Mobile Satellite Service (MSS) carriers that provide interconnected, two-way voice services must be fully equipped to handle 911 emergency calls. This means that providers must establish call centers to receive satellite phone emergency calls and then forward such calls to appropriate public safety access points. However, this regulatory requirement affords MSS carriers some generous exemptions that balance public interest with the carrier’s own technological and logistical challenges in providing emergency call capability.

In 2004, the U.S. Federal Communications Commission (FCC) imposed a requirement on MSS carriers to comply with 911 regulations. The mobile industry was subject to a similar requirement in 1996, and wireline carriers have been complying since 1965. The reason why the FCC delayed the requirement for MSS carriers was due to the technological and logistical challenges of providing 911 capabilities via MSS. 

Challenges of Providing 911 Calls via MSS

MSS is provided across a constellation of satellites, making it an international service by nature. As such, it presents a host of complicated issues with respect to 911-call access. For example, if a foreign MSS customer used the service in the United States to dial its own country emergency code, should U.S. MSS carriers be required to recognize and handle the call? Many European countries use the dial code 112, while Japan uses 119 for ambulance and fire and 110 for police. Argentina uses 101 for ambulance and police and 107 for fire. Brazil uses 192 for ambulance, 190 for police and 193 for fire. You get the idea.

The situation isn’t any clearer when applied to U.S. customers in U.S. territories. What if a U.S. customer called 911 from an oil rig in U.S. waters? Should this user expect the U.S. Coast Guard to show up as a result of the call? What if the user is a crew member or passenger aboard an aircraft in flight through U.S. airspace?

Unlike terrestrial wireless networks, MSS carriers are interconnected to only a small number of terrestrial points (i.e. gateway stations) in the United States. This makes it difficult to interface with the existing 911-call structure. Furthermore, an MSS call center likely will receive many calls from non-English speakers. Should MSS call centers be required to staff their call centers to handle many languages? How many?

What about MSS operators that provide only the satellite (i.e. the space segment)? Would resellers of MSS also have to comply? Although these and other conundrums delayed the FCC from imposing 911-call requirements on MSS carriers, the mandate now is clear. MSS carriers must comply with regulations like all phone service providers.

Mandate for MSS Carriers

One can view the mandate as a single requirement with a list of exemptions. The mandate: MSS carriers that provide real-time, two-way voice service interconnected with the public network must: (1) establish call centers for answering 911 emergency calls and (2) forward the calls to public safety access points.

That said, the regulations specify a handsome number of exemptions from the mandate. First, MSS operators which provide only the space segment are not required to comply, provided that they do not also offer service to end users. Resellers must provide 911-call access but only to the extent that their underlying carrier is subject to the requirement. Second, various services offered by MSS carriers fall outside of the requirement — for example, services across non-roaming, terrestrial, temporary fixed terminals (i.e. laptop computer size). These terminals do not operate while in motion and usually take a few minutes to boot-up. Also exempt are maritime and aeronautical services. The idea is that these users do not have an expectation of 911-call service because other forms of emergency access exist in these situations.

It also is important to note that MSS call centers only are required to answer calls in the English language and are required only to recognize the 911 dialing code as opposed to the many international emergency codes in existence. Finally, MSS carriers do not have to offer 911-call service to handsets that have not been initialized.

As you can see, emergency regulations for MSS carriers are a work in progress. The FCC has reserved the right to revisit the topic as technological innovations and logistical complications are addressed.

Raul Magallanes runs a Houston-based law firm focusing on telecommunications law.
He may be reached at +1 (281) 317-1397 or by email at raul@ rmtelecomlaw.com.