FCC Proposes Rules for Direct 911 Dialing by MLTS

The FCC today unanimously adopted a notice of proposed rulemaking that would require multi-line telephone systems (MLTS) to allow for direct dialing to 911 and to provide the location information of callers.

The FCC adopted the NPRM in PS docket 17-239 pursuant to two new laws, the Kari’s Law Act and RAY BAUM’S Act.  The Kari’s Law Act, which was enacted in February, is named after Kari Dunn, who was killed by her estranged husband in 2013 in a Texas motel room as her daughter attempted to call for help but couldn’t reach 911 because she didn’t dial “9” first.

Before the FCC adopted the item today, Kari Dunn’s father, Hank Hunt, spoke in favor of it.  “Kari’s daughter dialed 911 four times during her mother’s attack.  But not one of her calls ever reached 911 because the hotel phone required guests to dial a ‘9’ for an outbound line before dialing 911,” said FCC Chairman Ajit Pai, an early advocate of state and federal adoption of Kari’s Law.

“Now, it’s our turn to act for Kari.  In this notice, we propose rules to implement Kari’s Law so that when Americans dial 911 from multi-line telephone systems, which are commonly used in office buildings and hotels as well as on campuses, they can reach emergency services,” Chairman Pai said in a statement.

“But sometimes, being able to reach emergency services isn’t enough.  For example, if you’re calling 911 from a large office building, it’s important that first responders know where you are in that building so they can find you,” he continued.

“That’s why we’re also proposing to mandate that 911 calls from MLTS include a dispatchable location and that this requirement take effect at the same time as the compliance date set forth in Kari’s Law.  And we are seeking comment on the feasibility of requiring a dispatchable location for 911 calls from other technological platforms, including fixed telephony services, interconnected and other VoIP services, and Internet-based Telecommunications Relay Services, pursuant to section 506 of RAY BAUM’s Act,” he said.

“Finally, as a matter of good government, we’re proposing to consolidate the Commission’s existing 911 rules in one place.  Today, those rules are scattered throughout Title 47 of the Code of Federal Regulations,” he said.

The Kari’s Law Act also requires MLTS to provide notification, such as to a front desk or security office, when a 911 call is made in order to facilitate building entry by first responders, according to an FCC news release.

“The Commission proposed rules to provide clarity and specificity to these statutory requirements so that companies can effectively meet their obligations,” the news release said.  The text of the NPRM was not immediately available.

“At the end of the day, this is simple:  When you pick up the phone to dial 911, it should work,” Commissioner Jessica Rosenworcel said in a statement.  “When one of the tens of thousands of 911 call operators on the other end of the call answers, they should receive the location information they need to send help.”

“But as we move forward I hope that we keep another simple concept in mind:  a deadline.  When the FCC completes its work in this proceeding, I want us to be able to say that by 2020 911 callers across the country can expect that whenever, wherever, and however they call for help, first responders can find them,” Commissioner Rosenworcel added.

Commissioner Brendan Carr praised Chairman Pai’s work on the issue and said, “I am glad to support this notice, which will take much-needed steps to ensure that, when any child does exactly what their parents teach them to do in an emergency — dial 911 — the call goes through.”

Commissioner Mike O’Rielly also expressed support for the NPRM but raised concerns that portions of it “stretch the law in directions not necessarily intended.

“For example, the item suggests expanding the definition of MLTS to include systems provided using IP technology and over-the-top applications,” he said in a statement.  “I am having a difficult time imagining how such an obligation would even work.  How does the Commission envision regulating enterprise over-the-top VoIP apps — some of which already exist today — that can be created, updated and distributed from anywhere in the world?”

“Additionally, the Commission is considering whether operators of grandfathered MLTS systems should provide notification to callers, potentially in the form of stickers or labels, regarding how to call 911, even though Congress did not mandate this, and, in fact, Kari’s Law placed no requirements on systems manufactured, imported, sold, or installed before Feb. 16, 2020,” Commissioner O’Rielly added.

“Similarly, in implementing RAY BAUM’s Act, the Commission seeks comment on whether information besides a dispatchable address, such as x/y/z coordinates, should be voluntarily sent to PSAPs.  It is hard to imagine why this information is necessary when dispatchable addresses is the gold standard for location accuracy,” he said.

“I look forward to discussing these issues with interested parties as we proceed to order.  I hope the Commission will implement the statute as written and will look to keep burdens to a minimum,” he said.

NENA praised the FCC’s work on the issue.  “In a time of crisis, any caller should be able to dial 911 directly, reach a trained public safety professional, be quickly and accurately located, and obtain assistance promptly — no matter the phone or phone system,” Dan Henry, NENA’s director-government relations, said in a statement.

“This issue has long been a priority for NENA, and despite its successful efforts with many states, direct access to 911 is still not a reality for many of those living and working in offices, factories, hotels, dormitories, and hospitals,” Mr. Henry said.

“NENA applauds the FCC’s proposed rules and looks forward to continuing progress toward ubiquitous, direct access to 911,” he added.  “NENA also appreciates the FCC’s proposed plan to consolidate its 911 rules into a single rule part.  Creating a section of FCC rules regarding 911 will streamline the process in locating and determining which rules affect our industry.” — Tom Leithauser, tom.leithauser@wolterskluwer.com

Courtesy TRDaily