911 Services Requirement

Written by Orin Horowitz

December 29, 2021

As of August 2019, the Federal Communications Commission (FCC) announced the implementation of two federal laws which are intended to improve the emergency calling process. The two laws at play are Kari’s Law and Section 506 of RAY BAUM’s Act.

“Kari’s Law” – Direct Dialing and Notification for MLTS

Enacted by Congress in 2018, Kari’s Law is in response to Kari Hunt who was murdered by her estranged husband in a motel room back in 2013. Hunt’s daughter attempted to place a call to 911 several times not realizing that the system she was using required a “9” before any outbound call. The law itself mandates direct 911 dialing and “notification capabilities” in multi-line telephone systems (MLTS). MLTS are found in office buildings, campuses, and hotels to name a few. The statute created by Congress states that these requirements took effect as of February 16, 2020 making the date of compliance February 17, 2020.

The statute and FCC’s rules mandate that manufacturers and vendors must program MLTS systems to support direct dialing. This enables the user to dial 911 without the need for dialing any prefix or access codes, such as the number 9 in Ms. Hunt’s unfortunate scenario.

RAY BAUM’S Act – Dispatchable Location for MLTS

The FCC has adopted rules to “ensure that “dispatchable location” is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from MLTS”. The dispatchable location is delivered to the PSAP (Public-Safety Answering Point) via a 911 call and holds information pertinent to response such as “validate 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.) 

The compliance dates may vary depending on the device from which the MLTS 911 call is originating but are January 6, 2021 and January 6, 2022. The “dispatchable location rules” for MLTS apply to ALL MLTS that are “manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020”.

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