California MLTS E9-1-1 On a Fast Track

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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!


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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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