The 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…” This is technically a non-issue on any of the current Microsoft voice platforms, and it is likely that any installation that currently exists is already compliant with this requirement.
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…”
Because this is a standard feature on Skype for Business, a review should be done to ensure that location policies are configured to notify another person or group of people pre-selected for such duty. This person can differ from location to location.
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 with Skype for Business, with or without your carrier or third-party involvement. A review is recommended to assure the granularity is appropriate to identify “the door to kick down.” 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.
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. Given the diverse and evolving nature of the MLTS market and the breadth of enterprise environments at issue in this proceeding, we decline to expand upon the statutory definition in specifying instances in which “additional information” beyond street address must be made available, or in identifying specific categories of additional location information beyond floor level or room number..”
State Laws and Local Ordinances
It important to always cross-reference state laws and regulations as they may be more stringent or defined. Intrado/West Safety Services have compiled a public reference to current state laws. Local ordinances can be more difficult, so you should check with local county/city contacts for any specific regulations.
