STATEMENT OF
COMMISSIONER MIGNON L. CLYBURN
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
As our Fifteenth Mobile Services Report points out, the number of Americans who 
subscribe to wireless phone services has been increasing each year for the past nine years and, as 
of 2009, that figure exceeds 274 million.  Therefore, it is important that the Commission’s public 
safety policies keep pace with the Nation’s growing dependence on these technologies.  With 
regard to mobile wireless E-9-1-1 services, we must adopt rules that continue to improve the 
ability of public safety personnel to obtain accurate information, when a person uses a mobile 
phone to make an emergency call.  Our regulatory approach should be comprehensive and adapt 
to the technological advances in the mobile wireless industry.  But, our approach should also be 
reasonable and flexible enough to permit carriers to find the path to more accurate wireless 
E-9-1-1 services that is most cost effective for them.  
This item, I believe, strikes the right balance.  The Report and Order recognizes that the 
industry should be working towards the more stringent standard we set for handset based location 
technologies.  It requires all new wireless providers, which meet the definition of covered CMRS 
providers in our Rules, to satisfy that standard. It also explains that the Commission intends to 
sunset the less stringent network based location standard.  But it appropriately declines to impose 
a unitary standard for all providers.  The record makes clear that providers who are currently 
using network-based E-9-1-1 solutions, are migrating to handset based solutions.  Accordingly, 
the more accurate handset based standard should, as a practical matter and without a regulatory 
mandate, become the industry standard.  
The two Notices we also adopt today, properly seek comment about expanding 9-1-1 
location service requirements to cover more VoIP services.  The item explains that, as the use of 
location based services on smart phones becomes more prevalent, Americans are beginning to 
expect that their service providers know their current location whenever they are using that 
device.  It is therefore reasonable for them to also expect that, when they make a 9-1-1 call, their 
current location information should be provided to public safety agencies, whether they make the 
call using a traditional commercial wireless services or whether they are using VoIP services.  
Technical experts at the Internet Engineering Task Force have proposed standards that should 
allow that type of location communication to occur whenever a person chooses to make the 9-1-1 
call using VoIP services.  I hope that all relevant parties will contribute additional technical 
expertise that will move us closer to that goal.
I commend Admiral Jamie Barnett and his team at the Public Safety Homeland Security 
Bureau for presenting us with an excellent item.