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Dynamic E911

Dynamic E911 is a series of technologies and initiatives to update and improve the 911 communications infrastructure and standards. The aim is to improve public emergency communications services, by adapting to modern users’ increasingly mobile and wireless usage patterns.
Product Information Kari's Law Ray Baum's Act Documentation FAQ

Why is Dynamic E911 needed?

 

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:

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.

Kari’s Law

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.

RAY BAUM’S Act

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.

What it means for you

 

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.

Mitel Product Information

Mitel On-Site Solutions

  • Kari’s Law

    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.

    • MiVoice Business PBXs licensed in the United States can be configured by the customer or partner to provide phone and console-based 911 ancillary alerts (in addition to those covered by Dynamic E911 providers) consisting of a visual display and a tone.
    • The ancillary alert is capable of being sent to as many as 32 phones and consoles chosen by the customer. The alert, which is system wide, contains the time and date of the call, the caller’s extension number as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call. For deployments with broader notification requirements, we recommend using Mitel Revolution, which provides additional 911 alert functionality. Mitel Revolution can be purchased separately.
    • Mitel recommends that 911 alerts be enabled in all MiVoice Business PBXs. Customers or partners currently using MiVoice Business PBXs without 911 alerts are encouraged to enable alerts at this time.

    Dispatchable Location

    Dispatchable locations can be implemented on MiVoice Business using Customer Emergency Services IDs (CESID).

    • It is customer’s or partner’s responsibility to determine the number of CESIDs which are required to represent a dispatchable location with each 911 call and ensure that the requisite CESIDs are appropriately configured in the MiVoice Business system (and registered with the PSAP).
    • The method of providing a dispatchable location via a Dynamic E911 partner varies depending on device type and network location, but in most cases an additional SIP-based Emergency Routing Service is required to place 911 calls and a Location Information Service is also required for validated addressing requirements. Further technical information will be made available in a forthcoming solutions guide.
    • For MiVoice Business partners and customers, Mitel’s tested Dynamic E911 partners (providing Emergency Routing Service and Location Information Services) at time of publishing, are Intrado or RedSky.
    • Soft phones external to the customer’s network will require the use of a geolocation application as provided by RedSky or Intrado.

  • Kari’s Law

    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.

    • The MiVoice Connect PBX does not natively support notice to a central (or other location) when 911 is dialed.
    • To enable notifications for simpler deployments, we recommend using Mitel’s Emergency Notification app for MiVoice Connect (the app is free for up to 5 alertees).
    • For deployments with broader notification requirements, we recommend using Mitel Revolution, which provides additional 911 alert functionality. Mitel Revolution can be purchased separately for use with MiVoice Connect.

    Dispatchable Location

    • Dispatchable locations for fixed devices can be implemented on MiVoice Connect using CESIDs.
    • It is customer’s or partner’s (as the case may be) 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 in the Mitel MLTS (and registered with the PSAP).
    • For non-fixed devices deployed on-site—IP phones, for example—MiVoice Connect will enable mapping of CESIDs to IP address ranges that must be maintained by the administrator.
    • For non-fixed devices like softphones (including the Connect Client), customers will be required to engage with a third party 911 provider to manage and ensure that a user’s location can be properly identified and passed to the PSAP.
    • Customers and partners are free to implement automated dispatchable location using an alternative methodology.

  • Kari’s Law

    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.

    • MiVoice MX-ONE PBXs licensed in the United States can be configured by the customer or partner to provide console-based 911 ancillary (in addition to those covered by Dynamic E911 providers) alerts consisting of a visual display and a tone.
    • Mitel recommends that 911 alerts be enabled in all MiVoice MX-ONE PBXs. Customers or partners currently using MiVoice MX-ONE PBXs without 911 alerts are encouraged to enable alerts at this time.
    • In addition, SNMP Traps can be sent to an external management frameworks or mass notification systems to provide ancillary alerting mechanisms to phones and other medias. For deployments with broader notification requirements, we recommend using Mitel Revolution, which provides additional 911 alert functionality. Mitel Revolution can be purchased separately.

    Dispatchable Location

    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).

    • It is customer’s or partner’s (as the case may be) 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 in the Mitel MLTS (and registered with the PSAP).
    • The method of providing a dispatchable location via a Dynamic E911 partner varies depending on device type and network location, but in most cases an additional SIP-based Emergency Routing Service is required to place 911 calls and a Location Information Service is also required for validated addressing requirements. Further technical information will be made available in a forthcoming solutions guide.
    • For MiVoice MX-ONE partners and customers, Mitel’s validated Dynamic E911 partners (providing Emergency Routing Service and Location Information Services) at time of publishing, are Intrado or RedSky.
    • Soft phones external to the customer’s network will require the use of a geolocation application as provided by RedSky or Intrado.

  • Kari’s Law

    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 400 PBXs licensed in the United States can be configured by the customer or partner to provide phone and console-based 911 ancillary (in addition to those covered by Dynamic E911 providers) alerts consisting of a visual display and a tone. The alert is capable of being sent to as many as 32 Mitel SIP phones and consoles chosen by the customer.
    • The alert, which contains caller name, the caller’s internal extension number, as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call.
    • Additionally, a 911 notification email including caller name, extension number as well as a configurable description of the caller can be enabled. Emails are initiated contemporaneously with a 911 call, and do not delay the call.
    • Mitel recommends that 911 alerts and emails be enabled in all MiVoice Office 400 PBXs. Customers or partners currently using MiVoice Office 400 PBXs without 911 alerts and emails are encouraged to enable alerts and emails at this time.

    Dispatchable Location

    • Dispatchable locations for fixed devices can be implemented on MiVoice Office 400 using CESIDs.
    • It is customer’s or partner’s (as the case may be) 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 in the Mitel MLTS (and registered with the PSAP).
    • Teleworker functionality is not supported in the US and licenses are not available for purchase.
    • Customer or partner are free to implement automated dispatchable location using an alternative methodology.

  • Kari’s Law

    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.

    • MiVoice Office 250 PBXs licensed in the United States can be configured by the customer or partner to provide 911 ancillary (in addition to those covered by Dynamic E911 providers) alerts consisting of a visual display and a tone on consoles and phones designated as “administrator phones”.
    • The alert, which contains the time & date of the call, the caller’s name and extension number, is initiated contemporaneously with a 911 call, and does not delay the call. Additionally, a 911 notification email including caller name and extension number can be enabled. Emails are initiated contemporaneously with a 911 call, and do not delay the call.
    • Mitel recommends that 911 alerts and emails be enabled in all MiVoice Office 250 PBXs. Customers or partners currently using MiVoice Office 250 PBXs without 911 alerts are encouraged to enable alerts at this time. For deployments with broader notification requirements, we recommend using Mitel Revolution, which provides additional 911 alert functionality. Mitel Revolution can be purchased separately.

    Dispatchable Location

    Dispatchable locations can be implemented on MiVoice Office 250 using Customer Emergency Services IDs (CESID).

    • It is customer’s or partner’s responsibility to determine the number of CESIDs which are required to represent a dispatchable location with each 911 call and ensure that the requisite CESIDs are appropriately configured in the MiVoice Office 250 system (and registered with the PSAP).
    • It is also customer’s or partner’s responsibility to properly configure devices and network equipment so that MiVoice Office 250 system can associate the appropriate CESID with an emergency call.
    • A customer may need to use a Dynamic E911 partner depending on device type and network location, and in that case, an additional SIP based Emergency Routing Service is required to place 911 calls and a Location Information Service is also required for validated addressing requirements. Further technical information will be made available in a forthcoming solutions guide.
    • For MiVoice Office 250 partners and customers, Mitel’s planned Dynamic E911 partner (Emergency Routing Service and Location Information Services) at time of publishing is Intrado.
    • Soft phones external to the customer’s network will require the use of a geolocation application.
Mitel Cloud Solutions

  • Kari’s Law

    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.

    • Customers may change the emergency contact email notification recipients through the MiCloud Connect portal.

     

    Section 506 of RAY BAUM’s Act

    MiCloud Connect will:

    • Deliver an automated dispatchable location for fixed devices based on customer-assigned predetermined addresses to the Public Safety Answering Point (PSAP). The customer is responsible for identifying and assigning a dispatchable location to each fixed device.
    • Deliver automated dispatchable location for on-site non fixed devices where customer has provided L2/L3 mapping (create a virtual "wiremap" of the network environment and the associated devices) of their campus environment. The customer is responsible for L2/L3 mapping.
    • Automatically update or prompt users to update their registered address each time they move their offsite non-fixed device, in order to route 911 calls to the appropriate PSAP based on their current registered address. Users can update addresses directly on softphones or, for all devices, through the MiCloud Connect customer portal or console.

  • Kari’s Law

    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.

    • The ancillary alerts can be delivered to up to 32 phones and consoles chosen by the customer. The ancillary alert, which contains the time and date of the call, the caller’s internal extension number as well as a configurable description of the caller, is initiated contemporaneously with a 911 call, and does not delay the call.
    • Mitel recommends that 911 alerts be enabled in all Flex deployments. Retail customers with deployments pre-dating Feb 16, 2020, in which alerts are not enabled should contact Mitel if they would like 911 alerts enabled.
    • Customers maintained by a channel partner, that is MiCloud Flex Partner Delivered or Wholesale customers, should contact their partner for more details.

    Dispatchable Location

    Once properly configured, MiCloud Flex will deliver dispatchable location for fixed and non-fixed devices to the PSAP.

    • The customer is responsible for identifying and assigning a dispatchable location to each fixed device. MiCloud Flex deployments can implement Dispatchable location using CESIDs.
    • With MiCloud Flex Wholesale or Partner Delivered it is partner’s responsibility to work with their customers 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 in the end customer’s MiCloud Flex solution (and registered with the PSAP).
    • With Retail MiCloud Flex customers Mitel will work with the customer 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 in the end customer’s MiCloud Flex solution (and registered with the PSAP).
    • The method of providing a dispatchable location via a Dynamic E911 partner varies depending on device type and network location, but in all cases an additional SIP based Emergency Routing Service is required to place 911 calls and a Location Information Service is also required for addressing requirements. Further technical information will be made available in a forthcoming solutions guide.
    • For MiCloud Flex Partner Delivered and Retail customers will be partnering with a Dynamic E911 solution partner to provide RAY BAUM’s Act compliant dispatchable location information.
    • For MiCloud Flex Wholesale Partners and customers, Mitel’s tested Dynamic E911 partners (Emergency Routing Service and Location Information Services) at time of publishing are Intrado or RedSky.

 

Kari’s Law - Legal Overview

 

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:

  1. a user dialing 911 directly from any station equipped with dialing facilities as soon as the system is able to initiate calls to the PSTN; and
  2. sending 911 call notifications to a central location at the facility where the system is installed or to another person or organization at a different location (e.g. central or other location) if the MLTS is capable of doing so without an improvement to the hardware or software of the system.

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.

 
Information for Mitel Partners and Customers

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 - Legal Overview

 

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.

 

Information for Mitel Partners and Customers
Retail UCaaS Customers

In its provision of retail UCaaS services, Mitel acts as an interconnected VoIP (IVoIP) service provider (see FAQ for definition).

  1. Fixed Devices - Mitel will with each 911 call provide to the PSAP the automated dispatchable location which has been assigned to each customer fixed device. However, Mitel has no understanding of the physical layout of customer premises. As such, it is customer’s sole responsibility to Identify and assign a dispatchable location to each fixed device within their Mitel retail cloud system. Customers who have partners are encouraged to reach out to their partner for assistance.
  2. Non-Fixed Devices - Where technically feasible, Mitel will provide the PSAP with an automated dispatchable location. Where providing an automated dispatchable location is not technically feasible, Mitel solutions will either: (a) prompt the user to update their address each time the phone moves and use the last known address as the dispatchable location, or (b) route the 911 call to an emergency call center.

Partner Delivered Plus (Or Wholesale)

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.


On-Premise Deployments

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

 

Documentation

 

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. 

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:

  1. An interconnected Voice over Internet Protocol (VoIP) service is a service that:
    1. Enables real-time, two-way voice communications;
    2. Requires a broadband connection from the user's location;
    3. Requires internet protocol-compatible customer premises equipment (CPE); and
    4. Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.
  2. Notwithstanding the foregoing, solely for purposes of compliance with the Commission's 911 obligations, an interconnected VoIP service includes a service that fulfills each of paragraphs (1))(i) through (iii) of this definition and permits users generally to terminate calls to the public switched telephone network.
Frequently Asked Questions

  • 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:

    1. An interconnected Voice over Internet Protocol (VoIP) service is a service that:
      1. Enables real-time, two-way voice communications;
      2. Requires a broadband connection from the user's location;
      3. Requires internet protocol-compatible customer premises equipment (CPE); and
      4. Permits users generally to receive calls that originate on the public switched telephone network and to terminate calls to the public switched telephone network.
    2. Notwithstanding the foregoing, solely for purposes of compliance with the Commission's 911 obligations, an interconnected VoIP service includes a service that fulfills each of paragraphs (1))(i) through (iii) of this definition and permits users generally to terminate calls to the public switched telephone network.

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.

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