Summary of the Legal and Policy Landscape Surrounding Accessibility and 911

Abstract

This white paper summarizes the current landscape of federal, state, and local regulations as they relate to provisioning 911 emergency service for deaf, hard of hearing, and speech disabled communities in Colorado. This document also looks ahead to those regulations that are currently under consideration at the federal, state, and local levels that may affect 911 accessibility.

Our research was conducted at the request of the Colorado Public Utility Commission’s 911 Task Force. Next-generation 911 (NG911) applications such as text-to-911 (TT911), are especially important to people who are deaf, hard of hearing, and speech disabled, who may not be able to directly access emergency services through traditional means. In addition, NG911 access will benefit all members of a community by offering additional means of access during emergencies when calling may not be feasible or safe.

Much of the focus of this paper reflects the current state of technology used, with TT911 at the forefront of NG911 technologies being implemented. It is important to note that TT911 and other NG911 applications currently being considered at the federal, state, and local levels may not directly serve the Deaf/Blind community or even all members of the deaf and hard of hearing communities. Further research is necessary to determine how TT911 may resolve the emergency access problems facing these communities, and how or whether other NG911 technologies such as video or multi-mode communications may better address the accessibility of emergency services.

In Colorado, the decision to upgrade to NG911 rests largely with individual public-safety answering points (PSAPs). The Federal Communications Commission (FCC) has authority over wireless carriers, but almost none over PSAPs. The Department of Justice (DOJ) has issued PSAP requirements for ensuring 911 accessibility for all users, but has not taken action on that issue in more than four years. Several Colorado counties have implemented TT911 already, but many more have not due to budget or logistical reasons.

The paper concludes by exploring several case studies of TT911 implementation in other states, including states with total TT911 across the state.

Keywords: 911, accessibility, emergency services, Colorado