📜 Key FCC Rules and Statutes on 911 Access and Jail Communication Systems

Key FCC Rules / Statutes

1. 47 CFR Part 9 — 911 Requirements (eCFR)
   • § 9.4 — Obligation to Transmit 911 Calls: All telecommunications carriers must transmit all 911 calls to a Public Safety Answering Point (PSAP), a designated statewide default answering point, or another appropriate local emergency authority. (Cornell LII)
   • § 9.5 — Transition to 911 as the Universal Emergency Number: Requires carriers to transition to 911 as the universal emergency number and outlines compliance deadlines. (eCFR)
2. 47 CFR § 9.14 — Emergency Calling Requirements for Telecommunications Relay Services (TRS) (Cornell LII)
   • Applies to both TTY-based and internet-based TRS providers.
   • Requires emergency (911) calls to be routed properly, either automatically or immediately, to the correct PSAP.
3. Incarcerated People’s Communication Services (IPCS) / Inmate Calling Services (ICS)
   • FCC requires ICS providers to offer relay services for individuals with communication disabilities. (FCC Portal)
   • Although rules do not explicitly mandate 911 access for inmate phones, ICS providers classified as telecom carriers may still fall under § 9.4 obligations. (Federal Register)

How These Might Apply to Jail / Inmate Phone Systems

• 📞 If the jail phone system is operated by a telecommunications carrier or ICS provider that connects to the public telephone network, then under § 9.4 all 911 calls must be transmitted to a PSAP or other designated authority.
• 🛑 If the phone system is purely internal (not connected to the public network), FCC emergency access rules may not apply.
• ♿ Under § 9.14, ICS providers are obligated to ensure appropriate emergency handling for inmates with communication disabilities (e.g., TRS users).