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Better 911 Call Access

Multiline Phone System Interests Seek Changes on Implementing Kari's Law, Ray Baum's Act

Mutliline telephone systems (MLTS) providers and equipment vendors proposed changes in how the FCC implements new laws on better 911 access, in recent ex parte correspondence in docket 18-261. The commissioners are expected to vote Thursday on a draft report and order circulated in mid-July on implementing Ray Baum's Act (see 1902150036) and Kari's Law Act of 2017 (see 1907090047) to provide better location identification to emergency workers who take phone calls from apartment buildings, offices and other multi-unit spaces and to ensure callers who use MLTS phones can reach 911 quickly (see 1812110025).

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According to the FCC, if adopted, "the new rules would provide clarity and specificity" so MLTS companies can meet their obligations under Kari's Law and RAY BAUM's Act. The rules establish dispatchable location requirements for 911 calls from MLTS, fixed telephone service, interconnected VoIP services and telecommunications relay service (TRS), it said in a statement.

APCO International requested changes to the draft order, which it said "would exempt from location requirements the entire embedded base of legacy MLTS." It disagrees with the order's "stated interpretation that applying the requirements on a prospective basis would be consistent with congressional intent." It also said the "current state of location information for MLTS is especially problematic given that the location that is provided today can be very wrong," such as a distant corporation's headquarters. APCO asked the FCC to revise the draft order to "apply the location requirements to legacy MLTS within a reasonable timeframe for compliance." It also wants the FCC to "ensure that its rules do not create significant loopholes, such as permitting providers to make independent determinations of technical feasibility and cost effectiveness."

The TTY-based TRS industry, which offers text-based translation services to the deaf, presents unique challenges in implementing the new requirements, said Hamilton Relay. The company asked the FCC to make a "minor modification" to its draft rule to maintain the status quo for TTY-based emergency calls rather than use a system for incoming emergency calls that allows the caller's dispatchable location information to pass directly to an emergency call center. "TTY-based providers do not have access to, or the ability to generate, dispatchable location information about their TTY users," it said. If the FCC adopts the rule as written, it would require carriers and TRS providers and public service answering points (PSAPs) "to make extensive and costly technology changes to their equipment and networks in order to meet the new requirements without a clear benefit to callers," Hamilton said.

Incompas believes the FCC's proposed approach to dispatchable location information for non-fixed iVoIP "may be impracticable," it said, and it proposed new language for a revised draft. It also asked the FCC to clarify the rules to reflect a two-year compliance deadline.

Microsoft met with FCC officials to highlight remaining challenges to a proposed requirement that non-fixed interconnected VoIP provide "alternative location information" that would be sufficient to identify both an address and the approximate in-building location of a caller, which might include a floor level for large buildings. "While we believe that providing a civic address will be technically feasible for non-fixed iVoIP within the two years provided by the Commission's draft order, providing the floor level within a large building remains technically unfeasible for services that can be used from any location where the user can access the internet," Microsoft said. "A 'z' coordinate is not yet readily available for locating callers using apps on internet-connected devices." Microsoft also said collecting registered location information for the basis of location for iVoIP 911 callers isn't a worthwhile endeavor. To assume that callers remain at their registered location each time they make a call would be risky, it said, "and it should rarely form the basis of 911 location information" provided to a PSAP.

APCO raised concerns that using a so-called z-axis approach wouldn't give public safety professionals vertical location information that's actionable for dispatching first responders. "While some public safety agencies state they have the resources to procure technologies capable of operationalizing an estimated height above mean sea level or a three-dimensional (xyz) point in space, the Commission should ensure that carriers make location information available in a format that is actionable by all 9-1-1 emergency communications centers throughout the nation," it said.

FCC Commissioner Geoffrey Starks and Michael Scurato, his acting aide, met with New York City Information Technology & Telecommunications officials Monday for a tour of the city's Public Safety Answering Center and its Network and Security Operations Center, said a letter filed to docket 18-261.