• by David Chambers, Chief Service Architect, Clearspan

.Ray Baum and Kari’s Law: A Brief Overview

In August 2019, the Federal Communications Commission adopted statutory provisions to improve access to 911 and timely assistance from First Responders in the form of Kari’s Law and Section 506 of RAY BAUM’S Act.

Kari’s Law requires direct 911 dialing capabilities in multi-line telephone systems (MLTS), which are typically found in enterprises such as office buildings, campuses, and hotels. The Commission’s rules also implement the notification requirement of Kari’s Law, which is intended to facilitate building entry by first responders.  When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification. The statute provides that these requirements took effect on February 16, 2020, two years after the enactment date of Kari’s Law.  

Under Section 506 of RAY BAUM’S Act, the FCC 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.  Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated 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.

Two compliance deadlines were defined in the RAY BAUM Act.  The first was January 6, 2021 and covered MLTS services with ‘fixed’ devices.  The far more challenging second  deadline to address MLTS with non-fixed devices is January 6,2021.

MLTS Service with Non-Fixed Devices:  Challenges

Achieving Ray Baum compliance for MLTS service with non-fixed devices, especially in large campus environments with multiple dispatchable locations, presents a variety of challenges that must be overcome.  For example, the same telephone number can appear on more than one telephone (i.e. Shared Line Appearance – SLA) and the telephones can exist in different locations.   These multiple locations may just be an area of a floor, a different floor, a different building, or a different Public Safety Answering Point (PSAP).  In the original E911 service, a PSAP would be able to locate the location of a 911 caller based on a preconfigured entry in an Automatic Location Identification (ALI) database indexed by the caller’s calling party number to provide the static postal address associated with the telephone number.  The ALI database provides a single entry per phone number.  Anytime the same calling party number can originate from multiple locations, there is the potential that the ALI data query could yield an incorrect dispatchable location or result in the PSTN provider sending the 911 call to an incorrect PSAP.

VoIP based MLTS services also brings the element of mobility to both hard phones and softphones, further complicating the selection of the correct PSAP and providing the correct dispatchable location due to the ability of the phone to change physical location without notification.

Aspects to Consider

1. How to map, acquire, and maintain dispatchable location information in a VoIP environment
2. How to differentiate 911 calls from phones with Shared Line Appearances
3. How to ensure that the 911 call from an SLA is routed to the correct PSAP
4. How to get the campus and the PSAP informed as quickly as possible

 

Don’t forget about state specific requirements!

These federal requirements (Section 506 of Ray Baum Act and Kari’s Law) are the bare minimum.  Every company operating in the 50 states must abide by both the federal rules and any state specific requirements.  Several states have additional, state specific 911 legislation that must be addressed when planning for the January 2022 deadline for MLTS service with non-fixed devices .

States with Existing E911 Legislation

Organizations operated across multiple states will need a method to meet each state’s requirements. Given the layers of complexity, we recommend that organizations work with their public safety group, regulatory advisors, and legal teams to understand how these 911 laws and regulations will impact their operations. 

 

Get Started Now!  Recommended Prerequisites

Whether you intend to partner with someone to implement a solution or you plan to handle internally, there are several things you should be doing now to get ready to meet in the January 2022 compliance date.  

 

DISPATCHABLE LOCATIONS

Identify Dispatchable Locations within your environment : We recommended that you start with identifying how many Dispatchable Locations (DL) exist within your environment.  This will be the dispatch information provided to the first responders when a 911 call is made.  An environment may only require a single DL to cover a small single-story location.  Other environments, such as large single-story facilities, multi-story facilities, and campuses, will require multiple DLs to provide adequate location information.  The DL entries should be maintained in an authoritative DL database.

Emergency Response Location (ERL) indexes to the authoritative DL database : We also recommended that you create Emergency Response Location (ERL) identifiers associated with each DL.  For example, the ERL “EHC-2345” could represent a DL assigned to room 2021 on the second floor in the East Hall campus building.  The ERL will be used when a 911 call is made to index into the authoritative DL database to associate the correct Dispatchable Location with the 911 call.

Correlation of your network wire map to the ERL database : Whether your ERL identification/selection for a 911 call is based on the use of the HELD protocol, layer 2 discovery, or some other method, you should maintain a map of your network and associate the ERL information with your network map.  This would include both the wired and wireless access points.  This will allow the detection device movement/relocation and provide an accurate Dispatchable Location with 911 calls.

 

911 CALLBACK EXCEPTIONS

Addressing 911 callbacks for phones without DID numbers :  In the event a 911 call is initiated from a phone that only has an internal extension number, you should identify a DID that can be associated with that extension only phone when a 911 call is made.  This could be an attendant in the same area of the specific phone, a security desk in the local area, or campus police/security.  The associated DID will be the destination for any callbacks from the first responders if the initial 911 call is disconnected.

 

NOTIFICATION OF A 911 CALL

Identify who will receive notifications when a 911 call is made : We recommended that you review and maintain a list of who receives and how they receive notifications for 911 call originations.  This could be in the form of a distribution list that includes multiple email and SMS text destination, desktop alerts, directing the call to campus police/security, or even the bridging the call to both the PSAP and campus security.

We’re Here to Help

If you have questions or want to discuss your specific environment, please feel free to reach out.  We specialize in helping the world’s largest organizations with complex communication and collaboration environments that digitally transform the way they work.  That’s a fancy way of saying we have a lot of experience with complex environments!