Enhanced 911: The Current State Of Confusion

The issues regarding Enhanced 911 (E911) are spread across legacy phone systems, mobile services, and VoIP. This first of a series of monthly columns by the Enterprise Communications Association (ECA), will address the VoIP enterprise market and, hopefully, provide clarity to the key issues. Many players including the carriers are involved in lobbying on pending E911 legislation and participating in the FCC’s E911 proceedings. However, the ECA is the only organization representing the specific needs of the vendors, channel partners, and end-users in the enterprise market. The FCC defines this market as “multi-line business telecommunications systems” (MLTSs) which includes PBX users.

The dilemma presented to the FCC is that when a 911 call is made, the public service answering point (PSAP) operator currently uses the caller’s Automatic Number Identification (ANI) or billing number of the single line subscriber to retrieve address information from a 911 database to determine the caller’s location. When a call is made from behind a MLTS, the ANI is not necessarily an accurate indicator of the caller’s location. This is a critical issue when callers may not able to verbally or accurately advise the PSAP operator of their location. There are some industry options but they are not universally deployed or specified by regulators. The FCC and the industry have been wrestling with this issue since 1994.

Unfortunately, the complexities of the MLTS marketplace have defeated thus far the FCC’s attempts to adopt a uniform federal regulation. This has led to a hodgepodge of state legislation including those laws passed by Illinois (since amended) and more recently Florida that appear to require “station-level” location identification. In other words, in Florida the MLTS apparently would have to have an ELIN (Emergency Location Identification Number) for each MLTS station to enable the PSAP to identify the exact caller location. VoIP services do not use ANI and callers are often not associated with fixed locations. Therefore, an additional administrative layer is required to ensure that the PSAP identifies the correct caller location. This single element of the legislation would impose substantial costs on the MLTS vendors, manufacturers, and users.

Last year, the FCC again deferred the adoption of federal rules albeit for a limited time. The intent was to give states a year to address the issue and consider the adoption of the National Emergency Number Association (NENA) model legislation (http://www.nena.org/9-1-1TechStandards/ TechInfoDocs/MLTS_ModLeg_Nov2000.PDF ). Since this model legislation was developed in consort with manufacturers, vendors, public safety individuals, and NENA, it is considered a workable consensus. The year is now up and the FCC has issued a public notice seeking information on what has happened at the state level. Essentially, the states have been slow to adopt the NENA model or any MLTS legislation. Even in cases where states have acted, the results were inconsistent. For example, Florida completely ignored NENA whereas Minnesota closely based their E911/MLTS statute on the model
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The FCC is in a delicate position as it is forced to walk a fine line between:

1. Standards-promoting regulation to improve VoIP 911 capabilities.
2. Prevention of restrictive over-regulation by states limiting VoIP innovation.
3. Ensuring that carrier issues do not get in the way of enterprise compliance and technical innovation.

This is not a position that any regulatory body likes to find itself, so it is understandable that they are being cautious. However, with public safety organizations around the country clamoring for action on this ticking time bomb, it may be time for the FCC to adopt a more active regulatory role.

Readers of Internet Telephony are well aware that VoIP is becoming the predominant telecommunications technology. ECA’s position is that the model legislation provides a strong framework of reasonable regulation, and should be adopted by the FCC to preclude inconsistent state legislation. Looking to the future, ECA has urged the FCC to put in place a plan to address VoIP E911 compliance issues as quickly as possible and has proposed that the FCC convene a forum to develop standards for support of E911.

Certainly, vendors and manufactures are concerned that without a clear nationwide policy, the cost of E911 deployment could be enormous. However, ultimately the end-user may incur the most risk to the bottom line. For example, some existing and pending legislation would force PBX users to subscribe to Direct-Inward-Dial (DID) services to ensure that the same number used to identify the MLTS station could also be used by the PSAP operator to call back that station. Currently, a significant percentage of PBX users do not subscribe to DID services. The NENA model legislation avoids imposing this burden by allowing end users to use different numbers for callback and location identification.

The ECA and Internet Telephony would like to encourage vendors, manufacturers, and end-users to join in the E911 discussions by submitting “Letters to the Editor” or going to the ECA site (http://www.encomm.org/contact_eca.asp) and indicating your willingness to participate. IT

Max Schroeder is a consultant Principal of The InStep Group, a consulting firm, and a Founding Member of the ECA, Member of the Board of Directors, Chair of the Media Relations Committee and, in that capacity, is the ECA liaison for TMC.