California MLTS E9-1-1 On a Fast Track

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http://fletch.cachefly.net/E911Talk2013/Episode145_CalifLeg2.mp3


Thumbnail image for CPUC-MLTS LogoOnce again this week California’s in the news regarding E 911 legislation for multiline telephone systems or MLTS. Just last week, APN Legal Correspondent Martha Buyer provided an update on this legislative initiative, and just one week later there’s additional news to report.

The bill was in the Assembly Committee on Appropriations where some edits to the language were made. As is normally seen, the boilerplate language about being applicable only in areas where E 911 services are available and supported by the PSAP is in there, but that is almost a moot point, as the only areas without E 911 service in the US are some of the remote desolate areas of the Midwest.

As the bill is written right now, the main requirements for an MLTS operator are as follows:

A multiline telephone system (MLTS) operator shall maintain and operate the MLTS in such a manner that a telephone call made by dialing the digits “911” and, if applicable, any additional digit that must be dialed in order to permit the user to access the public Switch switched telephone network from any telephone on the MLTS is routed to a public safety answering point (PSAP) and provides automatic location information or automatic number identification to the 911 network that connects to the PSAP.

The important part here, is that they are requiring both 911 and the trunk access code plus 911. This is why one of my best practices is to make sure that 911 and 9-911 act identically in the system.

For an MLTS serving business locations, the MLTS operator shall program the MLTS equipment to deliver the 911 call with an emergency location identification number which will result in either of the following:
(1) An emergency response location which provides a minimum of the building and floor location of the caller.
(2) An ability to direct response through an alternate and adequate means of signaling by the establishments of a private answering point.

The two important things here are granularity and on-site notification. I’m happy to see that they acknowledge building and floor being adequate for PSAPs resolution. After all, the 911 call taker has no idea what cube 2C231 means in your floorplan. 911 dispatchers need to dispatch. The information they need is a street address, and that needs to be the right street address. Having the floor is very useful, especially in the case of a building fire. Eighth floor? Better bring the ladder truck!

It’s also good to see the mention of an “alternate and adequate means of signaling”. This is where on-site notification to appropriate individuals, and providing screen pops and other pieces of data is acknowledged which can simplify and E 911 remediation plan. Another important piece is the recognition of a PEAP or private emergency answer position. The only word of caution here is that what constitutes a PEAP, is not clearly defined. If you want a good example of that, take a look at the state of Maine legislation, where it’s clearly defined and what I use as a good example.

An entity that is the seller or lessor of an MLTS system shall provide, at the time of sale or lease, to the purchaser or lessee and to each new user, either a demonstration of how to place an emergency call from a telephone station or provide written instructions at each telephone station on how to do so.

This is certainly a new twist in legislation. Instead of focusing on the user of the MLTS PBX, the onus is put on the person that is the seller. This actually makes a lot of sense, since someone in the business of selling or leasing telephone systems most likely has the technical acumen to provide proper evaluation of an E911 environment, and usually is tasked with end-user training of a new system. Why not ensure that emergency call handling is part of that training? To whoever came up with that simple idea, great job! Sometimes the most obvious solution is overlooked.

The MLTS operator shall review and verify the accuracy of the number and location information provided by the MLTS at least once annually.

This one is another one of those common sense things, that we shouldn’t need a law on, however it’s a good reminder. I always say there are four things that should be done twice a year:

1.) Change the batteries in your smoke detector
2.) Set your clock forward or back one hour
3.) Update your Smart 911 profile
4.) Review and verify the accuracy of E911 in your PBX

Those simple tasks will save countless lives each and every year.

An MLTS serving multiple buildings or structures with a combined total workspace of 7,000 square feet or less shall not be required to provide more than one emergency response location.

This is a bit of a departure from other areas as in many other cases, each building and floor needed its own right emergency response location. I understand where they’re going with this one, but I’m not sure that I agree completely. As in many cases, it really depends on the use of the facility, and the normal population of employees.

An MLTS serving a single building with 7,000 square feet of workspace or less shall not be required to provide more than one emergency response location. In the event of a dispute over the total amount of square footage, the State Fire Marshal shall determine whether the exemption applies to the building or structures.

Again, I believe they are missing one important piece, in my opinion. I would agree with this if it was limited, or had language about multiple floors.

An entity that is a seller or lessor of an MLTS system in violation of this section after January 1, 2019, may be assessed a fine from five hundred dollars ($500) to five thousand dollars ($5,000) per system sold or leased.

I’m not sure I see the need for a date so far in the future, especially with no guidance to new systems being purchased being applicable sooner, however it is a direction and it acknowledges the problem which will ultimately raise awareness. As we flatten consolidate our environments, and the potential for seeing federal legislation somewhere in the immediate future, enterprises have gotten the message that the ability for their users to reach emergency services is a critical part of the infrastructure. New technology is affordable, deployable and can provide greater situational awareness about emergent events. Technology administrators can no longer claim a lack of knowledge on the topic. It’s been in the news, it’s certainly been covered in this blog and podcast, and the FCC even acknowledged the problem last year when they issued their notice of inquiry to the industry.

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The International Avaya Users Group Converge 2013 event will be held at the Gaylord Palms Resort in sunny Orlando Florida. APN will be there in booth 337 where my cohost Guy Clinch and I will be hosting a series of podcasts with technology leaders, vendors and partners, and even show attendees.

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If you’re in Orlando on Monday, be sure to check out the Avaya DevConnect sponsored session: IAUG Ignite! at 1 PM in Tallahassee rooms 1 & 2. IAUG Ignite! Is a unique session designed to ignite new ideas for you and your company. Using a presentation format similar to TEDx, speakers will challenge the way you look at communications, technology, customer experience and operational issues, using no more than 10 slides displayed for 30 seconds apiece. Once each segment starts, there’s no stopping, and the buzzer ends after five minutes. Be sure not to miss this exciting event on Monday, and kick off the conference with some new and stimulated ideas.

I look forward to seeing you in Orlando!


Want more on E9-1-1?  E9-1-1 Talk Podcast
Subscribe to my weekly E9-1-1 Talk Podcast here

Thanks for stopping by and reading the Avaya CONNECTED Blog on E9-1-1, I value your opinions, so please feel free to comment below or if you prefer, you can email me privately.

Public comments, suggestions, corrections and loose change is all graciously accepted 😉
Until next week. . . dial carefully.

Be sure to follow me on Twitter @Fletch911

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California cold feet on E911 Legislation?

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is also available as an MP3 Audio File


CPUC-MLTS Logo.pngIt’s no great secret that for several years now California has been touted as being very progressive with its E911 legislation. After initial Public Utilities Commission hearings in 2010, Bill A.B. 911 has recently been moving forward at lightning speed as it navigates its way through the legislative process.

A few weeks back, the bill was put into “SUSPENSE,” and today a Senate Appropriations Committee Fiscal Summary Bill Analysis was published on the California PUC website explaining the reasoning for this change.

Cue the suspenseful music!

The analysis reports a change to the Fiscal Impact (as proposed to be amended):
“Unknown one time costs, possibly in the hundreds of thousands to millions of dollars, from General Fund and various special funds to replace and update any ML TS system owned and operated by the state to be able to transmit the required information with 911 calls.”

As proposed, the bill would go into effect on January 1, 2016, and would require that the MLTS be operated and maintained so that dialing 911, or 911 and any additional digit for access codes (9 for example), route the caller to the PSAP with the “automatic display of the callers number address and location of the phone.”

161-5Percent-iStock_000014802700XSmall.jpgAs stated earlier in the PUC report, only a small fraction of companies would be affected by this new legislation, however that would account for a large majority of constituents that are serviced by these systems. The report documents that 95% of the 1.3 million businesses and government agencies within California would actually be exempt from this legislation, and the remaining 65,000 businesses “employ 9,521,366 Californians or 60.5% of the California workforce and serve countless visitors, customers, clients and tourists, are the business MLTS customers and end-users that require this critical E9-1-1 emergency services protection and would benefit from Enhanced 9-1-1 legislative mandate.”

Part of the issue here is that, despite the data presented during the PUC workshop in 2010, there is still a perception that 911 remediation is a costly undertaking for an MLTS environment. It is also clear that some of the base guidelines that are stated in the NENA MLTS Model Legislation document have not been taken into consideration. For example, requiring station level reporting to the PSAP becomes the burden for enterprises when implementing an E911 solution. Many stations within the enterprise do not have their own individual direct inward dial telephone number, and an organization with several thousand telephone instruments could be challenged with the operational costs managing locations at the individual device level.

As the NENA model legislation states, zone level reporting with the appropriate on-site notification mechanisms is adequate when establishing emergency response plans for a particular address. This reduces the complexity of the solution, as well as eliminates the ongoing and costly maintenance of the carrier PS-ALI database, which can now become static. Based on Avaya’s experience, eliminating this complexity not only reduces cost, but improves the chances of systems actually being implemented to where they will do some good. Let’s face it, you can have the best solution possible but if no one uses it, it’s worthless.

While I’m a proponent for legislation around E911 services in the enterprise, I do not believe in legislation that doesn’t actually solve the problem. California has an excellent opportunity to follow in the footsteps of states like Michigan, Massachusetts, Virginia, and the 15 other states that have implemented legislation and guidance around emergency services and multiline telephone systems.

Adopting this legislation, without clarification on zone level reporting requirements would be a huge mistake, now or in the future, and delaying the implementation of this bill until 2017 serves no purpose whatsoever. If there was a level of concern over requiring existing implementations enough time to evaluate and become compliant, there is always the proverbial “grandfather clause” that would allow existing systems to operate for an extended period of time past the implementation of the bill. New systems purchased on or after that date would require compliance, with of course a six month window at the beginning of the bill effective date to allow those businesses with construction plans already in place a short grace period.

martha.pngAPN Legal Correspondent Martha Buyer says, “There’s an old adage about never wanting to watch either legislation or sausage being made. My suspicion is that lobbyists got in the middle of this draft legislation and convinced the bill’s author and those supporting it, that the requested change was paramount to its adoption. Unfortunately, in the course of modifying the legislation to appease someone, the teeth–and effectiveness–may have been removed. At the end of the day, E911 legislation is all about safety and protecting people. Employers, who may have lobbied against an additional regulatory burden, may be unaware that they continue to have exposure, with or without legislation, for creating and maintaining a safe workplace, both for employees and guests.”

Again, most systems today will provide some level of 911 location granularity and reporting. This is not new to the industry, and we’ve worked closely with our DevConnect community to make it available several different solutions, at several different levels of functionality, and several price points which are nowhere near the costs indicated in the recent Bill Analysis.


Want more Technology, News and Information from Avaya? Be sure to check out the Avaya Podcast Network landing page at http://avaya.com/APN . There you will find additional Podcasts from Industry Events such as Avaya Evolutions and INTEROP, as well as other informative series by the APN Staff.

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Thanks for stopping by and reading the Avaya CONNECTED Blog on E9-1-1, I value your opinions, so please feel free to comment below or if you prefer, you can email me privately.

Public comments, suggestions, corrections and loose change is all graciously accepted 😉
Until next week. . . dial carefully.

Be sure to follow me on Twitter @Fletch911

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California Moves Forward on MLTS E911

CPUC-MLTS LogoCalifornia MLTS Legislation took another step forward this week after a unanimous vote in the Assembly on Bill CA911 that would provide a legislative directive, with penalties for non-compliance, on Multi Line Telephone System deployments (PBX systems) serving areas greater than 7,000 square feet.

Frequent APN Podcast guest and attorney Martha Buyer joins me once again, earning the title of ‘APN Legal Correspondent’, and is joined by Byron Battles, principal of the Battles Group. Byron is a former President of the Society of Telecommunications Consultants, and is well respected by many in the industry, myself included.

A full transcript is provided below,
as well as the MP3 Audio available here:
http://fletch.cachefly.net/E911Talk2013/Episode144_CaliLeg.mp3


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Spyder Harrison – VO Dude
This segment of the Avaya Podcast Network is sponsored by CacheFly, deliver content fast with CacheFly. Visit CacheFly.com to learn more. This is the Avaya Podcast Network (APN) – technology, news and information, all in one place.

Mark Fletcher:
California moves one step closer to MLTS legislation. Find out more on the next E911 Talk Podcast Episode 144, recorded Friday, May 24, 2013.

Spyder.png
Spyder Harrison – VO Dude
Welcome to this edition of E911 Talk with your host, Mark Fletcher, Product Line Manager for Emergency Services at Avaya. Now here’s Fletch.

Mark Fletcher:
Hi, everyone. It’s Fletch with the E911 Talk Podcast and joining me today is APN legal correspondent Martha Buyer. You don’t mind that I gave you that title, do you Martha?

Martha Buyer
Martha Buyer
I’m honoured by it. No, I think it’s delightful.

Mark Fletcher:
And also joining us is a consultant from the Battles Group, Byron Battles. Byron, how are you today? Thanks again for joining us.

ByronBattles.png
Byron Battles:
Very well. Thank you very much.

Mark Fletcher:
I called this two industry experts together because in my email box this morning showed up another bit of information about California Legislation. So Martha, this is something that you and I are both been tracking quite a bit and there’s been some recent turn of events in California. Why don’t you tell us what those are?

Martha Buyer
Martha Buyer
Well, it looks like the legislation is working into it through the process to get ultimately to the California legislature. Most recently, the legislation was presented to the Assembly Committee on Appropriations which is where the money comes from and it was voted on and it was voted 15 to nothing to move it ahead. So this is a step forward but it’s not going to happen at lightning speed even if this makes it to the legislature for a complete vote by the end of the term which is what the person who’s sponsoring it told me they hoped would happen. It wouldn’t become effective until January 1, 2019, big window for compliance.

Mark Fletcher:
So what are some of the highlights? What are they looking to accomplish? I know that they talked about location accuracy and a few other things.

Martha Buyer
Martha Buyer
Well I think to me, there are two very interesting things in terms of who’s not covered by it and that is, it does not apply to buildings or structures that are under 7,000 sq. ft. or in those areas in the State of California where enhanced 911 services are not available. So that certainly takes out a lot of your small business and maybe a good chunk of small and medium business, as well as residential providers of telephone service.

Mark Fletcher:
And that’s really not too much of a problem because if you’re under 7,000 sq. ft. I don’t think you really have much of a location problem unless you’re multiple stories.

Martha Buyer
Martha Buyer
Right. Right, that’s true. But otherwise, they would say, it’s fairly generic. It requires an MLTS operator in an area that has enhanced 911-capability to maintain and operate the MLTS as specified to ensure that each emergency calls placed from a telephone space and on the system is routed to the public safety answering point. That’s not very specific. I expect a lot of these details are going to get hammered out as we go forward. But a bill listing is very interesting in the bill reactors stand and remember this is in front of the Appropriations Committee is that the fiscal effect which is underlined in the bill as it stands does minor observable cost to the PUC, very nice. That for them MLTS providers I supposed like to hear. It’s not going to be their expense. The big challenge will be on the state side.

Mark Fletcher:
Well yeah, that I think is a really important part. And again, the fact that they rule out people under 7,000 sq. ft. rules out your small and small-medium businesses from having to do anything. I think it’s really targeted at the larger enterprises, multiple buildings, multiple stories. So Byron, you are a consultant in the space and I know you take 911 very seriously. Your past president of STC which is a tremendous title to have right there but I know that you take 911 very seriously because I’ve had to present in front of you for some of your customers. What’s your take on this?

ByronBattles.png
Byron Battles:
It’s interesting the timing on this because we actually have a client that Martha has been doing some research for that. It’s a single site but what we found as consultants in the last 5 years that organizations are taking 911 and E911 much more seriously and looking at it much more closely. The reason being is because of the pending legislation a variety of state, they need to provide that location information and even though this particular client has just single site and would probably be exempted in California, it has other locations in DC and Maryland that it has already rolled out E911. So it was to provide the state environment for all of its employees not just the one where it’s legislated or soon to be legislated by law. So we’re trying that the client and we as consultants has to be much more cognizant to the E911. We have to understand not only the technology behind it but how is it going to work within any specific organization, how big is it, how closely do they want to pinpoint where the medical or emergency is taking place and how is the call going to be conveyed to not only public first responders but the internal security if there is one.

Mark Fletcher:
Yes. So one of the things that impress me the most when I was dealing with you where I had to present to you was that you chose to include 911 in the initial RFI and RFP responses but you made it very clear that that particular section was kind of going to go through its own due diligence at a later point in time and that was because the network hadn’t really been established yet and you got to know what the network is going to look like. And I thought that was such a proactive stands to see from a consultant. I wish more people would do that.

ByronBattles.png
Byron Battles:
We feel like in any converged types of solution, the network is the road on which all the applications go. And even though it’s not the most glamorous part of that solution, it’s the most essential part.

Mark Fletcher:
Excellent information. Martha, any closing thoughts?

Martha Buyer
Martha Buyer
No, I think he has covered it. I mean, you know I wouldn’t tell anyone to panic. First of all, this hasn’t passed to legislature yet. It hasn’t become law but it’s certainly working its way in that direction and it’s doing so at a reasonably good clip. So I would say, “Stay tuned.”

Mark Fletcher:
And as always, it’s 911. It’s life safety. You should be looking at this anyway and this is just another proof point that it is coming again in another state. And again, maybe the language needs to be tightened up but still there’s this plenty of time for that to happen, so definitely stay tuned. Again, we’re talking with APN legal correspondent Martha Buyer. We appreciate you joining us today. And also, Byron Battles from the Battles Group. Byron, thank you very much. First time on the podcast and we’ll be talking to you at the Avaya IAUG Show in Orlando hopefully in a few weeks. Thanks for joining us today on this podcast.

ByronBattles.png
Byron Battles:
Thanks. Very well.

Martha Buyer
Martha Buyer
Thanks, Fletch.

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Spyder Harrison – VO Dude
You’re listening to APN, the Avaya Podcast Network. Find us on the web at Avaya.com/APN.

End of Transcription [00:07:25.07]


Want more on E9-1-1?  E9-1-1 Talk Podcast
Subscribe to my weekly E9-1-1 Talk Podcast here

Thanks for stopping by and reading the Avaya CONNECTED Blog on E9-1-1, I value your opinions, so please feel free to comment below or if you prefer, you can email me privately.

Public comments, suggestions, corrections and loose change is all graciously accepted 😉
Until next week. . . dial carefully.

Be sure to follow me on Twitter @Fletch911

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CacheFly is the world’s fastest CDN, delivering rich-media content up to 10x faster than traditional delivery methods. With a proven track record and over a decade’s worth of CDN experience, companies around the world choose the CacheFly CDN for reliable and unbeatable performance. For more information, visit www.cachefly.com