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The FCC Moves Forward with Potential New 911 Obligations for Hotels and Offices
3 Oct, 2018
The Federal Communications Commission will seek public comment on
proposed new rules to require that 911 calls made from hotels, offices and campuses automatically include precise location information, such as room or floor number or the location of the office or desk from which the call originates. Congress directed the agency to take this action as part of the RAY BAUM’S Act adopted earlier this year. The FCC also proposes rules to implement the Kari’s Law Act, also enacted earlier this year. Kari’s Law, which we summarized in a previous
alert, mandates direct 911 dialing.
Implementing Kari’s Law on Direct 911 Dialing Kari’s Law requires that all multi-line telephone systems (MLTS) used in hotels, office buildings or campuses have the capability to do two things: (1) dial 911 directly without having to dial any extra digits; and (2) at the same time a 911 call is made, the telephone system must also notify a security desk or central location or person in the enterprise that a 911 call has been made. The law includes a number of terms and requirements that the FCC proposes to clarify. Among the key proposals are the following;
- The internal notification that a 911 call has been made must occur contemporaneously and must include the fact that a 911 call has been made, a valid call back number and the information about the caller’s location that the MLTS has conveyed to the emergency personnel as part of the 911 call. (This last requirement ties in with the proposal, discussed below, that all MLTS provide location information.)
- The FCC proposes to define an MLTS to include the full range of networked communications systems that serve enterprises, such as over-the-top or cloud-based IP systems, in addition to traditional circuit switched, on-premises PBXs. (The FCC had thought to call these Enterprise Communications Systems (ECS) but will stick with MLTS since that is the term Congress used.)
- Requires companies that make, import, sell or lease MLTS to ensure that those systems are preconfigured to automatically and by default enable direct 911 dialing and provide the required in-house notification.
- Kari’s Law requires persons that install, manage or operate MLTS to configure the system to ensure direct dialing and notification. Installing, managing and operating are somewhat overlapping functions and can be performed by the same person or multiple entities. The FCC proposes more detailed definitions of these functions and would create a presumption that the person that “manages” the MLTS would bear ultimate responsibility for compliance. The MLTS manager is the person responsible for controlling and overseeing implementation of the MLTS after installation, for example, deciding how lines should be distributed, assigning and reassigning telephone numbers, and ongoing network configuration. Often this is done by in-house IT personnel but might also be outsourced to a third-party vendor. The person managing the MLTS is the entity that would likely be fined by the FCC for noncompliance.
- Consistent with Kari’s Law, the effective date for compliance would be Feb. 16, 2020. Thus, any MLTS manufactured, imported, first sold or leased, or installed after that date must be in compliance. The FCC does not propose to require currently installed systems to be modified to come into compliance.
- A number of states already have enacted some version of Kari’s Law and those state laws will remain in force.
