Nobody had ever asked before. Not Montgomery County. Not Maryland. Not Verizon.
I am not being facetious.
My Verizon bill has twelve lines on it. Four phones, five watches, three iPads. Courtney and I, our three daughters, and my mother. The taxes and surcharges come to $163.34 a month, which is $1,960.08 a year.
Part One of this series was about how the county set the fee.
Part Two was about the process to find answers.
This is about what lands on the bill and I am just getting started.
The law saw this coming
In 2019 the General Assembly changed how Maryland charges for 911. The fee had always been assessed per telephone bill. Carl Henn’s Law made it per line.
If you followed the bill as it moved through the Senate you could have watched someone realize what that would do to a family. Commercial mobile radio service furnished to multiple devices that share a mobile telephone number is treated as a single 911-accessible service.
It went in by amendment, in the same bill that created per-line billing, written by people who were at that moment thinking about what per-line billing does to a household with more devices than people.
That sentence now sits in two places. Section 1-311(c)(4) applies it to the county fee. Section 1-310(f)(3) applies it to the state fee. Same words, twice, in consecutive sections.
Four of the five Apple Watches on my account run on Number Share. They do not have their own phone numbers. They use the numbers of the paired iPhones.
Both fees are charged on all four.
Verizon’s own contract says the number is shared
I asked Verizon a direct question: is a Number Share watch assigned its own distinct mobile telephone number, or does it operate on the paired handset’s?
For the sake of this, an extension device is most commonly a smartwatch.
Verizon answered by quoting its own Number Share Terms and Conditions. Number Share “allows you to make and receive calls using one shared telephone number across all of your Number Share – Mobile capable Verizon LTE devices.” The host smartphone’s number “is shared by all eligible extension devices.” Calls “are received and sent from this shared line.”
Then the sentence Verizon leaned on: “Your extension device will also have its own line that will be reflected on your bill.” So Verizon’s position is that the number is shared and the line is separate.
The statute keys on the number. The bill keys on the line.
The same contract settles which one is doing the work. Deactivate the host line, it says, and extension devices must be deactivated, moved to another host, or “operate independently” — and “additional monthly fees may apply if an extension device becomes a standalone device.” Elsewhere: you “will incur an increased monthly charge for the extension device line” because it “will then operate in standalone mode.”
If the watch already had its own number, standalone mode would change nothing about numbering. Verizon’s own contract treats standalone as a different state, one that costs more. That is the company conceding that an extension device has no number of its own until it stops being an extension device.
I asked twice more what the legal basis was for assessing separate fees anyway. Both times Verizon sent back the identical paragraph from the terms page.
The county’s own tax has the same problem
Montgomery County charges a separate telephone tax of $3.50 per wireless line per month. Its code defines a line as a connection to the local telephone exchange through a unique telephone number.
A Number Share watch has no unique telephone number. It borrows one.
It is charged $3.50 anyway.
Verizon knows how these exemptions work, because it applies one correctly on the same bill. My three iPads carry no county line tax and no 911 fee at all, which is exactly the treatment the statute requires for a broadband connection not used for telephone service.
The iPads cannot place voice calls, so they are not assessed a county line tax or a 911 fee. The carrier got that right.
The watches place their calls on the paired phone’s number, which is already assessed a county line tax and a 911 fee on the phone line. They are assessed again anyway. The carrier is still investigating.
One phone number, taxed twice.
On my account, the four watches come to $92.64 a year in county 911 fees, $24 in state 911 fees, and $168 in county telephone tax.
Two hundred eighty-four dollars and sixty-four cents, on four wrists.
What the state said
On September 8, the Maryland Department of Emergency Management answered my records request. MDEM houses the Maryland 9-1-1 Board, which administers the 911 Trust Fund and reports annually to the Governor and the legislature.
Three things came back.
There are no guidance documents, bulletins, correspondence, or interpretive materials of any kind regarding § 1-310(f)(3) or § 1-311(c)(4). None. In the seven years the exemption has existed, the agency that administers the system has never written anything explaining it.
No complaints have ever been received about 911 fees assessed on devices sharing a mobile telephone number. Not one.
And then this, unprompted, in a letter signed by an Assistant Secretary and copied to the Department’s Principal Counsel:
The charges appear to be a technical error in how your carrier’s automated tax software processes wearable devices. It is our understanding that when a smartwatch is activated on a shared-number plan, a network assigns a hidden “shadow” Mobile Directory Number (MDN) solely for data routing. The carrier’s billing engine treats this shadow MDN as a standard phone line, triggering an automatic—and incorrect—9-1-1 surcharge. Because this line is a companion device sharing a primary number, these fees should be suppressed in accordance with Maryland law.
That is the state telling me the charges on my bill are wrong.
And before anyone else can, let me say the following.
MDEM is not the enforcement agency. Under § 1-310(f) the Comptroller audits carrier collection and remittance. MDEM administers the fund. Its reading is authoritative as interpretation and binding on nobody.
The language is hedged twice. “Appear to be.” “It is our understanding.” The Department is describing a mechanism it believes explains the charges, not reporting the findings of an investigation.
And I asked whether that statement represents the formal position of the Maryland 9-1-1 Board or an informal assessment by Department staff. I have not been told. Until I am, this is the Department’s view and I am describing it as such.
But note what the shadow-MDN explanation does. It does not contradict Verizon. It reconciles with it. Verizon says the number is shared; MDEM says there is also a hidden identifier used for data routing that the billing software misreads as a phone line. Both can be true. MDEM’s point is that the hidden identifier should not matter, because the device shares a primary number.
That is precisely the argument Verizon might have made, and the state answered it before Verizon got there.
And then there is the other charge
But wait! There is more!
Buried in Verizon’s response was a figure I did not ask about in that form.
I had asked what the Administrative and Telco Recovery Charge costs. That is Verizon’s own line item, not a tax, the one the company paid $100 million in 2024 to settle a class action over. Verizon answered: “$3.78 per line, and $1.60 per line for data-only plans.”
My three iPads are data-only. Verizon says so itself by charging them no 911 fee and no county line tax.
Each one is billed $3.97.
That is $2.37 a month more than the rate Verizon’s own Executive Relations department put in writing, on each of three lines, or $85.32 a year. It has nothing to do with statutes, counties, or the General Assembly. It is Verizon’s written statement against Verizon’s own invoice.
I sent them a screenshot and asked them to reconcile it.
What Verizon is doing about it
On September 1, after six weeks and several rounds, an individual at Verizon Executive Relations wrote that they had escalated my questions to the company’s Billing Team and Tax Team who were “actively working to answer these questions.”
Yesterday I sent them MDEM’s letter. They replied the same day: “Our Team is still reviewing your additional inquiry and I will provide an update on the information you provided regarding your account.”
I am not going to characterize that as an admission, because it is not one. It is a carrier reviewing, after a state agency put in writing that the charges are incorrect and after being shown a discrepancy between its own stated rate and its own bill.
What happens next is theirs to decide. Whatever they tell me runs here in full. There is nothing they can say or offer to me that will prevent that from being the case.
Two things I got wrong
The same records that produced all of this overturned two things I published in Part One. I said at the outset that everything I received would be published here, including anything that proved me wrong.
This is that.
Start with the eight cents. I wrote that the Council approved a fee of $2.01 on May 5, that the county certified $1.93 on May 29, and that nothing in the public record explained the difference. The Council has since produced its May 13 minutes, obtained after I sought assistance from the Maryland Public Access Ombudsman. They show the Council took final action on May 13 and adopted Resolution 20-1116. The certification matched the adoption. There was never a gap between the two, and my framing implied one.
The eight cents did disappear. It disappeared in the eight days between the May 5 straw vote and the May 13 adoption, and I described it in the wrong place. I had the committee report describing the straw vote but not the adoption minutes, and I should have written that the record was outstanding rather than that none existed.
What still stands: the $2.01 never took effect, and nothing produced explains why. The May 13 session summary records the Community Use of Public Facilities resolution as adopted 10 to 1 and the income tax rates as adopted 6 to 5, naming the dissenters by initial in both. The 911 fee is recorded as adopted 11 yes, with no initials. The clerk notes dissent when there is dissent. On this item there was none, including from the member who had proposed the increase.
Then the audit figure.
My opening paragraph in Part One said the state recovered $26,534 in 911 fee audits across all of Maryland in the most recent reported year, and that this worked out to one dollar for every $2,750 collected. That figure came from the 9-1-1 Board’s annual report, the only place the state publishes it.
On September 14 the Comptroller’s Office provided its own numbers. Fiscal 2022, ten audits, $321,738 assessed. Fiscal 2023, nine audits, $344,394. Fiscal 2024, five or fewer audits, nothing assessed. Fiscal 2025, six audits, $129,586. Fiscal 2026, five or fewer audits, nothing assessed.
The fiscal 2023 figure is roughly thirteen times what the Board published. My ratio was wrong by more than an order of magnitude, and I should not have built a lede on a single partial figure from a summary report without asking the enforcing agency for its own. That one is on me.
What the fuller record shows is not a larger enforcement program. It is $795,718 assessed over five years, with nothing at all assessed in two of them. And the number the public can read, in the state’s own annual report, is the smaller one. I have asked the Comptroller to explain the difference.
What this is actually about
I have four phones, five watches, and three iPads. Yes, I understand what image that projects. Please do not come at me for that.
So set my account aside and look at what the state said.
No guidance has ever been issued on the exemption. No complaint has ever been received. The Comptroller assessed nothing at all in two of the last five fiscal years, including the most recent, when it audited five or fewer carriers. And the agency that administers the system says that when a smartwatch is activated on a shared-number plan, carrier billing software automatically triggers a 911 surcharge that should be suppressed.
Automatically.
If that is right, this has been happening to every Maryland household with a paired smartwatch since 2019. Nobody has ever checked, and nobody has ever complained because nobody knew there was anything to complain about.
This is not just $284 on one bill. I have no idea what the number is, and neither does anybody I have asked.
What I want
Verizon should say plainly whether it agrees with the Maryland Department of Emergency Management, and if it does, how many Maryland accounts are affected and over what period. It should also reconcile the $1.60 data-only rate it put in writing with the $3.97 it charges.
The Maryland 9-1-1 Board should state whether the Department’s September 8 letter represents the Board’s position, and if it does, issue the guidance that seven years of silence has left unwritten.
The Comptroller should audit carrier application of §§ 1-310(f)(3) and 1-311(c)(4). Six or fewer audits a year, with nothing assessed in two of the last five, is not a program that would find this.
Montgomery County should say whether its telephone tax applies to a wireless device with no unique telephone number, given that its own code defines a taxable line as requiring one. I asked the Department of Finance on July 26 and again inside a records request. Neither has been answered but they have acknowledged the request as of publication thanks to the support of the Ombudsman.
If you are a Montgomery County wireless customer, or anywhere in Maryland with a paired smartwatch, look at the 911 line on your bill. Screenshot the surcharge and tax sections, black out your name, address, account number and phone numbers, and send it to me. I do not want your personal information and I cannot use it. I want the line items and the amounts.
Sources
Records obtained by request
Maryland Department of Emergency Management, response to media and public information requests, September 8, 2026. Contains the Department’s statement on shared-number devices, and its confirmation that no guidance documents and no complaints exist.
Comptroller of Maryland, correspondence regarding Maryland Public Information Act request of July 26, 2026, dated September 14, 2026. Contains the five-year audit figures.
Montgomery County Council, session summaries and approved minutes for May 5 and May 13, 2026. Produced after mediation through the Maryland Public Access Ombudsman.
Legislation and statute
Senate Bill 339 of 2019 (Carl Henn’s Law), Third Reader. The shared mobile telephone number provision appears as an amendment, with subsequent paragraphs renumbered on the page.
Maryland Code, Public Safety § 1-310 and § 1-311.
Montgomery County Code § 52-15, Telephone tax.
Government reports
Maryland 9-1-1 Board, Annual Report Fiscal Year 2023, required by Public Safety Article § 1-307. The only place the state publishes 911 fee audit outcomes.
Corporate
Verizon, Number Share – Mobile Terms and Conditions, updated February 22, 2024.
Verizon Executive Relations, written responses to questions submitted August 2026.
