18 states in the US currently have legislation regarding multiline telephone systems or MLTS. For the most part, that legislation doesn’t really have much teeth, as there are no penalties for noncompliance. The one exception to that rule is the state of Michigan who passed a law last year requiring businesses to remediate their 911 functionality by 2017, or they would be faced with penalties up to $5000.

WCAX Channel 3 in Montpelier, Vermont ran a story this past week highlighting a problem with schools and the states 911 system. In a recent interview, Rep. Joan Lenes (D-Shelburne) stated that the House and Senate Committees just recently learned that many of the states schools telephone systems have recently been centralized according to their town or district. When you centralize a telephone system, or flatten, consolidate and extend (FCE), you can create a 911 problem for users on the system.

Today’s 911 network operates off of a very simple principle. A telephone number equals an address. When the 911 system was first built in 1968, that factoid was mostly true. However today, a telephone number is probably the least significant piece of information that equals your location. Just think of your cell phone. It doesn’t matter what town you’re in, or the county, or even the state. Your cellular telephone number is transported with you wherever you go.

The logical question one might ask is “why is this not a problem for cell phones?” The answer to that is the FCC mandated Phase 1 and Phase 2 location reporting functionality built into that network. In simple terms, special p-ANI telephone numbers are associated with each cellular tower antenna, are “borrowed” by the cell phone making a 911 call, and these numbers are able to have their location information dynamically updated by the cell phone carrier. Phase 1 emergency calls provide the cellular tower coordinates to the 911 dispatcher, and within a few seconds after answering the call, the network is queried by the PSAP, and if the specific XY coordinates of the device are available, they are returned to the 911 center in the Phase 2 data.

Similar functionality is available in the Enterprise, however it does bear extra costs in addition to the location discovery automation that’s required in the enterprise network. Because of these extra costs, it is commonly used for remote VPN workers that are very migratory in their locations, and internally within enterprise networks other more cost conscious solutions are available.

But when you examine the map of the US that shows the states that require 911 remediation for MLTS PBX systems, Vermont is clearly marked as a state having legislation. If this is the case, why does this problem exist at the school systems? The answer to that unfortunately is that Vermont has one of the leaner pieces of legislation, and in fact, is a single sentence.

From Act 197 (S.311)

When an enhanced 911 system is implemented, any privately owned telephone system shall provide to those end users the same level of 911 service that other end users in the area receive and shall provide ANI signaling, station identification data and updates to enhanced 911 data bases under rules adopted by the board, except that the board may waive the provisions of this section for any privately owned telephone system, taking into consideration the costs and the public benefits of compliance, in accordance with standards and procedures adopted by the board by rule.

Although this is light on text, it does have some specific language that I happen to like. “Any privately owned telephone system shall provide to those end-users the same level of 911 service that other end-users in the area receive”. We’ve seen language like that in other states, such as Massachusetts, however regardless of any of this, the important piece that’s missing from this, and most other pieces of legislation, is the penalty for noncompliance.


I CAN’T DRIVE . . . 55
When you drive down the highway, and you exceed the posted speed limit, if you see a state trooper parked on the side of the highway, you intuitively slowdown. Do you do this because you’re reminded of the National Transportation Safety Boards statistics on highway deaths caused by speeding? Probably not. You’re worried about getting a $200 or more speeding ticket, and you’re worried about your insurance premiums that are probably already too high. You see, we are very predictable creatures. And one thing that does motivate most of us, is a potential financial impact.

Going back to the state of Michigan, just the potential threat of a $5000 penalty five years into the future, provoked enterprises to look at their 911 configuration, and do something about it. The state of California heard testimony in their Public Utilities Commission workshop a few years back, and added in penalties for noncompliance in their recommendations. That potential law is circulating through the legislative process as we speak, and there are hopes that it will be presented for a public vote this year.

Rep. Lenes correctly stated that “sometimes it’s not an expensive fix” and that the House committee has requested information from the schools that will be evaluated before they decide how they need to proceed statewide. In alignment with the California Public Utilities Commission estimate that 70% to 80% of PBX systems are not in compliance, she believes the same will be true for schools in Vermont.