"E911" Regulations Will Impact Building Owners, Colleges and Universities
March 25, 2004
Operators of multiline telephone systems (MLTS), such as businesses, hospitals and universities, likely will be affected by a Federal Communications Commission (FCC) order released on December 1, 2003, that encourages states to adopt new 911 regulations. MLTS allow multiline businesses and multitenant buildings to provide service more efficiently by eliminating the need for an external line for each individual telephone within their operation.
The FCC has been considering whether to require MLTS operators to transmit enhanced 911 (E911) information (such as call-back number and specific location information) to the Public Safety Answering Point (PSAP). For example, the FCC could require a caller using a telephone in an MLTS building to call 911, and the call would give the PSAP information on the caller’s exact location (i.e., building location, floor location, and location within the floor).
In its recent order, the FCC chose not to enact nationwide E911 regulations on MLTS at this time, instead deferring MLTS regulations to the state and local governments. The FCC determined that state and local governments are “in a better position” to see that E911 is effectively deployed, and that the “local nature of 911 implementation” supports giving states broad discretion to adopt rules.
However, the FCC’s deference was accompanied by a rather strong warning. If states do not take appropriate steps to ensure MLTS E911 deployment, the FCC will step back into the picture and consider adopting national rules. In fact, the FCC said that it will issue a public notice in a year to monitor the states’ progress, and urged the states to focus attention on setting standards for E911 compatibility on an “expedited basis.” State and local governments are strongly urged to use model legislation proposed by the National Emergency Number Association and Association of Public Safety Communications Officials International, Inc. This model legislation would require MLTS operators to provide information on the precise location of the caller, such as the building and floor location.
Along with the order, the FCC asked for public comments to ensure that it was prepared to take action should the states fail to effectively deploy E911 over MLTS. Specifically, the FCC requested comment on its role in requiring MLTS to deliver call-back and location information, and the value of a national approach should the states fail to act. The FCC also asked for information on the prevalence of MLTS and the status of E911 implementation for MLTS systems. The issue of the growth of IP telephony is also a subject of requested comments – specifically, whether it will affect the manufacture and use of MLTS equipment.
MLTS operators, such as building owners, hospitals, colleges and universities, should be aware of the FCC’s order and the likelihood that the states will require MLTS operators to provide E911 services. As the FCC defers to the states to implement MLTS regulations, it will be important for MLTS operators to monitor developments at the state level and comply with new regulations.
For more information, e-mail Rebecca Duke at rebecca.duke@hklaw.com or call toll free, 1-888-688-8500.