Society has undergone sweeping changes since on-premise PBX systems were first introduced. In addition, the number of fixed-line devices has steadily declined, whereas the market share of mobile devices has skyrocketed. 911 regulations that were written for a less mobile world are not always suited to today’s communications reality.
As an example:
Every day in the United States, callers place 600,000 calls for emergency response – that’s 240 million per year.
Approximately one-third of U.S. households now rely on a mobile device for their primary service.
In many areas, the overwhelming majority – about 80% - of those 911 calls are from mobile devices.
911 calls through Voice over Internet Protocol (VoIP) have also grown dramatically.
This page will focus on two key USA federal laws which strengthen emergency calling: Kari’s Law and Section 506 of the RAY BAUM’S Act.
This legislation arose from a tragic real-world scenario: in a Texas motel, Kari Hunt lost her life in an attack by her estranged husband. During the attack, Ms. Hunt’s daughter was unable to directly dial 911 from the motel room - the on-premise system expected certain digits to precede 911.
Congress enacted Kari’s Law to ensure that users of a multi-line telephone system (MLTS) can directly dial 911 from within the system, with no special prefixes or other codes. The law also mandates that when an emergency call is placed, a notification be sent to a central location on-site or off-site where someone is likely to see or hear the notification. Notifications must include a valid callback number and are intended to facilitate building entry by first responders. These are potentially life-saving changes.
Note that Kari’s law is prospective only and does not require upgrading MLTSs deployed as of Feb 15, 2020. However, after Feb 16, 2020, independent legal advice should be obtained prior to upgrading any non-compliant systems deployed prior to Feb 15, 2020, as these actions may trigger Kari’s Law requirements.
As with Kari’s Law, under Section 506 of RAY BAUM’S act (Repack Airwaves Yielding Better Access for Users of Modern Services) the Federal Communication Commission has adopted rules that aim to save lives by modifying certain aspects of 911 communications. The RAY BAUM’S rules deal with what’s called a “dispatchable location” – i.e., the physical address to which 911 responders will be sent when someone calls 911 from a certain device.
Whether you are using a fixed-line device (such as a traditional on-premise device/landline) or a non-fixed device (such as a VoIP softphone or IP desk phone), RAY BAUM’S Act aims to ensure that your device is associated with a dispatchable location – so that first responders can find you, even if you cannot speak or confirm your address. Again, this is a legislative change that could save lives.
Now that you are aware of these important changes to legislation, let’s look at what implications they may have for you and your business. The capabilities, roles, and responsibilities vary based on your Mitel product(s), the user device, and the model under which you purchased or sold them. Please find your product(s) under the “Mitel Product Information” section below (click to expand each section). Where applicable, actions for the customer or partner are highlighted.
MiVoice Business PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
Dispatchable locations can be implemented on MiVoice Business using Customer Emergency Services IDs (CESID).
MiVoice Connect PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e., without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
MiVoice MX-ONE PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e., without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
Dispatchable locations for fixed devices can be implemented on MiVoice MX-ONE using Customer Emergency Services IDs (CESID) – also known as ELINs on the MX-ONE (Emergency Location Identification Number).
MiVoice Office 400 PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
MiVoice Office 250 PBXs licensed in the United States contain a setting which allows the customer or partner to enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
Dispatchable locations can be implemented on MiVoice Office 250 using Customer Emergency Services IDs (CESID).
MiCloud Connect deployments enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
E-mail based 911 ancillary (in addition to those covered by Dynamic E911 providers) alerts are enabled on MiCloud Connect deployments in the United States by default. The alerts are sent to the “location emergency contacts.” Each alert contains the caller’s profile (e.g. name, phone number and service location), emergency location registration (e.g. emergency callback number and registered emergency location) and time and date of the call. Alerts are initiated contemporaneously with 911 calls and do not delay the call.
MiCloud Connect will:
MiCloud Flex deployments enable users to directly dial 911 (i.e., without dialing any additional digit, code, prefix, or suffix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN.
As of Feb 16, 2020, phone and console-based 911 ancillary (in addition to those covered by Dynamic E911 providers) alerts consisting of a visual display and a tone are enabled on all new Retail MiCloud Flex deployments in the United States.
Once properly configured, MiCloud Flex will deliver dispatchable location for fixed and non-fixed devices to the PSAP.
Kari’s Law, which came into effect on Feb 16, 2020, places obligations on multiline telephone system (“MLTS, ” which commonly includes PBX) manufacturers, importers, lessors, installers, managers, and operators. Kari’s Law is implemented by rules set out in FCC 19-76, which was released in August 2019.
Persons who manufacture, import, sell, and/or lease a MLTS must ensure that the MLTS software/hardware includes a setting that, when turned on, enables users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or post-fix) from any station equipped with dialing facilities as soon as the system is able to initiate calls to the Public Switched Telephone Network (“PSTN”).
Persons who install, manage and/or operate a MLTS must configure the MLTS’ settings so that once installed the MLTS is fully capable of:
FCC 19-76 does not prohibit indirect dialing of 911 (e.g. 9911) provided that direct 911 is also enabled.
Kari’s law is prospective only and does not require upgrading MLTSs deployed as of Feb 15, 2020. However, after Feb 16, 2020, independent legal advice should be obtained prior to upgrading) any non-compliant systems deployed prior to Feb 15, 2020 as these actions may trigger Kari’s Law requirements.
Mitel is typically the installer, manager, and operator (the operator role is typically shared with customer) of its retail cloud solutions.
Mitel partners or customers are typically the installer, manager and/or operator of partner delivered plus (or wholesale) cloud MLTS solutions and on-premise MLTS solutions.
FCC 19-76 details specific 911 call notification requirements. Both these requirements, and Mitel product documentation, should be reviewed carefully by any person engaged in the business of installing, managing and/or operating an MLTS prior to installation and/or operation. Mitel recommends that partners and customers installing, managing or operating a partner delivered plus cloud MLTS or on-premise MLTS ensure that they have a clear understanding of our technology and obtain independent legal advice in respect of Kari’s Law.
Mitel recommends upgrading systems which do not comply with Kari’s Law as a best practice.
FCC page on Kari’s Law and RAY BAUM’S Act: https://www.fcc.gov/mlts-911-requirements
RAY BAUM’S Act required the FCC to conclude a proceeding to adopt rules to ensure that a “dispatchable location” (see FAQ for more details) is conveyed with 911 calls regardless of the technological platform used, including MLTS. The FCC conducted such a proceeding and the resulting order, FCC 19-76, was released in August 2019.
The new rules affect fixed and non-fixed devices attached to both interconnected VoIP (“iVoIP”) services and MLTS systems. In both cases, where technically feasible, an automated dispatchable location must accompany all 911 calls initiated from fixed and non-fixed devices (see FAQ for definitions) by January 6, 2021, and January 6, 2022, respectively.
Where a call is initiated from a fixed device attached to either a MLTS or a VoIP system, an emergency address collected at time of provisioning and stored in a database is considered to be an automated dispatchable location (provided that the customer can update such address in a timely manner and at will.).Where a call is initiated from a non-fixed device, the MLTS and VoIP rules differ but both aim to have the automated dispatchable location generated in real time based on the user’s location. Details can be found at 47 CFR Part 9.
Similar to Kari’s Law, the MLTS dispatchable location rules are prospective only and do not require upgrading MLTS systems deployed as of Feb 15, 2020. However, after Feb 16, 2020, independent legal advice should be obtained prior to upgrading any non-compliant system deployed prior to Feb 15, 2020 as these actions may trigger the MLTS dispatchable location rule requirements.
In its provision of retail UCaaS services, Mitel acts as an interconnected VoIP (IVoIP) service provider (see FAQ for definition).
Under this model, the partner is considered to be running an iVoIp service. Dispatchable locations for fixed devices can be implemented using CESIDs. It is the partner’s legal responsibility to determine the number of CESIDs which are required to present a dispatchable location with each 911 call and ensure that the requisite CESIDs are appropriately configured (and registered with the PSAP). Customer or partner are free to implement automated dispatchable location using an alternative methodology.
As between Mitel and partner, it is partner’s legal responsibility to implement dispatchable location for its customers and Mitel requires all partners to do so immediately.
Mitel would be pleased to provide partners with configuration assistance pursuant to a professional services engagement, if desired.
Mitel recommends its customers and partners obtain independent legal advice to properly understand their Dispatchable location requirements.
See Product Information section for Details.
Mitel considers purchases of on-premise PBXs (with or without SIP trunks) to be purchases of a MLTS and not an IVoIP service. Current generation Mitel MLTS can be configured to provided automated dispatchable location. Identification and configuration of dispatchable location is customer and/or partner’s responsibility, as Mitel does not typically operate the MLTS. If Mitel operates your MLTS please contact Mitel directly. Customer’s should reach out to their partners as required. Mitel would be pleased to provide (A) customers and partners with configuration assistance pursuant to a professional services engagement, if desired, (B) CESIDs for with SIP trunks purchased from Mitel at standard pricing. Where 3rd party SIP trunks are involved, CESIDs must be obtained from the 3rd party SIP provider.
Mitel recommends that legacy MLTSs be updated and configured to provide dispatchable location for all devices as a best practice. Customers and partners should obtain independent legal advice to properly understand their Dispatchable location requirements.
Dispatchable location product information is found in the Product Information section above.
FCC page on Kari’s Law and RAY BAUM’S Act: https://www.fcc.gov/mlts-911-requirements
For MiCloud Connect and ShoreTel Sky documentation related to Dynamic E911, please visit OneView.
For MiCloud Flex, MiCloud Business and all Mitel On-Site Product and Solution Documentation related to Dynamic E911, please visit the Document Center.
As of Feb 16, 2020, notice of a 911 call to a central (or other location) will be enabled for all new Mitel retail cloud solutions capable of doing so. If you instruct Mitel to turn this feature off, Mitel will comply with your request, however any legal liability related to Kari’s Law will lie with your organization, not Mitel. Mitel recommends that you obtain independent legal advice prior to advising Mitel to turn off this feature.
The FCC defined a fixed device as a device which cannot be moved by the user without administrative intervention. Non Fixed devices are devices that the end user can move from one endpoint to another without assistance. In Mitel’s view, fixed devices include any analog (or digital) phone which is plugged into a traditional telephone jack which, through fixed in-building wiring (e.g. within floors, ceilings, walls etc.), uses an analog telephone adapter device, or similar, to connect to the IVoIP Service or MLTS. Mitel considers the following to be non-fixed devices: (1) Internet Protocol (“IP”) phones which can connect to the VoiP Services or MLTS through any office ethernet jack or wireless network, (2) teleworker enabled IP phones, or (3) softphones operating on desktop, laptop or mobile devices.
The FCC states “dispatchable location means a location delivered to the public safety answering point (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.” In other words, it is a validated address – not just street address, but all other necessary information – that emergency services could use to accurately and efficiently locate the person who placed the emergency call.
The FCC defines MLTS as follows: “MLTS are communications systems typically used in enterprise settings such as hotels, offices, and campuses. Under Kari’s Law and RAY BAUM’S Act, an MLTS is defined as ‘a system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems (as classified by the Commission under part 68 of title 47, Code of Federal Regulations), and includes systems owned or leased by governmental agencies and non-profit entities, as well as for profit businesses.’ As interpreted by the Commission, this definition of MLTS covers the full range of networked communications systems that serve enterprises, including IP-based and cloud-based systems. It also includes outbound-only MLTS that allow users to make 911 calls but do not enable public safety answering points (PSAPs) to place a return call directly to the 911 caller.”
The FCC defines Interconnected VoIP service as:
THIS DOCUMENT (AND ANY UPDATE(S) PROVIDED BY MITEL) MAY CHANGE FROM TIME TO TIME AND IS CURRENT ONLY AS OF THE DATE LAST UPDATED. PLEASE VISIT MITEL'S PORTAL FOR THE MOST RECENT LATEST VERSION. THIS DOCUMENT IS INFORMATIONAL ONLY AND IS NOT LEGAL ADVICE. THE CONTENTS ARE "AS IS" AND WITHOUT WARRANTY. IN NO EVENT SHALL MITEL NETWORKS CORPORATION OR ANY OF ITS AFFILIATES HAVE ANY LIABILITY ARISING FROM OR RELATING TO THE INFORMATION CONTAINED HEREIN. MITEL RECOMMENDS THAT YOU OBTAIN YOUR OWN LEGAL ADVICE ON KARI'S LAW AND FCC 19-76.
Updated January 24, 2022.