Ring. The emergency operator picks up the phone. “911, what is your emergency?”

“Hello! This is cardmember services calling about ways to lower the interest rate on your credit card."

"Sir, this line is for emergency use only.”

“Press 1 to speak with an operator now!”

Click.

Although 1991's Telephone Consumer Protection Act (TCPA) prohibited calls to emergency lines from autodialers and robocallers, those calls continued. Some marketers resorted to autodialers that simply plowed through every number in the US (111-1111, then 111-1112, etc.) and would inadvertently dial directly into emergency lines while merely intending to interrupt people at home during dinner. (911 systems are generally accessible by dialing unpublished access numbers.)

The telemarketing situation nationally was bad enough that, in 2003, the federal government established a National Do Not Call registry which bans most such calls to the 209 million numbers on the list.

But while legitimate companies have largely complied, rogue operators just keep calling (as evidenced by the rising volume of dodgy robocalls I get from companies bent on ignoring The Man as long as they can get away with it). Emergency operators have had enough, and earlier this year convinced Congress to help them out as part of the Middle Class Tax Relief and Job Creation Act of 2012.

In addition to dealing with tax issues, the law required the Federal Communications Commission to set up a separate Do Not Call list specifically for government emergency numbers. Public Safety Answering Points (PSAPs)—which can include "911" calls, poison control centers, etc.—will soon be even more illegal to robocall. Penalties for leaking the new list of phone numbers will hit at least $100,000 per incident, while penalties for actually calling one of the numbers will be between $10,000 and $100,000 per call.

The FCC yesterday issued a lengthy Notice of Proposed Rulemaking (PDF) on the scheme, which will cover the 6,089 PSAPs in the US. While a database of all the PSAP phone numbers might sound simple to set up, the FCC doesn't actually know their numbers; its internal tracking only shows where every PSAP is located, not how to reach it. And it's possible that the rules here need to be crafted narrowly, since some PSAPs may need to receive autodialed calls (say, from a federal emergency warning system).

And of course there's the problem of protecting the list. This has been a long-running concern when setting up such lists; the Federal Trade Commission concluded years ago that creating a “do not spam” list would actually be a huge boon to spammers by centralizing the information. One suspects that a comprehensive list of every 911 access number would be just as enticing to a certain kind of bored teenager.

But Congress hath wrought it, and so it will be. The only questions are about how to set up the "PSAP Do Not Call" list—and just how much good it will do anyone. Are the operations calling my house with impunity really going to make a special effort to log in to the new system, pull the PSAP contact data, and avoid calling the numbers? Or will they just keep blasting away with their robodialers?