Multiline Telephone Systems and 911 Caller Location - Room for Improvement?

At Congress’s direction, FCC explores feasibility of more precise caller-location capability for 911 calls from MLTSs.

When you make an emergency call to 911, it’s helpful – and often crucial – for the person on the receiving end to be able to figure out where the call is coming from, particularly if you the caller can’t speak or aren’t familiar with your surroundings.  The receiving operator, stationed at a Public Safety Answering Point (PSAP), generally sees both the number from which the incoming call is made and the address associated with that number in a database available to the PSAP.  This occurs through the magic of Automatic Number Identification, similar to the Caller ID system with which we’re all familiar.  Even cellphones must report their location to the PSAP, meeting FCC-prescribed accuracy standards.

But if the 911 call is made from a phone system that operates through multiple extensions (including Centrex, VoIP, PBX, hybrid, and key systems) – systems referred to as Multi-Line Telephone Systems (MLTSs) – the magic may not work.  MLTSs, used by businesses and institutions, usually use shared outgoing trunks that may not even have a conventional phone number and are tied only to the location of the central phone system and not the location of the calling extension.  So when a 911 call comes in from an MLTS, the PSAP must hope that the caller can report his/her location and callback number.  Without input from the caller, the PSAP operator may know only the general location of the business or institution, but not the particular room, floor, or even building from which the call is coming.

It doesn’t do a lot of good to send an ambulance to a university campus if you don’t know where on the campus to look for the patient.

This is not a new problem.  Historically, the Commission has been inclined to buck the MLTS  problem to state and local governments, which the FCC felt to be “in a better position to devise rules for their jurisdictions”.  But Congress had different ideas.

As part of the sweeping Middle Class Tax Relief and Job Creation Act signed into law in February, Congress enacted the Next Generation 911 Advancement Act of 2012.  That provision directed the FCC to take a look at the feasibility of requiring MLTS manufacturers to include

within all [MLTS] systems manufactured or sold after a date certain, to be determined by the Commission, one or more mechanisms to provide a sufficiently precise indication of a 9-1-1 caller’s location, while avoiding the imposition of undue burdens on MLTS manufacturers, providers, and operators.

The new law also required the FCC to seek comment on model legislation drafted by the National Emergency Number Association (NENA).  (The full title of that model legislation is “Technical Requirements Document On Model Legislation E9-1-1 for Multiline Telephone Systems.”)

The FCC has dutifully responded with a public notice requesting comment on both the questions posed by Congress.

So far, the inquiry as framed by Congress in the Act and the FCC in its public notice is directed exclusively to newly manufactured MLTSs.  There is no suggestion that existing systems should be retrofitted.  Nevertheless, large businesses and institutions using MLTSs – universities providing phone service to dormitories spread out across a wide campus, as an example – should probably consider how to react if the FCC were to adopt regulations, even if those regs are prospective-only.  The adoption of such standards may encourage such entities to accelerate the replacement of their MLTSs.  Why?  To avoid any possible negligence claim if a person somewhere on the premises of the business or institution were to call 911 but not be locatable in time by first responders because of the technical shortcomings of the older MLTS

The FCC has set deadlines for responses to the public notice: July 5, 2012 for comments, August 6, 2012 for replies.

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