It’s no great secret that for several years now California has been touted as being very progressive with its enhanced 911 (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 recently, 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 [Multi-Line Telephone System] owned and operated by the state to be able to transmit the required information with 911 calls.”
Most people know that when they call 911 from a landline telephone, their name and location data is automatically sent to the 911 dispatcher (thus, why it’s called “enhanced 911.”) But what about when you call from inside an office that has multiple phone lines, running through a Multi-Line Telephone System? The new proposed legislation in California would require that companies running an MLTS phone system route the caller to a Public Safety Answering Point (or PSAP) with the “automatic display of the callers number address and location of the phone.”
The concern among businesses is that upgrading Multi-Line Telephone Systems will incur extra costs.
As stated earlier in the PUC report, only a small fraction of companies would be affected by this new legislation. However, those small number of companies account for a large majority of people serviced by these systems.
The report estimates that 95 percent of the 1.3 million businesses and government agencies within California would be exempt from this legislation, and the remaining 65,000 businesses “employ 9,521,366 Californians or 60.5 percent 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 of managing locations at the individual device level.
As the NENA model legislation states, zone level reporting with the appropriate onsite 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 multi-line 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 a 6-month window at the beginning of the bill’s effective date to allow those businesses with construction plans already in place a short grace period.
“There’s an old adage about never wanting to watch either legislation or sausage being made,” said APN Legal Correspondent Martha Buyer. “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.”