Texas Advisory Committee on State Emergency Communications

In the Matter of

Federal-State Joint Board on
Universal Service

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

CC Docket No. 96-45

To: The Commission

COMMENTS OF THE TEXAS ADVISORY COMMISSION ON STATE
EMERGENCY COMMUNICATIONS

NOW COMES THE TEXAS ADVISORY COMMISSION ON STATE EMERGENCY COMMUNICATIONS (TX-ACSEC), by and through the Office of the Attorney General of Texas, and submits these COMMENTS in response to the Federal Communications Commission's (Commission) Notice of Proposed Rulemaking [NPRM] in CC Docket No. 96-45, released March 8, 1996.

In the NPRM, the Commission sought comments on whether specific telecommunications services, with respect to rural, insular, and high cost areas, should be included among the core services receiving universal service support. One of those services is access to 9-1-1 emergency services. NPRM at p. 12. The Commission invited specific comment "on whether we should include access to erhance 911 services among the services that should receive universal service support in the event we include basic 911 service in that group." NPRM at p. 15. TX-ACSEC has a few comments.

TX-AC SEC applauds the Commission's concern and attention to the issue of 9-1 -1 in rural, high cost areas. TX-ACSEC would note, however, that many states, such as Texas, already have separate dedicated funding for basic and enhanced 9-1-1 emergency services that includes the rural, high costs areas. 9-1-1 implementation is essentially a local issue because it involves the coordination of both the local telephone companies and the local governments that provide the emergency response services. Universal service fund support for 9-1-1 should be appropriately coordinated with the existing state funding mechanisms and the local governments involved in providing the emergency service.

Respectfully submitted,
DAN MORALES
Attorney General of Texas
JORGE VEGA
First Assistant Attorney General

THOMAS P. PERKINS, JR.
Assistant Attorney General
Chief, Consumer Protection Division

RUTPACO T. GONZALEZ
Assistant Attorney General
Chief, Public Agency Representation Section
State Bar No. 14741550

RICHARD A. MUSCAT
Assistant Attorney General
State Bar No. 14741550
Consumer Protection Division
Public Agency Representation Section

P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Voice: (512) 463-2185
Fax: (512) 322-9114