The Latest FCC 911 Laws

It is common practice today to protect our schools and public buildings through legislation such as Kari’s Law, requiring the direct dial of 911 from telephone devices and the on-site reporting of the emergency call to staff, and the Ray Baum's Act requiring a dispatchable location be sent to public safety in an emergency.

Alyssa’s Law is also now in effect in Florida and New Jersey, requiring mobile ‘panic buttons’ specifically in schools that can provide critical situational awareness direct to public safety in the event of an emergency.


The FCC & New 911 Laws

One of the FCC’s top priorities is to ensure that the public can always reach 911. The FCC’s rules require communications service providers to complete 911 calls, notify 911 call centers of outages, and certify that they are taking certain reliability measures.

Completing 911 Calls.
Wireless, wireline, and interconnected VOIP service providers must connect all 911 calls and transmit the caller’s location information to 911 call centers.

Ensuring 911 Reliability. Covered 911 service providers, or providers that aggregate 911 traffic from an originating service provider and deliver it to a 911 call center, must annually certify to the FCC whether they have implemented specific measures within the last year with respect to 911 circuit diversity, central office backup power, and network monitoring.

Reporting Outages to 911 Call Centers.
Communications providers must notify, as soon as possible, a designated official at the affected 911 facility, of an outage which potentially affects the 911 facility, and must convey all available information that may be useful to mitigate the effects of the outage.

What is Kari's Law & Ray Baum's Act?

Kari’s Law and Ray Baum’s Act are two FCC statutes will make it easier for callers to reach 911 and for emergency services to locate callers in a large facility like an office building, hotel or university campus.

Facilities with multi-line telephone systems (MLTS) provide challenges in getting help from 911, such as:

1) Securing an outside line, since MLTS often require callers to dial a number or code before placing calls.

2) Providing accurate information about the caller’s location within the campus.

Kari’s Law Requirements

1.Does your current 911 infrastructure notify relevant parties that an emergency call has been made via an organization provided PBX phone?

2. Does your current 911notification provide the location of the device that dialed 911?

3. Does your current 911 infrastructure allow for 911 calls to be places without requiring them to dial 9 first then the number?

Ray Baum’s Act

4. When you dial 911 from your business phone, do you send the building address with the call through the 911 network?

5. When you dial 911 from your business phone, do you send additional information that allows the calling party to be located in a reasonable amount of time to the PSAP and on-site individuals.

6. Does your organization contain multiple buildings or buildings with multiple floors that are listed under one address?

If you answered “YES” to the question above:

6.1 Do you provide this additional location data (i.e. building, floor, zone) with the 911 calls?

6.2 Can the level of location detail you provide allow you and/or first responders the ability to find the caller in a reasonable amount of time?

7. Do you have a way of updating associated device locations in the 911 records when the devices are moved?

8. Do you have a mechanism for knowing when devices move throughout the network so that the associated 911 records can be updated?

9. If you have employees working from home who are using a softphone on a laptop or a hardware IP or SIP phone, are you currently provisioning their location data to the 911 database?

10. If you have employees that travel frequently and using a softphone on a laptop or a hardware IP or SIP phone, are you currently provisioning their location data to the 911 database?

Alyssa's Law

The Stoneman Douglas High School in Parkland, Florida took the lives of 17 people children, and school staff members.

One of these victims, 14-year-old Alyssa Alhadeff, inspired a law, known as Alyssa’s Law.

Alyssa’s Law is critical legislation addressing the installation of silent panic alarms that are directly linked to law enforcement, so in case of any emergency they will get on the scene as quickly as possible, take down a threat and triage any victims.

Alyssa Law in Texas

Alyssa’s Law will require Texas schools to implement an emergency alert system that prepares, prevents, and protects children and staff in the event that an act of mass violence occurs.

Emergency Response Applications Must Include:

Administrative Access to Critical Information

Silent Panic Alarm System

Real-Time Communication Between First Responders

2-Way Communication with Users

FCC Requirements 

There are three rules primarily based on Kari’s Law and Ray Baum’s Act that require attention, and each will vary in ease of implementation and impact over the next few years:
Direct 911 Dialing
MLTS Notification
Dispatchable Location For
On-premises fixed telephones
On-premises non-fixed telephones
Off-premises devices

Direct 911 Dialing §9.16(b)(1) – effective February 16, 2020 “…a user may directly initiate a call to 911 from any station equipped with dialing facilities, without dialing any additional digit, code, prefix, or post-fix, including any trunk-access code such as the digit 9…”

MLTS Notification §9.16(b)(2) – effective August 2, 2020 “…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…”

Dispatchable location §9.16(b)(3) – effective August 2, 2020 “…configured such that the dispatchable location of the caller is conveyed to the PSAP with 911 calls…”

Dispatchable location for on-premises fixed telephones §9.16(b)(3)(i) – effective August 2, 2020 “…An on-premises fixed telephone associated with a multi-line telephone system shall provide automated dispatchable location…”

Dispatchable location for on-premises non-fixed devices §9.16(b)(3)(ii) – effective January 2022 “…provide to the appropriate PSAP automated dispatchable location, when technically feasible; otherwise, it shall provide dispatchable location based on end user manual update, or alternative location information…”

The on-premises requirements can be satisfied by most of the latest premise and cloud-based phone systems with or without your carrier or third-party involvement.

In larger or multi-floor buildings, there may be a requirement to use a third-party phone discovery manager (PDM) and E911 service provider for MSAG validation, for less complexity and ease of management. Brookside can help assure the granularity is appropriate to identify “the door to kick down.”

Dispatchable location for off-premises devices §9.16(b)(3)(iii) – effective January 2022 “…provide to the appropriate PSAP automatic dispatchable location, if technically feasible; otherwise, it shall provide dispatchable location based on end user manual update, or enhanced location information, which may be coordinate-based, consisting of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost…

Skype for Business would require an E911 service provider for MSAG validation as the validation has become a requirement of the “dispatchable location” definition to align with the mobile E911 definition. Whether the “reasonable cost” clause would apply is very ambiguous.

On Microsoft Teams, which is slated to release their initial rendition of dynamic E911, it becomes interesting to see what types of “any available technology or combination of technologies” apply, especially after reviewing some of the Microsoft comments in the referenced FCC document: Microsoft states that commercially available location services already in use around the globe can be leveraged “relatively quickly and effectively” to enhance the 911 capabilities of IP-based and cloud-MLTS and interconnected VoIP services in ways “far more accurate and reliable than a ‘registered location’ manually entered by the end-user.”

According to Microsoft, location technologies that could be leveraged include GPS/GNSS location, device-based sensing of Wi-Fi hotspots, and use of commercially available crowd-sourced location data.

When it comes to providing the exact dispatchable location, the definition is still a little blurry and there doesn’t seem to be any definitive rules for going beyond the MSAG validated civic address. It is important to take this seriously and as not putting proper thought and investment could open yourself up to fines, if not private lawsuits.

Dispatchable Location “..A location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment or similar information necessary to adequately identify the location of the calling party..”

“..Accordingly, the definition of dispatchable location that we adopt today gives participants in the MLTS marketplace flexibility in deciding what level of detail should be included in the location information provided to PSAPs for particular environments, so long as the level of detail is functionally sufficient to enable first responders to identify the location of a 911 caller in that environment.

State Laws and Local Ordinances It important to always cross-reference state laws and regulations as they may be more stringent or defined.

Local ordinances can be more difficult, so you should check with local county/city contacts for any specific regulations. Scenarios Not Addressed by FCC It is not clear in the new rules what the requirements are for PSAP’s ability to call you back in case of disconnection.

There could be a limitation where your phone number is simply an extension of a main number using an auto attendant, and the callers DID is masked with a vanity number, resulting in PSAP not being able to call back to the caller directly.

There are also insufficient references to running a private 911 PSAP service, which is sometimes the case in large manufacturing campuses with private emergency, fire, ambulance, and security services.

The E911 regulations are a critical factor with regards to the proper setup of your Skype or Teams environment along with the overall safety planning for your office.

Brookside works directly with providers that have extensive experience with deploying and implementing various types of E911 including the general PSTN carrier or third-party E911 routing carriers based on the organization’s size, number of locations, and needs.

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What is Next Generation 911?

Next Generation 911 (commonly referred to as NG911) is a digital, internet protocol (IP)-based system that will replace the analog 911 infrastructure that’s been in place for decades.

The success and reliability of 911 will be greatly improved with the implementation of NG911, as it will enhance emergency number services to create a faster, more resilient system that allows voice, photos, videos and text messages to flow seamlessly from the public to the 911 network.

NG911 will also improve public safety answering points’ ability to help manage call overload, natural disasters and transfer of 911 calls based on caller location data. Because most 911 systems were originally built using analog rather than digital technologies, literally all the PSAPs across the country need to be upgraded to NG911.

While the technology to implement these new IP-based 911 systems is available, the transition to NG911 involves much more than just new computer hardware and software. Implementing NG911 in states and counties nationwide will require the coordination of a variety of emergency communication, public safety, legislative and governing entities.

NG911 Progress Across the U.S. Many states and localities are planning for and making the transition to NG911 now. In Phase I, the 911 software provides the civic address of the nearest cell tower or the coordinates of the cell sector centroid.

The Phase I location is typically not a “dispatchable location,” meaning it cannot reliably be used on its own to dispatch emergency responders.

Phase II location utilizes GPS, which is often very accurate in outdoor environments with a clear line of sight to a satellite, but can have limitations in dense urban settings or indoors.

Often, Phase II location falls back to cell tower triangulation which is much less accurate.

The greatest challenge for emergency responders is that Phase II location typically takes 30 seconds or more to arrive – precious time in an emergency.

Annually, the National 911 Program collaborates with 911 associations to gather the most recent information about nationwide progress toward NG911. The 911 Profile Database includes the latest self-reported data from U.S. states on their progress toward NG911.

The National 911 Program