911 Legislative Update: Plain Facts in Plain English

“I’m not a lawyer, and I don’t play one on TV.” That is a common line that I say jokingly quite often, however there is a definite sense of seriousness to it. With all of the legislative action on emergency 9-1-1 requirements in the past few years (most of it sparked or inspired by Kari’s Law), it’s no great surprise that many self-appointed soothsayers have awarded themselves with legal degrees, or at least so it seems.

Because of this, administrators who are responsible for enterprise telephony systems, and the upcoming remediation/Implementation of emergency services would do themselves a great favor by consulting with someone holding actual legal credentials, and practicing law for a living.

Far too many times I have seen wild stories build upon themselves, all based on incorrect information. Just the other day, I heard a user in a meeting make the comment that Florida has the toughest 911 legislation, requiring station level reporting. I responded by explaining how that particular law is one of the most misquoted pieces of legislation I run across.

The first section of the Florida law contains definitions for five specific terms used in the second section. One of those definitions is: “Automatic Location Identification” or ‘ALI’ means the automatic display at the Public Safety Answering Point (PSAP) of the caller’s telephone number, the address or location of the telephone, and supplementary emergency services information.”

The second section consists of a single sentence that states:  “REQUIRED ALI CAPABILITY – Each PBX system installed after January 1, 2004, must be capable of providing automatic location identification to the station level.”

When dissecting these statements, neither of them requires reporting location of the caller at the station level. In the first example, the word “or” allows for just the address, making the station information optional. In the second example, being capable of a function, is not actually performing a function. Not only is this legislative language NOT very specific, it is poorly worded and optional at best.

Kari’s Law (as of February 16, 2020) will go into effect federally. If a state law is less prescriptive, then the federal law will supersede it. If the state law is more prescriptive, then that is the deciding factor.

Notable exceptions: The Commonwealth of Massachusetts requires an MLTS operator to report at the station level. However, if a designated central response location is defined; the individual station reporting is no longer required. That can make a significant impact on monthly OPEX of the solution, as the number of endpoints reporting to the PSAP is significantly reduced, while the level of detail that is sent to them is greatly increased.

Later this year, on August 2, 2020, the additional requirements will come into play as Dispatchable Location capabilities that are defined in the Ray Baum Act when it goes into effect.  Once again, don’t be fooled by the term “dispatchable location.” The definition of that term is very broad and very nondescript. Whatever that information is, it needs to be actionable and assist in finding the location of the caller.  

At the end of the day, a company and its sales organization have a mission to sell their products and services. There is absolutely no requirement, and certainly no incentive for any 911 solution to provide you with “the best deal.” The key here is to avoid making purchasing decisions based on emotion; take some time to understand what you need and want. Then, secure legal counsel to review your particular compliance level and potential exposure before making a purchase.

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