Mitel & Dynamic E911
by Mitel Legal Team
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.
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:
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.
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 those 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.
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Kari’s Law
MiCloud Connect deployments enable users to directly dial 911 (i.e. without dialing any additional digit, code, prefix, or postfix) 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 the 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.
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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 locations 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 the 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. The 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 the time of publishing are Intrado or RedSky.
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Kari’s Law
MiVoice Connect PBXs licensed in the United States contain a setting that allows the customer or partner to enable users to directly dial 911 (i.e., without dialing any additional digit, code, prefix, or postfix) 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 the 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 locations using an alternative methodology.
Kari’s Law - Legal Overview
Kari’s Law, which came into effect on Feb 16, 2020, places obligations on multiline telephone systems (“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 an 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 postfix) 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 an MLTS must configure the MLTS’ settings so that once installed the MLTS is fully capable of:
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
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 customers) 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 that 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 an MLTS or a VoIP system, an emergency address collected at the 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).
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 the 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 partners for assistance.
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). Customers or partners are free to implement automated dispatchable locations using an alternative methodology.
As between Mitel and partner, it is the 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 an MLTS and not an IVoIP service. Current generation Mitel MLTS can be configured to provide automated dispatchable location. Identification and configuration of dispatchable location is the customer and/or partner’s responsibility, as Mitel does not typically operate the MLTS. If Mitel operates your MLTS please contact Mitel directly. Customers 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 locations 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
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Mitel & Dynamic E911
