. I don’t need to 
dwell on the importance of E911 saving lives, protecting property, and preventing and 
discouraging crime. Location accuracy has gotten measurably better and certainly we have seen 
welcome increases in GPS-capable handsets and in network upgrades. That’s good news for 
citizens. But even as we applaud that, we know our job is far from being done and we are still 
pushed by our public interest duty to move things along with all deliberate speed. This is another 
step in the right direction.
In light of the dynamic changes in technology, I support maintaining separate standards 
for both network and handset based location systems. I am particularly pleased that we are now 
requiring carriers to test and report to us, as well as to state 911 centers and PSAPs, whether or 
not carriers are hitting the mark for outdoor calls. This kind of real-world data can only make our 
diagnosis and our decisions better. And it will provide our Communications Security, Reliability, 
and Interoperability Council (CSRIC) important information that it needs as it considers its next 
steps and recommendations. I am hopeful CSRIC will provide the guidance we need toward the 
development of effective standards as a top priority matter. As I have stated many times before, 
vitally-necessary E911 infrastructure will best be built by the private and public sectors 
discussing together, planning together, working together and coming up with solutions together.
It’s not something either sector can accomplish alone. 
I also want to reemphasize the priority of keeping clear focus on the matter of indoor 
testing. As more consumers cut the cord, their cell phones become the one and often only 911-
capable device in their homes. Today we ask the right questions about indoor testing. I welcome 
that because it is just absolutely critical that we do not let this issue stall. The record clearly 
shows that my requests for reports and studies on in-building coverage go back many years in the 
E911 Location Accuracy docket.
I am also encouraged that we propose to expand E911 requirements to a greater set of 
VoIP users. It makes complete sense to me that VoIP users who can make calls to anyone would 
expect to be able to reach 911 in an emergency. I look forward to what I hope is a thorough 
record that tells us what consumers of this and other one-way services expect. So I appreciate the 
Notice’s questions about our authority to extend E911 requirements to VoIP services for which 
callers can only call out.
But it should not stop there. To me public safety communication means two-way
communications. Two-way communications become really important if an emergency call gets 
disconnected, goes dead for any reason, or if other emergency responders need to contact the 
caller. So I am pleased that we will also inform ourselves about what consumers need in the way 
of receiving calls back from emergency call centers.  I understand that the Net 911 Improvement 
Act bolsters our legal authority in this area. Nevertheless, as I have said before, I believe the 
Commission should look comprehensively at the proper classification of VoIP. At the risk of 
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sounding like a broken record, our charge to protect the safety of the American people is clear 
and should never have to hinge on semantics or distinctions without a real difference.
The item also moves the ball forward for VoIP users by asking how we can ensure that 
location information is automatically updated. Today, that updating is a manual process. The 
issues are technically challenging, I understand that. But we live in a digital world and we here at 
the FCC must demand digital solutions to these critical problems. So here, too, I look forward to 
reviewing the record and to taking appropriate steps to move this critical issue expeditiously 
forward.
I want to thank the Public Safety bureau for bringing us this important item and helping 
us work through its many technical aspects. I commend the Chairman for his leadership in 
making these issues a priority and I thank him and my colleagues for working together to enhance 
the item as it made its way around the Eighth Floor.