Calling all UCaaS / CPaaS / CCaaS / enterprise VoIP providers. We need to comment on MLTS (Multi-Line Telephone Systems) NPRM (Notice of Proposed Rule Making) (FCC 18-132) as soon as possible.

Firstly, an apology in the lateness of this article. I learnt about FCC 18-132 back in October at the IIT RTC Conference and have been meaning to write about it since. Life has been a little hectic, I’m finally catching up on the backlog, which also means I’m available for consulting work 😉 But focusing on the topic at hand, FCC 18-132.

The Notice proposes to define MLTS (Multi-Line Telephone Systems) consistent with Kari’s Law and RAY BAUM’S Act which define MLTS as “a system comprised of common control units, telephone sets, control hardware and software and adjunct systems, including network and premises based systems, such as Centrex and VoIP, as well as PBX, Hybrid, and Key Telephone Systems.

The Notice proposes to interpret this definition to include the full range of networked communications systems that serve enterprises, including circuit-switched and IP-based enterprise systems, as well as cloud-based IP technology and over-the-top applications. We further interpret this definition to include systems that allow outbound calls to 911 without providing a way for the PSAP to place a return call.

So UCaaS / CPaaS / CCaaS / enterprise VoIP if you can make a voice call through your service to the PSTN it potentially means you!

The Law / Act referred to in the notice are:

• Kari’s Law: No matter what a telephone systems dial pattern is, “911” gets to the PSAP.
• RAY BAUM’S Act defines “dispatchable location” as “the street address of the calling party, and additional information such as room number, floor number, or similar information necessary to adequately identify the location of the calling party.”

At the IIT RTC Conference Eric Burger, CTO FCC, gave an excellent presentation on this notice, shown below and you can download the presentation here.

I know the MLTS NPRM (FCC 18-132) request for comments, has the deadline of December 10, 2018. But do not worry, you can still comment, and as an industry we need to!

Quoting from Eric’s Slides:

• If you build it, you need to do it
• If you buy it, you need to do it
• If you operate it, you need to do it
• What if you have one already that doesn’t do it?
  • You need to do it if you don’t need a hardware upgrade
  • You need to do it if you don’t need a substantial software upgrade
  • You need to do it if you don’t need a significant purchase
• In short, just about everyone needs to build it / offer it / use it

Submit your filing here, they are listening.

Thinking through some of the scenarios and issues.

I can make a call using my UCaaS client on my mobile at home, so it looks like a call from my desk phone number in the office. The client on the mobile looks like a phone dialer, I’ll come back to why this is important in a minute. How is the dispatchable location determined? The 911 call from the UCaaS dialer could be captured and routed to the phone’s dialer so the mobile network solves the issue. For tablets and laptops the issue is more complex.

There’s also a more fundamental issue on “what is a line?” Historically its was a piece of wire from the PBX to the office phone on your desk. But today a line is closer to a DID (phone number) I can make calls to/from, and that DID can be shared.

Many ‘lines’ (DIDs) are used for bots, IoT devices, and services so these rules should not necessarily apply there.

The ruling does make sense that a person in need, can pick up a phone (or dialer screen?) dial 911 and receive timely help where they are physically located.

However, today we have dialers everywhere. I’m sure you saw the video of the teenagers trying and failing to use a rotary phone. My son has only ever used mobile phones with screen dialers, its just an app for him. There are different expectations with children today on what a phone is, it’s virtual, it’s a pervasive service.

A child maybe waiting for their parent using a tablet to watch videos and an emergency arises. They flip to the UCaaS app their parent uses to make calls when working from home, it’s a dialer, they’ve been taught at school to dial 911 in an emergency, its not too far-fetched a scenario. The GPS could be disabled, the WiFi could not be connected to the internet. The concept of a line today with all the assumptions made about that line are no longer valid. An obvious answer to this scenario is to disabled the dialer or have big flashing sign of NO EMERGENCY SERVICES SUPPORTED when 911 is dialed. But if GPS is working, and the internet is connected, and a 911 call with a dispatch-able location could be supported, where do we draw the line?

I’m not going to pretend I have a clear-cut set of recommendations. To the previous example of the child, my son knows his mobile phone is his emergency life line as we pay T-Mobile to provide that – all parents should educate their children on this, its not obvious to our kids. But he is an exception, most children his age do not have mobile phones, nor the knowledge that the life-line service is part of the mobile phone service. For children today, devices are all computers and dialers just work.

Hence we all need to contribute to the discussion, the FCC is listening to us. As an industry we must find a common sense way to define the line of 911 support in this complex and continuously evolving situation.