Is your Multi-Line Telephone System ("MLTS") currently providing direct 911 dialing (without requiring the dialing of any other digits or "9" to access an outside line), and on-site notification to a central location at the facility where the MLTS is installed to expedite emergency response?  Is your MLTS capable of transmitting dispatchable location information for 911 calls?  If you are a service provider, are your fixed telephone, interconnected VoIP and TRS services technically able to transmit dispatchable location information?  If not, it's time to start preparing for new E-911 mandates for 911 emergency calls.  If not, it's time to start preparing for new E-911 mandates for MLTS emergency calls.  The FCC is proposing to implement new MLTS 911 call rules, and dispatchable location requirements more generally for all 911 calls, by the February 16, 2020 compliance date of Kari's Law.

The Federal Communications Commission ("FCC"), in response to the enactment of Kari's Law (amending the Communications Act of 1934 as section 721), and RAY BAUM's Act earlier this year, has commenced a new rulemaking (Comments due December 10, 2018, with Reply Comments due January 9, 2019) that would fill gaps within its rules providing for minimum 911 capabilities in MLTS, and new dispatchable location requirements for virtually all 911 calls, so that every 911 caller can be quickly and accurately located.

To accomplish these statutory and FCC goals, the FCC proposes to adopt rules requiring manufacturers, sellers, or operators of MLTS to configure their system to:

  • enable a user to initiate a 911 call "from any station equipped with dialing facilities, without dialing any additional digit, code, prefix...including any trunk-access code such as the digit "9"....";
  • provide an on-site notification to a central location (e.g. security desk,third partysecurity service, or to an enterprise employee on call) at the facility where the system is installed; and
  • convey "dispatchable location" with every 911 call, regardless of the technological platform used (RAY BAUM Act rules to be adopted by September 23, 2019).


This rulemaking will not only determine what 911 capabilities will be required of MLTS systems, but who will be subject to them.  For example, the rules do allow for grandfathering, i.e. they would only apply to MLTS manufactured, imported, offered for sale or lease, "installed after February 16, 2020", thereby avoiding stranded investment in existing MLTS systems, many of which already support direct 911 dialing and notification.  Still, the FCC seeks comment on any barriers or potential costs facing MLTS manufacturers, importers or managers/operators of such systems in terms of their future compliance with these proposed rules.  The FCC observes in its Notice of Proposed Rulemaking ("NPRM") that in the absence of federal or consistent state regulation, some MLTS in operation today do not support direct 911 dialing, may not route 911 calls to the most appropriate PSAP for the 911 caller's location, or do not provide accurate information regarding the caller's location.  In a large building complex, hotel, or college campus, that could have dire consequences for a 911 caller facing a life-threatening emergency. With the vast majority of enterprise communications systems ("ECS") having migrated to or planning to migrate to IP-based ECS, and with a trend toward adoption of cloud-based service offerings, the FCC believes that the ability of such IP-based MLTS systems to support 911 direct dialing, notification and dispatchable location is inconsistent.

Direct Dialing and Notification for MLTS (Kari's Law)

The FCC requests comment on its proposed direct dialing requirements for persons "engaged in the business of manufacturing importing, selling or leasing MLTS, as well as persons engaged in the business of installing, managing or operating MLTS...." NPRM, Para. 13.

Similarly, though Kari's Law is silent on the contents of any internal notification requirement for 911 calls, the FCC requests comment on its tentative conclusion that at a minimum, onsite notification --to internal first responders-- should minimally include the following information: (1) that a 911 call has been made; (2) a valid callback number; and (3) the information about the caller's location that the MLTS conveys to the PSAP with the 911 call (i.e. the same dispatchable location information that the PSAP receives). The FCC also proposes that notification timing be "contemporaneous" with the 911 call and not delay placement of the 911 call.

Destination Points for Notification

The FCC also seeks comment on whether it should specify any specific destination points, either on-site or off-site, to increase the likelihood that it is going to be received by someone able to take appropriate action to assist the 911 response.  Should it be on-site to a location normally staff or where on-site staff are likely to hear or see the notification?  Should it be to an authorized person or organization who can provide first responders with access regardless or the person or organization's location?  The FCC believes that requiring staffing or monitoring should not be required to meet the notification goals of the statute, but that notification should be sufficient, and be of negligible additional cost above the MLTS cost, if directed to points "where they are likely to be seen or heard by existing staff...." NPRM, Para. 26. However, the FCC does ask if the costs and benefits of notification apply differently to smaller organizations and businesses that are less likely to have personnel controlling access.


As a starting point, the FCC suggests that Enforcement would track the requirements of the Kari's Law statute, so that, for example, a manufacturer "offering to sell" an MLTS that is not pre-configured to support direct 911 dialing, and an MLTS operator operating a system that will not allow users to dial 911 directly, would face potential enforcement.  Given varying apportionment of responsibilities (i.e. contractor/subcontractor) between the MLTS or enterprise system operator and the service provider in today's marketplace, the FCC seeks comment on its proposal to apply a "presumption" that the MLTS Manager bears "ultimate responsibility" for compliance with the FCC's MLTS Rules.  The FCC also asks how liability should be apportioned where multiple parties may be responsible for compliance with the statute and the FCC's proposed rules.

RAY BAUM's Act Dispatchable Location Information

RAY BAUM's Act directs the FCC to consider adopting rules requiring transmission of "dispatchable location" with 911 calls "regardless of the technological platform used." NPRM, Para. 51.  The FCC is considering such requirements not only for MLTS but for the following communications services required to offer 911-capable services to their customers: fixed telephony; mobile telecommunications; interconnected VoIP; and Internet-based Telecommunications Relay Service ("TRS").

The FCC tentatively concludes that it is feasible for 911 calls originating from MLTS locations to convey dispatchable locations to the appropriate PSAP based on various solutions available.  Accordingly, the FCC proposes to prohibit the manufacture, sale, leasing or installation, management or operation of MLTS without being configured so that the dispatchable location of the caller will be conveyed to the PSAP with 911 calls.  The same entities subject to Kari's Law will be subject to these prohibitions.  Nevertheless, the FCC seeks comment on whether the technical elements necessary to convey dispatchable location information with a 911 call are currently available in MLTS deployed today.  If not, can they be upgraded?  What disclosure requirements or target compliance dates should be required of non-compliant, grandfathered MLTS?  What steps should an MLTS manager or operator take to provision the MLTS to ensure that dispatchable location is conveyed to the PSAP?

The FCC seeks comment on how to reconcile the Act's definition of dispatchable location with the nearly identical definition of dispatchable location (street address, room number, floor number, etc.) under the mobile E911 location accuracy rules, which it considers functionally identical.  The FCC also seeks asks whether it should require validation of the street address of the calling party before delivery to the PSAP, as is required of CMRS providers under the mobile E911 definition.  Should the transmittal of additional location information be required for each floor of an office building or hotel, and each 7,000 square feet of workspace after the first 7,000 square feet, in accordance with NENA's model federal MLTS legislation?  Should alternatives to dispatchable location that do not meet the statutory definition (street address) be encouraged, such as x/y/z coordinates such as when a person is in a large public park or amusement park, where a street address is not particularly helpful to first responders?

Fixed telephony, Interconnected VoIP and TRS

The FCC also proposes to impose new FCC dispatchable location requirements for fixed telephony (which is already subject to certain state requirements), interconnected VoIP (subject to existing Registered Location requirements under FCC rules), over-the-top ("OTT") providers and TRS providers, and to apply the same February 2020 compliance date for MLTS on these communications services.  The FCC tentatively concludes that applying the same compliance date to dispatchable location requirements will encourage solutions that can support multiple technology platforms.

Finally, the FCC seeks comment on whether these requirements would improve emergency response and the public health and safety, and whether those benefits would exceed any compliance costs.

This rulemaking is one of the most important E911 rulemakings by the FCC in many years.  It will certainly have a lasting impact on public safety and emergency response effectiveness, but also on technological development and management of enterprise communications systems.  If you are interested in filing comments, please let us know.

If you would like more information about how to participate in this rulemaking, please contact either Katherine Barker Marshall at (202) 792-6422 or, or Doug Bonner at (202) 352-7500 or

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