STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re:  Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications; 
Framework for Next Generation 911 Deployment, PS Docket Nos. 11-153, 10-255
Helping to ensure the safety of the American people is a core priority for government and 
this agency in particular.  As our robust communications market continues to create innovations 
that are literally improving the human condition across the globe, the opportunity for new 
technology to help save lives has never been greater.  Today, we continue our noble endeavor of 
exploring paths to deploy next generation technologies for emergency communications (what we 
are calling “next generation” 911, although I suspect that term will become quaint before too 
long).  As we go forward, with our gaze fixed on the goal of modernizing this framework, we 
should take extra care to avoid tripping over pragmatic realities on the ground, such as limited 
legal authority, technical limitations and unfunded mandates.
Especially given today’s economy, the Commission must be careful not to impose costly 
requirements on industry that would, in turn, require large taxpayer financed investments by 
public safety or overhauls of existing emergency communications systems.  As part of this 
proceeding, we should examine all potential costs.  As we all recognize, today money is either 
unavailable or tightly managed.  Therefore, I thank the staff for preparing the white paper on 911 
costs.  The document is detailed and thorough.  I have no doubt that it will serve as a useful tool –
both internally and externally – as we work together to grapple with these complex legal, 
economic and technical issues.
Furthermore, I am pleased that today’s notice contains questions about the Commission’s 
legal authority.  Ensuring clear and effective communications in times of emergency is a key 
aspect of the Commission’s mission.  At the same time, however, some providers of current and 
future application-based communications services are not FCC licensees and thus fall outside of 
the Commission’s jurisdiction.  Given the importance of the topic, however, I am eager to hear all 
good faith legal arguments.
In addition, we could all learn more about consumer expectations.  The lessons learned 
from deployment of wireless Enhanced 911will help guide us in our pursuit of a workable 
framework for next generation 911 deployment.  For instance, should the Commission require 
public safety entities to demonstrate a specified level of technical capability at the statewide or 
local level as a precondition to carriers delivering text or other media to them?  What steps should 
be taken, and when and by whom, to educate consumers on the status of this work-in-progress?
I also appreciate the white paper on Deployable Aerial Communications Architecture in 
emergency situations.  The recent trifecta of an earthquake, hurricane and tropical storm hitting 
the East Coast, has heightened the need for in-depth analysis of potential communications 
solutions.  Thank you for this excellent primer.
Finally, in this instance, I support our decision to refrain from including draft rules at this 
point in the process.  Usually, I am a proponent of including draft rules with notices of proposed 
rulemaking.  As we remain at a preliminary stage, however, final proposals have yet to be 
developed.  As I have noted, we must develop a strong record illustrating the costs and technical 
feasibility of implementing this technology.  Accordingly, I approve of this prudent approach to 
develop the record further before drafting proposed rules.
Thanks again to all who have contributed today.  I am pleased we are taking a 
comprehensive approach and I applaud your work.