E9-1-1 for MLTS Solution Providers
In its comments filed with the FCC in 200531, Verizon argued that there was no need for federal rules in this area because competitive E9-1-1 solutions were readily available for all MLTS systems from carriers and third parties and because states were the best venue to address this issue.
`E-911 Solutions are available for all customers, including multi-line telephone Systems.' `Local exchange carriers ("LECs"), PSAPs, third-party vendors, and multi-line telephone system manufacturers have developed in response specific multi-line telephone system E-911 solutions, and the Commission properly has concluded that "a variety of technologies and vendors exist currently that make E-911 compliance in the MLTS context quite feasible." (p. 2).
Third-party vendors and software providers also report that "robust E-911 solutions are readily available" for multi-line telephone systems'. (p. 3)
NENA correctly notes that the' expectation for simple, inexpensive, integrated E9-1-1 support within future PBX models will lower user concern about costs, and indeed the industry has worked to streamline and simplify this process for businesses.' (p. 5)
Initial Staff analysis has identified several MLTS equipment manufacturers and third-party vendors who worked on the National Emergency Number Association (NENA) Technical Committee that developed the NENA Model Legislation E9-1-1 for MLTS. Based on an Internet search of web sites and news reports, Staff has concluded that there is a healthy and competitive market as to the offering of commonly available and affordable E9-1-1 MLTS solutions at all price points for all sizes of LEC business customers.
(END OF APPENDIX A)
31 Verizon's comments in CC Docket No. 94-102, Feb. 28, 2005.
