911 Law: What it REALLY Means

Having focused on emergency services and 911 calling for the past several decades in my career and my participation in several legislative initiatives, such as Kari’s Law and the RAY BAUM’S Act, I’ve learned that the definitions of specific words define the meaning and teeth behind the law. Case in point, when RAY BAUM’S Act was initially introduced, the term “dispatchable location” had not been clearly defined. Did it mean the cubicle or office? Did it mean the street address of the building? Did it mean the floor or zone inside of the building? As initially written, a Dispatchable Location could have meant anything with no specific definition assigned to it.

During my day-to-day interactions with customers, I am often asked, “What exactly is a dispatchable location?” Each time, the answer I give is identical. “the US Code of Federal Regulations under 47 CFR 9.3 defines a ‘Dispatchable location as 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 identify the location of the calling party adequately”.

Pretty straightforward, right? Not so fast. Did you know that a 911 call is also explicitly defined? It certainly is, and that definition is found under 47 CFR 9.3 “911 calls”This leads to another question I often get. “Do I need to do anything with the new 988 Lifeline number?” Today, at least, that answer is a flat NO. While indeed a good idea and one that is proactive in aiding with a potential emergency, language similar to the definition of 911 for 988 doesn’t exist . . . yet.

To provide a little guidance, I’ve curated the following reference to some standard definitions focused on MLTS in the Enterprise as defined in the CFR Title 47. You will find this helpful when interpreting legislative text on this issue. Of course, while this is a handy reference during your research, for any serious matters, you should enlist the services of an attorney to review anything before formalizing any policy. I will also caveat that with the need to contract with not just any attorney but one who understands telecommunications-related issues and is willing to research the current facts and trends, as this topic is currently very dynamic. Over the years, I have dealt with legislative issues, especially with Kari’s Law; Attorney Martha Buyer remains number one on my speed dial list, and there is not too much I don’t run past her. While she has taught me a considerable amount of legal common-sense, and I have double-checked her on technical functionality and facts, we both agree – she is NOT an engineer, and I am NOT an attorney. In all seriousness, I can’t thank her enough for the assistance and guidance she’s provided over the last decade or more!

Not only can you find Martha’s articles in No Jitter, but she is also the resident attorney advisor for the Society of Communications Technology Consultants. A great group of individuals that takes 911 consulting very seriously and has identified a core group of individuals dealing specifically with the topic with representation both in the US and Canada. Find SCTC on the web HERE.

THE DEFINITIONS

47 CFR 9.3 “911 calls”

Any call initiated by an end user by dialing 911 for the purpose of accessing an emergency service provider.

47 CFR 9.3 “Alternative location information”

Location information (which may be coordinate-based) sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings.

47 CFR 9.3 “Appropriate local emergency authority”

An emergency answering point that has not been officially designated as a Public Safety Answering Point (PSAP), but has the capability of receiving 911 calls and either dispatching emergency services personnel or, if necessary, relaying the call to another emergency service provider. An appropriate local emergency authority may include, but is not limited to, an existing local law enforcement authority, such as the police, county sheriff, local emergency medical services provider, or fire department.

47 CFR 9.3 “Configured”

The settings or configurations for a particular MLTS installation have been implemented so that the MLTS is fully capable when installed of dialing 911 directly and providing MLTS notification as required under the statute and rules. This does not preclude the inclusion of additional dialing patterns to reach 911. However, if the system is configured with these additional dialing patterns, they must be in addition to the default direct dialing pattern.

47 CFR 9.3 “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.

47 CFR 9.3 “Improvement to the hardware or software of the system”

An improvement to the hardware or software of the MLTS, including upgrades to the core systems of the MLTS, as well as substantial upgrades to the software and any software upgrades requiring a significant purchase.

47 CFR 9.3 “MLTS notification”

An MLTS feature that can send notice to a central location at the facility where the system is installed or to another person or organization regardless of location. Examples of notification include conspicuous on-screen messages with audible alarms for security desk computers using a client application, text messages for smartphones, and email for administrators. Notification shall include, at a minimum, the following information:

(1) The fact that a 911 call has been made;

(2) A valid callback number; and

(3) The information about the caller’s location that the MLTS conveys to the public safety answering point (PSAP) with the call to 911; provided, however, that the notification does not have to include a callback number or location information if it is technically infeasible to provide this information.

47 CFR 9.3 “Multi line telephone system or MLTS”

A system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems (as classified by the Commission under part 68 of title 47, Code of Federal Regulations), and includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.

47 CFR 9.3 “Person engaged in the business of installing an MLTS”

A person that configures the MLTS or performs other tasks involved in getting the system ready to operate. These tasks may include, but are not limited to, establishing the dialing pattern for emergency calls, determining how calls will route to the Public Switched Telephone Network (PSTN), and determining where the MLTS will interface with the PSTN. These tasks are performed when the system is initially installed, but they may also be performed on a more or less regular basis by the MLTS operator as the communications needs of the enterprise change. The MLTS installer may be the MLTS manager or a third party acting on behalf of the manager.

47 CFR 9.3 “Person engaged in the business of managing an MLTS”

The entity that is responsible for controlling and overseeing implementation of the MLTS after installation. These responsibilities include determining how lines should be distributed (including the adding or moving of lines), assigning and reassigning telephone numbers, and ongoing network configuration.

47 CFR 9.3 “Person engaged in the business of manufacturing, importing, selling, or leasing an MLTS”

A person responsible for the day-to-day operations of the MLTS.

47 CFR 9.3 “Person engaged in the business of operating an MLTS”

A person responsible for the day-to-day operations of the MLTS.

47 CFR 9.3 “Pre configured”

An MLTS that comes equipped with hardware and/or software capable of establishing a setting that enables users to directly dial 911 as soon as the system is able to initiate calls to the public switched telephone network, so long as the MLTS is installed and operated properly. This does not preclude the inclusion of additional dialing patterns to reach 911. However, if the system is configured with these additional dialing patterns, they must be in addition to the default direct dialing pattern.

47 CFR 9.3 “Public safety answering point or PSAP”

An answering point that has been designated to receive 911 calls and route them to emergency services personnel.

47 CFR 9.3 “Registered Location”

The most recent information obtained by a provider of interconnected VoIP service or telecommunications relay services (TRS), as applicable, that identifies the physical location of an end user.

47 CFR 9.3 “Statewide default answering point”

An emergency answering point designated by the State to receive 911 calls for either the entire State or those portions of the State not otherwise served by a local PSAP.

By no means is this list intended to be complete or exhaustive. It is merely a starter list highlighting the complexities that can, and like will, exist from a legislative perspective. Once again, I must reiterate I’m not an attorney, and I don’t play one on TV. I DO understand communications, have been a certified NENA Emergency Number Professional for 14 years, and hold a position on the NENA Institute Board. 911 may be the most important phone call you ever make, and it must go through correctly the FIRST time, EVERY time.

Remember to follow me on Twitter @Fletch911, my posts, and articles are on LinkedIn, and I also have a page on Facebook.

Fletch

Follow me on Twitter @fletch911

My Linkedin Profile is available here

I am also active on Facebook here

I am also a candidate for the NENA Northeast Regional Director
with Elections in March 2023 – Visit my campaign Page HERE

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