Pace yourself; this is going to be a long read, but NOT as long as the 70 thousand-word FCC Guideline Document on these upcoming changes. Significant changes to the way you do business are starting in just a month. If you would prefer to sit back and listen to this information, you can also sign up for our forthcoming Kari’s Law live webinar, Kari’s Law compliance for FreePBX®️ and other Multi-Line Business Phones Systems.
Similar to The Telecommunications Act of 1996, which required location information transmitted when calling 911 from your cellphone, Kari’s Law and the Ray Baum Act will require the same type of enhancements for users of a multi-line business phone system.
Twenty years ago, during the rollout of enhanced 911 services in the wireless industry, I remembered keenly the significant changes required by hardware manufacturers, service providers, and 911 call centers, also known as Public Safety Answering Points or PSAPs. Initially, wireless carriers needed to provide the location of the cell tower that transmitted the 911 call, which was a smooth implementation by adding a GPS receiver to give the general calling area back to the 911 center. Before this functionality was enabled, I had the experience of working directly with the State Police to pull up carrier system call logs to determine the location and path of travel of a woman that had been kidnapped, shot, and left for dead in the trunk of her car. Luckily, she had her cell phone in her pocket and was able to make a 911 call, but she had no idea where to send help. Thankfully, we were ready to begin tracking her location on the back end after law enforcement presented a warrant, with the position of the towers and specific sectors she called from we could provide a general place to start looking for her. Thankfully she was found in time and survived. However, it would have been optimal for the dispatchers to have that at the moment they were sending help. This information is so vital in an emergency when seconds matter.
In Phase Two of the wireless e911 rollout, phone manufacturers and service providers had to provide a more specific location of the handset. Complying with those requirements back in the day made both winners and losers of the companies that could pull off the technical hurdles to provide this required data.
As an example, Motorola, the most popular phone manufacturer at the time, initially chose to utilize their chipsets when implementing the location requirements for wireless callers. Their first e911 supported phone required over 30 firmware updates to “get it right.” In those days to update your phone, you had to stop by your cell provider’s company store and have a technician update this manually, as there was no such thing as an over the air update. This painful experience for customers meant that wireless carriers and sales reps stopped pushing Motorola devices in place of other manufacturer devices that used a Qualcomm chipset. With the significant decline in sales, Motorola eventually gave in and moved to the Qualcomm chipset, but never really regained the edge they once enjoyed in the marketplace.
The upcoming deadlines for compliance with Kari’s Law and Section 506 of the Ray Baum Act have the same potential to make winners and losers in the VoIP marketplace. So this blog is written first to explain what’s changing, why it’s changing, who is impacted, and then finally how ClearlyIP can assist your business in being on the “winning side” while implementing your support for these requirements.
Who needs to care about Kari’s Law and the Ray Baum Act? Do these laws impact you?
Do you plan on selling, leasing, installing, managing, operating, manufacturing or importing, a Multi-line Telephone Systems “MLTS” after February 16, 2020? If you are reading this blog, the answer is probably yes, and you need to care about this stuff. Compliance with the Law is always a good idea for the apparent ‘legal’ reasons and as some mitigation of legal exposure for non-compliance. It’s also the right thing to do for your end-users and customers, as providing more accurate access and responses to emergencies when you can is just being a good human.
What is the FCC definition of an MLTS?
The FCC definition of “MLTS” or Multi-line telephone system is pretty broad. It includes IP-based telephone systems, VoIP, and outbound-only calling systems including most commercial phone systems on the market, as well as opensource platforms such as FreePBX®️. The only systems not currently required to comply would be internal systems with no expected ability to communicate with 911, such as an internal video conferencing system. The Law specifically applies to:
What are these laws, and how do they impact your business?
The Communication Act of 1934 established the Federal Communications Commission (FCC), an independent US agency responsible for the regulation of interstate and foreign communications by radio, television, wire, and, later, satellite. The FCC has the power to enforce rules, assign judgments, and collect penalties. Kari’s Law and the Ray Baum’s Act amends the Communications Act of 1934 and reauthorizes appropriations for the Federal Communications Commission. As part of this reauthorization, these laws, and subsequent FCC rulemaking, generally require enhancements of how 911 emergency calls and the caller location information transmitted with those calls.
Background and Requirements of Kari’s Law
On December 1, 2013, Kari Reni Hunt, was fatally stabbed by her estranged husband. Kari’s then 9-year-old daughter unsuccessfully tried to call 911 multiple times from her hotel room, not knowing the phone system in place at the hotel required that callers must first dial ‘9’ to reach an outside line. Sadly, her daughter was thus unable to reach emergency responders after trying to call a few times. Kari’s daughter ushered her younger siblings into the hotel hallway. She attempted to get employees to notify emergency services, but, unfortunately, those employees did not speak English, and the messages never made it to the management staff. It took another hotel guest responding to the commotion to get a call out to 911 eventually. Furthering the tragedy, sadly, it’s likely that emergency responders could potentially have saved Kari’s life had they reached her in time.
Kari’s father, Henry “Hank” Hunt, lobbied in his daughter’s name to pass legislation that would standardize and better define how a Multi-Line Phone System would and should call for emergency services. Before his testimony to congress, Hank created a change.org petition, that caught the attention of Mark Fletcher, ENP at Avaya, a long proponent of enhancing e911 location data and services for multi-line telephone systems. Mark used his many industry contacts to eventually get congressional sponsorship of legislation that was signed by the President in February of 2018.
Interestingly, I had an online conversation with Mark Fletcher with Avaya seven years ago on the FreePBX Community Forums, where we discussed the possibility of enhancing support for emergency services in open source communications projects such as FreePBX. (See that conversation here https://community.freepbx.org/t/adding-e911-support/16781/12.) It’s great to see that Mark with Avaya’s support and Hank Hunt’s mission for change were able to see the implementation of these necessary regulations, I congratulate them on their success and sincerely thank them for all the hard work to get Kari’s Law enacted.
So what are the new requirements?
Kari’s Law requires MLTS systems in the United States to enable users to dial 911 directly, without having to dial a prefix to reach an outside line, and to provide for the notification (e.g., to a front desk or security office) when 911 calls happen.
- Your phone system cannot require a prefix for dialing an emergency number; for example, dialing 9 for an “outside line” to reach emergency services is not allowed.
- When placing an emergency call, notifications will be provided to a central monitoring point such as a front desk, on-site management, or security office. There is no current requirement for the Emergency Notification Destination to be continuously staffed or monitored.
Background on Ray Baum Act – Section 506
Repack Airwaves Yielding Better Access for Users of Modern Services Act of 2018
The Ray Baum Act, named after a close friend of US Congressman Greg Walden (Previous Chairman of the Congressional Telecommunications Subcommittee), who drafted the Law for Congress. Raymond Sims Baum (1955-2018) was on the Congressional Energy and Commerce Committee Staff, a longtime friend of Chairman Walden and telecommunication advisor who lost his battle with cancer in February 2018.
Section 506 of the RAY BAUM’S Act requires that a “dispatchable location” is conveyed with 911 calls so that 911 call centers will receive the caller’s location automatically and can dispatch responders more quickly. “Dispatchable location” is defined as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.” A Dispatchable location provided from the emergency responders’ point of view; I like to call it ” information sufficient for guiding first responders to the right door to kick down.”
- Your Phone Systems should provide caller locations from the emergency responders’ point of view, described as the “dispatchable location of the caller.” Meaning that the location is provided so that the emergency responder will know precisely where to go. Instead of sending just the main address such as ‘ClearlyIP University, 2416 Industrial Dr, Neenah, WI 54956’ You can provide a detailed “dispatchable location” ‘ClearlyIP University, Professor Luke’s Office, Room 2402, 2nd Floor, 2416 Industrial Drive, Unit F Neenah, WI 54956’. Of course, for many small businesses, the provision of street address alone will be sufficient.
Just as wireless e911 location services evolved in stages, some rules for providing a dispatchable location will be modified and become stricter over time as technology advances. Currently, the FCC has enacted the easiest to comply with regulations first and laid out timelines to provide more accurate location information for the areas where additional technical development is needed. The current rules apply to ‘ON-Premise’ devices, note that the FCC includes in its definition of on-premise devices that originate from fixed “remote locations” or “remote workers” that have a “regular set place of work.”
On-Premise Fixed Devices – meaning devices that an end-user is not capable of relocating on their own without operational assistance, such as hotel phones, or fixed desk phones, should provide a dispatchable location today.
This includes phones that are capable of “hot desking,” which allow end-users to log into various phone devices to make calls using their credentials and extension information.
Softphones, and mobile devices, used on-premise,– should convey automated dispatchable location when technically feasible. The process may rely on the end-user to provide or confirm the dispatchable location information manually by responding to a system prompt. Over the next two years, this requirement will become stricter, eventually requiring the same level of “knowing which door to kick down” as Fixed Devices. The advances needed in technologies to enable these devices and services to utilize the network or other location services to provide the callers’ precise location automatically. These deadlines will coincide with tighter in-building location requirements for your standard wireless cellular phone services as well, so we may see some overlap in the technologies that will be the basis for this technology.
Calls that do not originate on devices located ‘on-premise’ are going to be much tougher to bring into compliance. – Sending the proper ‘dispatchable locations’ when placing emergency calls, The current FCC guidelines state that within two years (February 2022) that for off-premise calls MLTS operators must utilize the “best-available” location information which consists of:
- Providing a dispatchable location, if technically feasible
- Or may rely on end-users to provide or confirm dispatchable location information manually by responding to a system prompt, Having End-users choose a “dispatchable location” every time they use a device off-premise is very likely to induce “user fatigue” meaning your end users will likely not keep this information accurate or up-to-date
- Or utilize enhanced location information, which may be coordinate-based, consisting of the best available location obtained from any available technology or combination of technologies at a reasonable cost.
These guidelines I suspect will spur many innovations and opportunities for new hardware, software, and services over the next two years as the industry works to comply with these requirements.
What solutions are available from ClearlyIP to assist you with complying with Kari’s Law and the Ray Baum Act? What steps should you take to protect your end users, as well as limit your liability and exposure?
We spent a lot of time considering Kari’s Law and the Ray Baum act when designing our ClearlyIP SIP Trunking platform and IP phone line. We contacted many competitive SIP Trunking providers, and surprisingly many don’t have options to support providing a dispatchable location outside of requiring end-users to purchase additional standard e911 locations plus DIDs associated with each e911 location, growing expensive quickly! Surprisingly some carriers we contacted had never even heard of Kari’s Law or the Ray Baum Act, which was the most startling part of our research.
In addition to the service providers’ ability to support these laws, your PBX manufacturer (both phones and PBX platforms) must also ensure they provide resources needed to support these mandates. Some larger proprietary systems have had the required technology either directly embedded or via third-party add-ons for some time. However, we realized there was not a similar standard solution in the open-source Asterisk®️ / FreePBX®️ space where our team has a wealth of experience. With the prevalence of businesses depending on these platforms, we decided to roll out Trunking Services and Re-Brandable IP Phones with built-in support for the technologies needed to be compliant with Kari’s Law and the Ray Baum Act.
I’ll take the three primary requirements of the Law and provide an overview of our solutions for each.
Requiring a prefix when calling 911 is prohibited – locations with MLTS must remove any requirements to dial ‘9’, ‘8’, or any other prefix to reach 911 and should send the caller location to the nearest PSAP.
ClearlyIP Solution: Configuring your FreePBX based phone system not to require a prefix is a relatively simple modification to the outbound routes on your phone system, and this is generally the most effortless requirement to satisfy. Our ClearlyIP trunking service can be configured automatically with our ClearlyIP Trunking Module for FreePBX. If you are not using FreePBX, our service can work with just about any SIP-enabled phone system on the market. When using the ClearlyIP Trunking module to configure your FreePBX based system, we automatically generate outbound routes for calling 911 without requiring a prefix. Users can test this connectivity by calling 933 to ensure that the outbound route will also properly dial 911 when needed.
911 calls are to be transmitted to the appropriate public safety answering point (PSAP) with a “dispatchable location” information defined as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.” In a typical office environment, this could include building, floor, wing, office, cubicle, or other location information allowing first responders and in-building security personnel to know the exact location of the person calling 911. So, in short, the address sent must be provided from the emergency responders’ point of view.
ClearlyIP Solution: Our SIP Trunking platform allows you to quickly and economically configure multiple Emergency Call-Back Profiles and Emergency Endpoints on your phone system. If you are utilizing FreePBX, our “Clearly Trunking FreePBX Module” easily configures your services and maps your endpoint locations and emergency call back numbers directly within the FreePBX GUI. So when your users place emergency calls, the specific dispatchable location is sent to the proper PSAP (public-safety answering point).
Each ClearlyIP trunking location with at least one Unlimited SIP Trunk includes (1) Emergency Call-Back Profile and (1) Dispatchable location. The Emergency Call-Back Profile provides the company name and call-back number, and the Dispatchable location provides a validated address to the caller for the PSAP. If the validated address cannot determine the proper PSAP, our service will automatically forward the call to the National e911 call center, where the caller will need to provide their location. Users can verify the configuration by dialing 933 to ensure the proper emergency location transmitted.
Additional e911 address locations and e911 endpoints are easily added online, without the need to contact us. We also offer plans that allow you to utilize our e911 services without the Unlimited Voice Subscription, and only pay for your e911 addresses and endpoint locations. With many of our competitors, you will likely have to purchase additional DIDs for each site and map those DIDs to an additional e911 addresses, which is exponentially more costly to you than the platform we are implementing. If not utilizing FreePBX, we will also provide guides on how to configure your existing phone system to use our trunking in compliance with the new laws.
ClearlyIP phones provisioned with the ClearlyIP Device Management module within FreePBX, allow users to “hotdesk” or log in and out of different handsets. When a device doesn’t have an active user logged in, we default it to a profile enabled to call 911 still. Ensuring the proper location is sent to the 911 center.
Manage your FreePBX Extensions Emergency Call-Back Profile and assigned a Dispatchable location directly within the FreePBX GUI.
Allow End Users to control their e911 location options directly from the FreePBX User Control Panel and the screen of their ClearlyIP desktop phone.
ClearlyIP Phone Application
Emergency Notifications must be sent to personnel alerting them to the emergency, and the notification can take the form of phone calls, visual alerts, audible alarms, text messages, or emails. The notification provision mandates that all such MLTS systems must provide a notification to a central location, locally or to another person or organization offsite, such as a front desk or security office, when placing a 911 call.
ClearlyIP Solution – Emergency Notification Destination Points
ClearlyIP SIP Trunking enables our users to define Emergency Notification Destination Points directly on the phone system. The FCC does not require that the notification point be continuously staffed or monitored, only that it be a location where someone is likely to see or hear the notification. Notifications sent will include, (1) The fact a 911 call was placed. (2) A valid call-back number (3) Dispatchable Location of the caller sent to PSAP available notification options include:
- SMS Message – Sent from the phone system to the Emergency Notification Destination Point
- Email to Administrator – Sent from the phone system to the Emergency Notification Destination Point
- Audible Page Group Notification – Configured within the phone system to notify the Emergency Notification Destination Point defined paging group.
These Notification Destinations are configured directly within the ClearlyIP Trunking module in the FreePBX GUI.
We invite you to attend our upcoming webinar, Kari’s Law compliance for FreePBX®️ and other Multi-Line Business Phones Systems or reach out to our sales team to see if these solutions are a good fit for your business. Safety, Compliance, Peace of Mind, and Value with ClearlyIP Trunking!
All trademarks, service marks, trade names, trade dress, product names, and logos appearing on the site are the property of their respective owners.