(1) Kari’s Law applies to multi-line telephone systems (MLTS), which are telephone systems that serve
consumers in environments such as office buildings, campuses, and hotels. Kari’s Law requires MLTS systems in
the United States to enable users to dial 911 directly, without having to dial a prefix to reach an outside line, and
to provide for notification (e.g., to a front desk or security office) when a 911 call is made.
(2) RAY BAUM’S Act requires the Commission to conduct a rulemaking proceeding to consider adopting rules
to ensure that “dispatchable location” is conveyed with 911 calls, regardless of the technological platform used, so
that 911 call centers will receive the caller’s location automatically and can dispatch responders more quickly.
“Dispatchable location” is defined as “the street address of the calling party, and additional information such as
room number, floor number, or similar information necessary to adequately identify the location of the calling
party.”
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2 comments
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Larry Neblett With regard to Kari's law, it currently complies.
I have a number of hotel clients around the country and what I do not believe was covered in the act is the requirement that dialing instructions that property owners may provide must also be updated to reflect the change. As many hotels have dialing instructions on the phones (emergency, front desk, room service, etc.) they oftentimes indicate that when dialing an for an emergency that the caller must prepend the number with a 8, 9 or something else. I have to use the dialing rules to cover any possible scenario of what a caller may dial by using the dialing rules to either strip or append such that if they dial 911, 8911, 9911 or other, the system will take it and then dial 911. Additionally, the system will also notify others of when an emergency number was dialed and provide the extension number that did so.
I am no attroney, so the other aspects are somewhat confusing -
The FCC’s rules require that a person engaged in the business of installing, managing, or operating an MLTS must, in installing, managing, or operating such a system for use in the United States, configure the system to provide MLTS Notification to a central location at the facility where the system is installed or to another person or organization regardless of location, if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system. 47 C.F.R. § 9.16(b)(2).
MLTS Notification is defined as an MLTS feature that can send notice to a central location at the facility where the system is installed or to another person or organization regardless of location. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification must include, at a minimum, the following information: (1) the fact that a 911 call has been made, (2) a valid callback number, and (3) the information about the caller’s location that the MLTS conveys to the PSAP with the call to 911. 47 C.F.R. § 9.3.
MLTS Notification must meet the following requirements: (1) MLTS Notification must be initiated contemporaneously with the 911 call, provided that it is technically feasible to do so; (2) MLTS Notification must not delay the call to 911; and (iii) MLTS Notification must be sent to a location where someone is likely to see or hear it. 47 C.F.R. § 9.16(b)(2).
4. Interconnected VoIP
Fixed interconnected VoIP providers are required to transmit dispatchable location with each 911 call. While dispatchable location may be determined by means of a customer generated Registered Location in the fixed VoIP context (to the extent a physical location conveys a street address that is validated), it must be provided automatically to the PSAP by the VoIP service provider, without additional action by the caller, at the time the 911 call is made. This requirement will take effect one year from the effective date of the FCC’s rules. Order ¶ 176.
So, it appears that the issue really lies with the SIP Trunk provider of which most do have the requirement met if they are using geo-location services by which to validate the address. So, if talking about SIP Trunks, then I believe the PBX meets the requirement provided that you have set up the existing functionality in the PBX correctly and use a provider that is capable of registering a validated address to a number that will be seen by the PSAP.
Where it gets sketchy is non-interconnected fixed VoIP. -
Providers of non-fixed interconnected VoIP service (i.e., a VoIP service that is capable of being used from more than one location) must provide automated dispatchable location, if technically feasible. Otherwise, non-fixed interconnected VoIP service providers must either:
(1) provide Registered Location information that meets the following requirements:
• the service provider has obtained from the customer, prior to the initiation of service, the Registered Location (as defined in the FCC’s rules) at which the service will first be used;
• the service provider has provided end users one or more methods of updating their Registered Location, including at least one option that requires use only of the CPE necessary to access the interconnected VoIP service. Any method used must allow an end user to update the Registered Location at will and in a timely manner; and
• the service provider must identify whether the service is being used to call 911 from a different location than the Registered Location, and if so, either: (i) prompt the customer to provide a new Registered Location; or (ii) update the Registered Location without requiring additional action by the customer.
As Wi-FI and smartphone apps are about, it is not clear to me how that latter point would be accomplished. Not all use a PBX.
I am also unsure how analog trunks play, but my take is that as long as the DID has a validated address and someone at the site is available and gets the notification, they can direct the responders to the exact location. Can you imagine have a 400 room hotel or office building and only one DID and be expected to register 400 different locations which could only be accomplish by the extension number?
Good question, and as stated, I am no attorney so my interpretation may be well off the mark. I look forward to what Yeastar has to say or anyone else who may have some insight.
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Billy Bugg I do not see any other updates regarding this subject especially as it pertains to Linkus Mobile Applications and E911 Service in the U.S. How is anyone handling Mobile and Nomadic Linkus Users. I would hope that anyone with a Cell Phone in their hand is not going to Launch Linkus to make a 911 Emergency Call but if the App is open and they Dial 911, the ELIN is not going to provide a Valid Dispatchable Location or a Laptop user that logs in at Starbucks. There is no way to update the Dispatchable Location for the App User. The Linkus Mobile App should always use the Cellular Network to make emergency 911 calls so that falls onto the Cellular Carrier but for Tablet or Laptop users there needs to be a way to update the Dispatchable Location from the App or Web Portal for the user.
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