STATEMENT OF 
COMMISSIONER MIGNON L. CLYBURN
Re: Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications 
Systems, PS Docket No. 17-239
A frantic call to 911 is one we never hope to make, but in an emergency, we count on that 
number to be our link to police, fire, or EMS.  When dialing 911 from your hotel, school, or 
office building, the expectation is that the call will connect just as it would from your home 
phone or mobile device, and that the dispatcher will know exactly where you are calling from. 
Unfortunately, that has not always been a reality, as we saw from the tragic death of Kari Hunt 
which ultimately led to the passage of “Kari’s Law.”
As we continue to witness the utter devastation and loss of lives resulting from 
Hurricanes Harvey, Irma, and Maria, we are reminded that we must do all we can to enable 
effective emergency services.  So, today, we consider an item which examines the provision of 
911 services in enterprise communications systems or ECS.  ECS provides phone service within 
large businesses, including the office building we are in right now.  And since ECS is expanding 
to include virtual and cloud-based platforms, it is all the more reason why it is time to explore 
challenges that ECS may face when accessing 911.
In this NOI, we invite input on the capabilities of ECS to directly call 911 and 
provide automatic location information.  Notably, we seek comment on ways to ensure that these 
systems will keep pace with technological developments and enable the 911 service that 
consumers expect and deserve.
I was pleased that my colleagues supported my requests to seek comment on two issues.  
First, whether, during hurricanes and other natural disasters, ECS services face technical 
challenges different from other services in the provision of access to 911.  And second, how 
precise should ECS location information be when a caller dials 911.  For example, in the case of 
an office building, is it sufficient to identity the floor a call was made from, or should the system 
be able identify the actual office from which the call was made?  
This item should help enhance the provision of emergency communication services to the 
public and I am pleased to support it.  My thanks to the Public Safety and Homeland Security 
Bureau for presenting us with this important item.