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 PUBLIC  NOTICE  Federal  Communications  Commission  445  12  th  St.,  S.  W.  Washington,  D.  C.  20554  News  Media  Information  202  /  418-  0500  Internet:  http://  www.  fcc.  gov  TTY:  1-  888-  835-  5322 
 DA  04-  3874 
 December  10,  2004 


 COMMISSION  SEEKS  COMMENT  ABOUT  STATUS  OF  STATE  ACTIONS  TO  ACHIEVE  EFFECTIVE  DEPLOYMENT  OF  E911  CAPABILITIES  FOR  MULTI-  LINE  TELEPHONE 
 SYSTEMS  (MLTSs) 
 CC  Docket  No.  94-  102 
 Comments  due:  [45  days  from  publication  in  the  Federal  Register]  Reply  Comments  due:  [75  days  from  publication  in  the  Federal  Register] 


 This  Public  Notice  solicits  comment  about  the  progress  made  by  the  states  in  implementing  E911  1  solutions  for  multi-  line  telephone  systems  (MLTSs).  2  When  an  emergency  (i.  e.,  911)  call  is  placed  from 
 a  station  served  by  an  MLTS,  the  Public  Safety  Answering  Point  (PSAP)  receiving  the  call  will  not  always  be  able  to  identify  the  office,  dormitory  room  or  other  detailed  location  of  the  caller.  3  This 
 problem  is  well  known  and  has  been  a  subject  of  several  Commission  proceedings.  4  In  the  E911  Report 


 1  Enhanced  911  or  E911  refers  to  the  automatic  addition  of  location-  specific  and  call-  back  information  to  a 
 traditional  911  call,  permitting  more  efficient  and  speedy  response  by  emergency  service  personnel. 
 2  Multi-  line  telephone  systems  serve  multiple  telephone  stations  at  a  single  customer  site,  e.  g.,  an  office  building  or 
 a  university  campus,  and  allow  the  stations  to  be  administered,  managed  and  billed  as  a  single  entity  for  the  customer.  MLTSs  range  in  size  and  complexity,  serving  anywhere  from  a  handful  to  thousands  of  telephone 


 stations.  In  this  Public  Notice,  we  use  the  term  MLTS  or  multi-  line  telephone  system  to  describe  Centrex,  analog  PBXs,  ISDN  PBXs,  non-  ISDN  digital  PBXs,  IP-  PBXs,  key  systems  and  systems  that  use  combinations  of 
 these  technologies. 
 3  The  emergency  calling  system  works  in  the  following  way:  When  a  caller  dials  911  to  place  an  emergency  call, 
 the  serving  local  exchange  carrier  uses  the  caller's  telephone  number  to  deliver  the  call  to  the  correct  PSAP.  The  caller's  telephone  number  is  sent  to  the  PSAP,  and  the  PSAP  uses  that  number  to  automatically  query  a  database  to 


 obtain  the  customer's  address.  The  system  works  when  the  delivered  number  references  the  location  from  which  the  911  call  is  placed.  However,  when  the  Public  Switched  Telephone  Network  (PSTN)  delivers  an  emergency  call 
 from  a  station  on  a  multi-  line  telephone  system  to  the  PSAP,  the  PSAP  may  receive  the  MLTSs  outgoing  trunk's  telephone  or  circuit  number,  and  not  the  emergency  caller's  station  number.  (In  some  cases,  the  MLTS  station  that 
 placed  the  call  will  not  even  have  its  own  telephone  number.)  As  a  result,  the  standard  method  used  by  PSAPs  to  determine  the  location  of  the  caller  no  longer  works. 


 4  For  a  history  of  the  Commissions  activities  regarding  the  compatibility  of  E911  with  MLTSs,  see  Revision  of  the 
 Commissions  Rules  to  Ensure  Compatibility  with  Enhanced  911  Emergency  Calling  Systems,  CC  Docket  No.  94-  102,  Report  and  Order  and  Second  Further  Notice  of  Proposed  Rulemaking,  18  FCC  Rcd  25340,  25361-  62,  paras. 


 49-  50  (2003)  (E911  Report  and  Order  and  Second  FNPRM).  See  also  Revision  of  the  Commissions  Rules  to  Ensure  Compatibility  with  Enhanced  911  Emergency  Calling  Systems,  CC  Docket  No.  94-  102,  IB  Docket  No.  99- 
 67,  Further  Notice  of  Proposed  Rulemaking,  17  FCC  Rcd  25576,  25605-  07,  paras.  82-  85  (2002)  (E911  Scope 
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 and  Order  and  Second  FNPRM,  the  Commission  was  concerned  that  the  lack  of  effective  implementation  of  MLTS  E911  could  be  an  unacceptable  gap  in  the  emergency  call  system  but  declined 
 to  adopt  federal  rules  to  address  this  issue,  because  the  record  demonstrated  that  state  and  local  governments  are  in  a  better  position  to  devise  such  rules  for  their  jurisdictions.  Expecting  the  states  to 
 act  expeditiously  in  this  area,  the  Commission  committed  to  releasing  a  Public  Notice  in  a  year  to  examine  states  progress  5  and  announced  its  intention  to  re-  visit  the  E911-  MLTS/  caller  location  issue 
 depending  on  the  results  of  its  evaluation  of  state  action.  6 
 Status  of  State  Action 
 Public  sources  indicate  that  approximately  twelve  states  have  adopted  legislation  addressing  E911  requirements  for  MLTSs.  7  These  same  sources  indicate  that  some  state  regulatory  commissions  have 
 promulgated  regulations  addressing  these  requirements.  8  We  seek  public  comment  about  state-  adopted  statutes  and  regulations,  as  well  as  about  proposals  for  action  in  this  area  that  may  be  currently  under 
 consideration  and  the  anticipated  time  frames  for  conclusion  of  such  proposals.  We  specifically  ask  commenters  to  identify  and  discuss  state  actions  that  may  be  based  on  model  legislation  such  as  that 
 proposed  by  the  National  Emergency  Number  Association  (NENA)  and  the  Association  of  Public-  Safety  Communications  Officials  (APCO).  9 


 More  specifically,  we  ask  commenters  to  identify  and  discuss  relevant  state  activity  by:  (1)  specific  identification  (citation)  to  a  particular  statute  or  regulation,  or  proposed  statute  or  regulation,  in 
 each  case;  (2)  identification  of  any  corresponding  state  web  page  where  these  activities  are  presented  or  discussed;  (3)  identification  of  the  date  any  final  legislative  or  regulatory  action  became  effective  or  is 
 expected  to  become  effective;  (4)  discussion  of  any  requirements  placed  on  carriers,  MLTS  equipment  manufacturers,  MLTS  operators,  or  any  other  persons;  and  (5)  discussion  of  how  the  statute  and/  or 
 regulation  is  enforced. 
 With  regard  to  (4),  commenters  should  note  whether  any  entities  are  specifically  exempted  from  adopted  requirements  imposed  by  the  legislation  or  regulations  and  explain  the  criteria  for  exemption.  To 
 the  extent  legislation  or  regulation  was  proposed  but  not  ultimately  adopted,  we  invite  parties  to  explain  why  such  action  was  not  taken,  such  as  cost  concerns,  technical  complexity,  and  the  perceived  lack  of 
 demand  or  need  for  the  proposed  requirements. 
 Use  of  Model  Legislation 


 NPRM);  and  Revision  of  the  Commissions  Rules  to  Ensure  Compatibility  with  Enhanced  911  Emergency  Calling  Systems,  CC  Docket  No.  94-  102,  Notice  of  Proposed  Rulemaking,  9  FCC  Rcd  6170,  6170-  73,  paras.  1,  8,  11  and  12 
 (1994). 
 5  See  E911  Report  and  Order  and  Second  FNPRM,  18  FCC  Rcd  at  25361-  62,  para.  50. 


 6  Id.  at  25365,  para.  59. 
 7  Our  preliminary  analysis  indicates  that  fewer  than  half  of  the  states  have  even  considered  legislation  or  regulation 
 imposing  E911/  MLTS  requirements.  For  a  list  of  states  that  have  imposed  E911/  MLTS  requirements,  see  for  example,  APCO  International,  State  Legislative  Summary,  http://  www.  apcointl.  org/  about/  pbx  (accessed  Nov.  22, 


 2004)  or  RedSky  Technologies,  Inc.,  Current  E-  911  Legislation,  http://  www.  enhanced911.  com/  src/  03_  sec/  e911/  media/  E-  911%  20Enacted%  20Legislation.  pdf  (accessed  Nov.  22, 
 2004). 
 8  See,  for  example,  83  Ill.  Adm.  Code  726. 


 9  See  MLTS  Proposal  of  NENA  and  APCO,  CC  Docket  No.  94-  102  (filed  July  24,  2001)  (  Model  Legislation). 
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 The  Commissions  E911  Report  and  Order  and  Second  FNPRM  states:  we  believe  that  the  Model  Legislation  submitted  by  NENA  and  APCO  offers  the  states  a  valuable  blueprint  for  their  own 
 laws,  and  we  strongly  support  the  approach  taken  by  the  model  legislation.  10  With  this  view  of  the  model  legislation,  we  request  information  regarding  how  it  has  affected  efforts  by  the  states  to  produce 
 their  own  statutes.  In  particular,  please  describe  how  this  model  legislation  has  been  used  in  determining  states  approaches,  how  extensively  this  model  legislation  has  been  and  is  being  used,  and  its  perceived 
 shortcomings. 
 In  addition  to  use  of  this  particular  model  legislation,  we  invite  comment  as  to  whether  there  are  any  other  models  that  states  have  found  useful  in  developing  legislation,  e.  g.,  laws  passed  in  any  other 
 state.  We  ask  commenters  to  identify  such  examples  and  analyze  their  possible  utility  for  widespread  use. 
 Carrier  Services  Provided  Under  State  Tariff 
 Although  our  primary  focus  is  evaluating  state  action  addressing  E911/  MLTS  issues,  we  also  seek  comment  on  the  extent  to  which  carriers  and  others  offer  E911  solutions  for  MLTSs.  It  appears  that 
 at  least  one  carrier  is  providing  E911  service  for  MLTSs  under  tariff  in  at  least  one  state,  11  and  that  carrier  works  with  individual  MLTS  operators  elsewhere  within  its  footprint  to  implement  customer-  specific 
 solutions  if  such  are  economically  and  technically  feasible.  12  We  seek  comment  regarding  the  availability  of  E911/  MLTS  services  offered  under  tariff  or  otherwise  both  in  states  that  have  passed  E911/  MLTS 
 legislation  or  adopted  E911/  MLTS  regulations  and  in  states  that  have  not.  In  particular,  where  these  services  are  offered  absent  state  legislative  or  regulatory  action,  we  seek  comment  regarding  the  reasons 
 the  services  were  developed. 
 Specifically,  commenters  should  (1)  identify  the  carrier  and  the  state  or  states  in  which  that  carrier  offers  or  plans  to  offer  E911  service  for  MLTSs;  (2)  provide  links  to  the  carriers  published  tariffs, 
 and  identify  the  effective  dates  of  those  tariffs,  where  applicable;  (3)  identify  the  salient  technical  features  of  each  service  offered  under  tariff,  including  but  not  limited  to  which  MLTS  technologies  are  supported 
 (e.  g.,  Centrex,  analog  PBX,  ISDN  PBX,  non-  ISDN  digital  PBX,  IP-  PBX,  or  key  system),  which  E911  MLTS-  to-  network  technical  interface  standards  or  other  specifications  are  supported  (e.  g.,  CAMA  13  or 
 Primary  Rate  Access  (PRA)  ISDN  14  ),  and  any  special  requirements  regarding  trunking  arrangements  or 


 10  See  E911  Report  and  Order  and  Second  FNPRM,  18  FCC  Rcd  at  25361-  62,  para.  50  &  n.  179. 
 11  See  Verizon  New  York  Inc.,  Tariff  PSC  NY  No.  1,  Section  19,  at  16-  20. 
 12  Verizon  Comments,  CC  Docket  No.  94-  102  (filed  March  29,  2004),  at  1. 
 13  Centralized  Automatic  Message  Accounting  (CAMA)  is  an  "arrangement  that  provides  for  the  recording  of 
 detailed  billing  information  at  a  centralized  location  other  than  an  end  office,  usually  a  tandem.  CAMA  equipment  also  may  be  associated  with  operator  systems,  etc."  See  Telcordia  Notes  on  the  Networks,  Telcordia  Technologies 


 Special  Report,  SR-  2275,  Issue  4,  October  2000  at  Glossary  (TELCORDIA  NOTES  ON  THE  NETWORKS).  A  CAMA  trunk  can  be  used  to  transmit  a  caller's  ANI  or  another  number  used  to  identify  the  caller's  location. 


 14  The  Integrated  Services  Digital  Network  (ISDN)  is  an  "integrated  digital  network  in  which  the  same  digital 
 switches  and  digital  paths  are  used  to  establish  connections  for  different  services,  for  example,  telephony,  data."  See  TELCORDIA  NOTES  ON  THE  NETWORKS  at  Glossary.  An  ISDN  Primary  Rate  Access  (PRA)  line  "offers  23  B 


 channels  and  1  D  channel,  also  known  as  23B  +  D.  Information  is  delivered  over  a  single  T1-  carrier  system  at  a  rate  of  1.  544  Mbps,  which  includes  8  kbps  for  overhead.  PRA  ISDN  is  full  duplex  and  can  serve  large-  business 
 applications  and  PBXs."  See  TELCORDIA  NOTES  ON  THE  NETWORKS  at    14.9.5.2. 
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 the  use  of  Direct  Inward  Dial  (DID)  numbers;  (4)  identify  salient  operational  characteristics  of  the  service;  (5)  identify  the  Automatic  Location  Identification  (ALI)  database  interface  options  and  costs  for 
 MLTS  operators,  the  procedural  impacts  on  MLTS  operators,  and  the  ALI  database  interface  standards  or  specifications  supported;  (6)  indicate  whether  PSAPs  generally  have  been  able  to  receive  and  utilize  the 
 ALI  and  call-  back  information  provided  and,  if  not,  why  not;  (7)  estimate  the  degree  to  which  the  offerings  satisfy  or  cover  the  MLTS  market;  and  (8)  identify  real  or  perceived  technical,  economic, 
 operational  and  other  impediments  to  full  E911  coverage  for  MLTSs. 
 Where  specific  technical  features  are  required  by  state  legislation  or  regulation,  we  ask  that  commenters  identify  those  features.  For  those  states  where  E911/  MLTS  service  is  provided  under 
 customer-  specific  arrangements,  such  as  individual  case  basis  (ICB)  arrangements,  we  ask  that  commenters  present  and  discuss  all  relevant  information  to  allow  us  to  characterize  the  available  technical 
 features.  In  each  case,  commenters  should  be  sufficiently  complete  and  specific  in  their  descriptions  of  requirements  and  references  to  standards  to  enable  us  to  develop  a  comprehensive  picture  of 
 commonalities  and  differences  in  E911/  MLTS  implementation  across  the  states. 
 Comment  Filing  Procedures 
 Pursuant  to    1.415  and  1.  419  of  the  Commission's  rules,  47  C.  F.  R.    1.415,  1.419,  interested  parties  may  file  comments  and  reply  comments  on  or  before  the  dates  indicated  on  the  first  page  of  this 
 document.  Comments  may  be  filed  using  the  Commission's  Electronic  Comment  Filing  System  (  ECFS)  or  by  filing  paper  copies.  See  Electronic  Filing  of  Documents  in  Rulemaking  Proceedings,  63 
 FR  24121  (1998).  When  filing  comments,  please  reference  CC  Docket  No.  94-  102.  Comments  may  be  filed  electronically  using  the  Internet  by  accessing  the  ECFS  at  http://  www.  fcc.  gov/  cgb/  ecfs/  and 
 following  the  instructions  provided  on  the  website.  Generally,  only  one  copy  of  an  electronic  submission  must  be  filed.  In  completing  the  transmittal  screen,  commenters  should  include  their  full  name,  U.  S. 
 Postal  Service  mailing  address,  and  the  applicable  docket  number.  Parties  may  also  submit  an  electronic  comment  by  Internet  e-  mail.  To  get  filing  instructions  for  e-  mail  comments,  commenters  should  send  an 
 e-  mail  to  ecfs@  fcc.  gov,  and  should  include  the  following  words  in  the  body  of  the  message,  get  form  <your  email  address.  A  sample  form  and  directions  will  be  sent  in  reply. 


 Parties  who  choose  to  file  by  paper  must  file  an  original  and  four  copies  of  each  filing.  Filings  can  be  sent  by  hand  or  messenger  delivery,  by  commercial  overnight  courier,  or  by  first-  class  or  overnight 
 U.  S.  Postal  Service  mail  (although  we  continue  to  experience  delays  in  receiving  U.  S.  Postal  Service  mail).  The  Commission's  contractor,  Natek,  Inc.,  will  receive  hand-  delivered  or  messenger-  delivered 
 paper  filings  for  the  Commission's  Secretary  at  236  Massachusetts  Avenue,  N.  E.,  Suite  110,  Washington,  D.  C.  20002.  The  filing  hours  at  this  location  are  8:  00  a.  m.  to  7:  00  p.  m.  All  hand  deliveries  must  be  held 
 together  with  rubber  bands  or  fasteners.  Any  envelopes  must  be  disposed  of  before  entering  the  building.  Commercial  overnight  mail  (other  than  U.  S.  Postal  Service  Express  Mail  and  Priority  Mail)  must  be  sent 
 to  9300  East  Hampton  Drive,  Capitol  Heights,  MD  20743.  U.  S.  Postal  Service  first-  class  mail,  Express  Mail,  and  Priority  Mail  should  be  addressed  to  445  12th  Street,  SW,  Washington,  D.  C.  20554.  All  filings 
 must  be  addressed  to  the  Commission's  Secretary,  Office  of  the  Secretary,  Federal  Communications  Commission.  One  copy  of  each  filing  must  be  sent  to  Best  Copy  and  Printing,  Inc.,  Portals  II,  445  12th 
 Street,  SW,  Room  CY-  B402,  Washington,  DC  20554,  telephone  1-  800-  378-  3160,  or  online  at  www.  bcpiweb.  com. 


 Parties  who  choose  to  file  by  paper  must  also  send  three  paper  copies  of  their  filing  to  the  attention  of  Michael  Goldstein,  Industry  Analysis  and  Technology  Division,  Wireline  Competition 
 Bureau,  Federal  Communications  Commission,  445  12th  Street,  S.  W.,  Room  5-  A422,  Washington,  DC  20554. 
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 Pursuant  to    1.1206  of  the  Commissions  rules,  47  C.  F.  R.    1.1206,  this  proceeding  will  continue  to  be  conducted  as  a  permit-  but-  disclose  proceeding  in  which  ex  parte  communications  are 
 permitted  subject  to  disclosure. 
 For  Further  Information 
 Contact  Michael  Goldstein,  Wireline  Competition  Bureau,  (202)  418-  0806,  michael.  goldstein@  fcc.  gov;  or  Cathy  Zima,  Wireline  Competition  Bureau,  (202)  418-  7380, 
 cathy.  zima@  fcc.  gov.  Users  of  TTY  equipment,  call  (202)  418-  0484. 
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