New Multi-Line Telephone Systems at All Businesses Now Subject to FCC 9-1-1 Requirements

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Over the last 20 years, the Federal Communications Commission (FCC) has implemented many rules to ensure that emergency calls reach 9-1-1 dispatch centers. Initially, these requirements covered calls that individual consumers placed from their own landline or mobile phones, significantly improving dispatch centers’ ability to deliver critical emergency response services in a timely manner. In many instances, the improvements were life-saving tools, providing critical information when a caller was unable to verbally communicate his or her location, such as when a call was dropped or discontinued and could not be reestablished.

Most recently, the FCC has applied 9-1-1 requirements to multi-line telephone systems (MLTS) installed by virtually all businesses, educational institutions and other establishments. First adopted in 2019, the MLTS rules have gone into effect on a graduated schedule, with the final rules becoming effective last year on January 6, 2022.

MLTS include a widely embedded base of legacy private branch exchange (PBX), Centrex, and key telephone systems, as well as IP-based systems and hybrid systems. MLTS serve millions of employees, residents and guests at all types of businesses, educational institutions, hotels, office parks, hotels and planned community developments. These systems can support anywhere from 10 to thousands of telephone numbers.

In the past, emergency calls from MLTS stations generally provided dispatch centers with only the telephone number or circuit number of the systems' outgoing trunk, and not the emergency caller's individual device number. In some cases, the MLTS device that placed the call would not even have had its own telephone number. As a result, dispatch centers often found that they were unable to match an MLTS emergency call to the actual source from which it originated within a large facility.

Under the new rules, existing MLTS systems are "grandfathered" and do not need to be immediately replaced or upgraded to meet the new requirements; however, any business that now replaces or significantly modifies its MLTS must meet the new requirements for all devices "connected to" its system -- no matter whether they are fixed desk phones; non-fixed devices, such as laptops or mobile phones used on a company's premises, or non-fixed devices used off-premises -- that is, any place that an employee may engage in remote work, such as at home or at a coffee shop. Companies that keep their existing systems but add devices with remote capabilities to their networks will need to make sure that not only are the new parts of their systems compliant but also evaluate whether the existing or "legacy" equipment needs to be updated as well.

The specific MLTS requirements are drawn from Kari's Law of 2017 and RAY BAUM'S Act, which was passed by Congress in 2018. (RAY BAUM'S is an acronym for Repack Airwaves Yielding Better Access for Users of Modern Sciences.) Kari's Law is named in honor of Kari Hunt, who was killed by her estranged husband in a motel room in Marshall, Texas in 2013. Ms. Hunt's nine-year-old daughter tried to call 9-1-1 for help four times from their motel room phone, but the call never went through because she did not know that the motel's phone system required dialing "9" for an outbound line before dialing 9-1-1.

Kari's Law and the FCC's implementing regulations require manufacturers and vendors of MLTS to pre-configure their systems to support direct dialing of 9-1-1, so that a user does not need to add any prefix or access code, such as the number "9." Then, MLTS installers, managers and businesses operating these systems must ensure that, once they are in place, they support 9-1-1 direct dialing.

Kari's Law and the FCC's rules also include a second requirement to help ensure first responders can gain access to the premises after a 9-1-1 call is placed on a MLTS. The system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. Acceptable forms of such notification include conspicuous on-screen messages with audible alarms for security desk computers, text messages for smartphones and emails to administrators.

These notifications sent to an MLTS owner's central location must include three components: the fact that a 9-1-1 call has been made, a valid callback number, and information about the caller's location. The FCC recognized that manufacturing or installing equipment that provides a callback number or location information to the central location can prove very challenging, so it has provided an exception to the central notification requirement if the MLTS operator can demonstrate that it is technically infeasible for particular devices or the system to provide a callback number or location information.

Under RAY BAUM'S Act, the FCC has adopted a third requirement to ensure that "dispatchable location" is conveyed with 9-1-1 calls to dispatch centers. The "dispatchable location" requirement means that even more detailed information must be delivered to the first responders' dispatch center with every 9-1-1 call. The information must include the validated street address of the calling party, plus a suite or apartment number or similar information that adequately identifies the calling party's whereabouts within the larger building. Just as with the requirement under Kari's Law for devices to notify a business' central location when they call 9-1-1, the "dispatchable location" requirement also has a "technical infeasibility" exception for non-fixed devices, whether used on the business' premises or not. With recent improvements in technology, however, it is becoming harder and harder for businesses that need to update or replace their MLTS to argue that the 9-1-1 requirements are "technically infeasible."

In the little over a year that the FCC's full complement of MLTS 9-1-1 rules have become effective, there have not been publicly reported enforcement cases in which the FCC has pursued or sanctioned a non-compliant MLTS system. In the coming months, however, the FCC can be expected to take any violations that it uncovers very seriously, particularly if they come to light in an emergency situation in which first responders were unable to properly assist a victim because of deficiencies in the MLTS system over which the emergency call was placed.

This column was written by Anne Swanson, Partner, Wilksinson Barker Knauer, DC.

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