FCC Adopts 9-1-1 Rules for MLTS
Friday, August 02, 2019 | Comments

The FCC adopted rules to help ensure that people who call 9-1-1 from multi-line telephone systems (MLTS) — which commonly serve hotels, office buildings, and campuses — can reach 9-1-1 and be quickly located by first responders. The new rules will also improve emergency response for people who call 9-1-1 from other calling platforms.

The policy implements two laws enacted last year that are designed to strengthen emergency calling. Kari’s Law, requires MLTS equipment to enable users to dial 9-1-1 directly, without having to dial a prefix such as a “9” to reach an outside line. Kari’s Law also requires MTLS to provide notification, such as to a front desk or security office, when a 9-1-1 call is made in order to facilitate building entry by first responders.

Second, Section 506 of RAY BAUM’S Act requires the FCC to consider adopting rules to ensure that “dispatchable location” information, such as the street address, floor level and room number of a 9-1-1 caller, is conveyed with 9-1-1 calls, regardless of the technological platform used, so that first responders can be quickly dispatched to the caller’s location. The new rules apply dispatchable location requirements to MLTS, fixed telephone service, interconnected VoIP services, Telecommunications Relay Services and mobile texting services. Mobile wireless services are already required to provide either dispatchable or coordinate-based location information with 9-1-1 calls.

In addition, the commission consolidated its 9-1-1 rules from multiple rule parts into a single rule part, making it easier for stakeholders, such as service providers and emergency management officials, to more easily ascertain 9-1-1 requirements.

FCC Commissioners Jessica Rosenworcel and Geoffrey Starks approved the rules in part and dissented in part. Rosenworcel said the MLTS rules don’t go far enough because they don’t require businesses already operating a MLTS to change their systems. The rules kick in for MLTS equipment beginning in February 2020.

“So I dissent in part because we do not adopt any requirements for enterprises to inform callers about the 9-1-1 limits of their phone systems, because we do not provide any guidance about when upgrades to existing phone systems will trigger the rules we adopt today, and because we exempt the embedded base of millions of MLTS from complying with location requirements,” she said.

The Association of Public-Safety Communications Official (APCO) International also criticized the rules because the entire embedded base of legacy MLTS are exempted from location requirements. In an ex parte filing before the rules passed, APCO also said the FCC should place bounds on loopholes that permit providers to make independent determinations of technical feasibility and cost effectiveness, and require warning labels or other ways for providers to inform enterprises and end users that their products will not provide an accurate location when dialing 9-1-1.

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