DOCKET ALECOpy OR\G\NAL
`
`Before the
`FEDERAL COMMUNICATIONS COMMISSION
`Washington, D. C.
`20554
`
`FCC 94-237
`
`In the Matter of
`
`Revision of the Commission's rules
`to ensure compatibility with
`enhanced 911 emergency calling systems
`
`CC Docket No. 94-102
`
`RM-8143
`
`NOTICE OF PROPOSED RULE MAKING
`
`Adopted:
`
`September 19, 1994 Released: October 19, 1994
`
`By the Commission:
`
`January 9, 1995
`Comment Date:
`Reply Comment Date:
`February 8, 1995
`
`TABLE OF CONTENTS
`
`TOPIC
`
`I.
`
`:INTRODUCTION
`
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`I I. BACltGROOND
`Private Branch Exchange and Dispersed Private Telephone
`Systems .
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`,Enhanced 911 and Wireless Systems
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`
`B.
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`III. COMPATIBILITY OP PBX BQUIPMENT ~TB 911 SYSTEMS
`A.
`Adcomm and Industry Proposals
`.
`.
`.
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`Adcomm Petition .
`.
`.
`.
`Industry Efforts
`.
`Comments
`.
`. . .
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`Discussion .
`.
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`911 Availability .
`.
`Attendant Notification.
`.
`ALI database maintenance
`.
`Station Number Identification (SNI)
`Information Protocol Standard. . . .
`Network Interface Standards.
`. . .
`Local Exchange Company Services.
`.
`Implementation Schedule
`.
`.
`.
`.
`C.
`rv. Compatibility of Wirele•• Service. with
`BDhanaed 911 .
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`Discussion
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`911 availability
`.
`Grade of service. . .
`911 call priority.
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`PARAGRAPH.
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`1
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`3
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`8
`9
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`11
`13
`13
`14
`15
`19
`22
`23
`24
`26
`27
`28
`29
`30
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`32
`37
`41
`42
`44
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`User location information.
`Re-ring/call back
`Common Channel Signaling
`Access to text telephone devices (TTY)
`Equipment Manufacture,
`Importation, and Labeling
`
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`V. ADDITIONAL CONSIDERATIONS .
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`Privacy
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`Compatibility with Network Services
`Preempt ion
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`VI. CONCLUSION
`
`VII. ORDERING CLAUSE
`
`VIII. ADMINISTRATIVE PROVISIONS
`Initial Regulatory Flexibility Analysis.
`Comment dates.
`.
`.
`.
`. . .
`. . . .
`
`APPENDIX A
`
`INITIAL REGULATORY FLEXIBILITY ANALYSIS
`
`APPENDIX B 911 CALL FEATURES
`
`APPENDIX C PROPOSED RULES
`
`APPENDIX D EMERGENCY ACCESS POSITION PAPER
`
`45
`52
`53
`54
`55
`
`56
`56
`58
`. 59
`
`60
`
`62
`
`63
`64
`65
`
`I.
`
`INTRODUCTION
`
`the Commission proposes to amend its
`In this proceeding,
`1.
`regulations to address issues raised by the provision of 911 and
`enhanced 911 services through certain telecommunications
`technologies. The primary objective of this proceeding is to
`ensure broad availability of 911 and enhanced 911 services to
`users of the public switched telephone network (PSTN) whose
`health and safety may depend on 911 emergency services systems.
`Toward this end, we intend to ensure that the effective operation
`of 911 s~rvices is not compromised by new developments in
`telecommunications. First, we address a petition filed by the
`Adcomm Engineering Company ("Adcomm")
`to amend Part 68 of the
`rules by proposing technical performance requirements that ensure
`the compatibility of private branch exchanges (PBXs) with
`enhanced 911 emergency services. l
`In this Notice of Proposed
`
`Comments were filed by Associated Public-Safety
`l
`Communications Officers,
`Inc.
`(APCO) , Bell Atlantic, BellSouth,
`GTE, South Carolina Budget and Control Board, and the
`Telecommunications Industry Association (TIA) , and reply comments
`were filed by Adcomm and the North American Telecommunications
`Association (NATA).
`
`2
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`Rulemaking, we seek comment on proposals for ensuring the
`compatibility of private branch exchanges
`(PBXs) and other
`dispersed private telephone systems with enhanced 911 emergency
`services.
`
`2. Second, we propose to adopt rules that would require
`wireless -services,
`in particular commercial mobile radio services
`(CMRS)2 that provide real time voice services,
`to include
`features that will make enhanced 911 services available to mobile
`radio callers.
`These features include Station Number
`Identification (SNI) , Automatic Location Information (ALI),
`Selective Routing (SR), and other features for 911 calls provided
`over wireless mobile units. This action responds to a Petition
`for Reconsideration filed by the Texas Advisory Commission on
`State Emergency Communications
`(TX-ACSEC) under the Office of the
`Attorney General for the state of Texas. 3
`It also responds to
`the issues raised in the Emergency Access Position Paper filed
`recently by the Associated Public Safety Communications
`Officials-International,
`Inc.
`(APCO),
`the National Emergency
`Number Association (NENA),
`the National Association of State Nine
`One One Administrators (NASNA), and the Personal Communications
`Industry Association (PCIA).4
`
`II. BACKGROUND
`
`in 1965 that the digits 9-1-1
`Since AT&T's announcement
`3.
`would be made available nationally as an emergency telephone
`number,
`the use of 911 for emergency purposes has become
`in
`widespread.
`The Commission's Network Reliability Council,
`performing a special study of the reliability of 911 services,
`found that "the American public depends on 911 services in its
`
`2 CMRS is defined as "any mobile service ... that is provided
`for profit and makes interconnected service available (A)
`to the
`public or (B)
`to such classes of eligible users as to be
`effectively available to a substantial portion of the public .... "
`The term "interconnected service" means "service that is
`interconnected with the public switched network .... " Omnibus
`Budget Reconciliation Act of 1993, Pub.L.No. 103-66, Title VI,
`§§6002 (b) (3) (B), 107 Stat 312, 392 (1992) .
`
`3 The Petition for Reconsideration was filed in response to
`Amendment of the Commission'S Rules to Establish New Personal
`Communications Services, GEN Docket No. 90-314, September 23,
`1993, 8 FCC Rcd 7700 (1993) (Second Report and Order). Because
`this inquiry is broader than the proposals made in the TX-ACSEC
`petition, we are initiating this separate proceeding.
`
`4 This paper was filed on July 5, 1994, as an ~ parte
`comment to GEN Docket No. 90-314.
`It is attached at Appendix D.
`
`3
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`emergencies. liS The Council found that 89 percent of the wireline
`access lines in the United States are served by some form of 911
`service and that the service is increasingly engineered to
`provide.a high level of reliability.6 Currently, about 260,000
`calls nationwide are placed to 911 every day.
`
`4.911 emergency services enable telephone users to
`receive, and state and local governments to provide, fast
`response to emergency situations.
`The ability to dial 911 offers
`several advantages to users. First, it is a single, nationally
`used three-digit number that is easy to remember and dial in
`emergency situations. This provides callers,
`including children,
`with easy access to emergency services in areas where the
`telephone number for the various emergency service providers is
`not readily known.
`Second, because 911 calls are sent to Public
`Safety Answering Points (PSAPs) over dedicated telephone lines,
`these calls are recognized and answered as emergency calls by
`professionals trained to assist callers in need of emergency
`assistance. Third,
`the use of 911 shortens the response time to
`requests for assistance because PSAP professionals have ready
`access to police, fire, and health emergency response service
`providers.
`s.
`There are different levels of 911 services available,
`depending on the location. Basic 911 service is a forwarding
`arrangement in which calls dialed to the 911 telephone number are
`translated at a telephone company switch and are transmitted to a
`public safety agency for response. Most emergency systems,
`however, have enhanced this service.
`
`Enhanced 911 systems help emergency services personnel
`6.
`achieve the shortest possible emergency response time by using
`Automatic Number Identification (ANI)' to route an emergency call
`
`S Network Reliability; A Report to the Nation, National
`Engineering Consortium, June, 1993 at Section F, page 1.
`
`6 Wireline carriers and 911 service providers may employ
`diverse routing of interoffice facilities, multiple 911 tandem
`switch architectures, alternate public safety answering positions
`(PSAPs), special marking of 911 equipment, back-up power sources
`for PSAP facilities and diverse links for automatic line
`identification database access to ensure 911 service is reliable.
`
`, The use of the term "automatic number identification ll or
`in this NPRM is not
`intended as a reference to billing
`"ANIII
`number presentation provided as part of Feature Group B or D
`local exchange services. Although the number presented to a PSAP
`on a wireline call is often derived from Feature Group B or D
`services,
`the number presented to a PSAP on a wireless call may
`be generated by several other means.
`Thus,
`the term ANI merely
`
`4
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`to the PSAP nearest the caller's location. At a minimum,
`enhanced 911 service provides the PSAP with the ANI of the
`calling party, permitting the PSAP to call back in the event the
`call is disconnected.
`A fully enhanced 911 system not only
`displays the ANI, but also permits an attendant at the PSAP to
`identify the calling party's address through the use of an
`The
`external Automatic Location Identification (ALI) database.
`ALI feature also permits selective routing (SR) of the call to
`the appropriate PSAP for the identified location and displays the
`public safety agencies (fire, police and emergency medical
`services) covering that location on the PSAP terminal. 8 A fully
`enhanced 911 system may also provide the PSAP with other
`information,
`including the name of the subscriber, city, zip
`code,
`telephone number, date,
`time of day, and the class of
`telephone service (business, residential, etc.).9 Approximately
`85% of 911 services include some form of enhanced 911 service.
`
`7. Congress created the Federal Communications Commission
`IIfor the purpose [among others] of promoting safety of life and
`property through the use of wire and radio communication .... 1110
`This Commission has jurisdiction to license the electromagnetic
`spectrum, and also to regulate "instrumentalities, facilities
`[and] apparatus lI
`through which wire and radio services are
`provided. 11
`It is difficult to identify a nationwide wire or
`radio communication service more immediately associated with
`promoting safety of life and property than 911. We believe that
`broad availability of 911 and enhanced 911 services will best
`promote IIsafety of life and property through the use of wire and
`radio communication. II
`
`8.
`Systems.
`
`Private Branch Exchange and Dispersed Private Telephone
`Private Branch Exchange (PBX) and other dispersed
`
`identifies a number associated with the caller and used to
`reference the caller'S location.
`The term does not reflect a
`specific service or technology.
`
`8 Selective routing is not needed in all areas. This
`feature is useful when telephone exchange boundaries extend into
`two or more PSAP jurisdictions.
`
`9 A list of the 911 call features currently available to
`many emergency call taking organizations,
`listed in order of
`is shown in
`importance as defined by NENA/APCO leadership,
`Appendix B.
`
`·10
`
`11
`
`47 U.S.C. §151.
`
`47 U. S. C. §151, §153 (a),
`
`(b), Titles II and III.
`
`5
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`private telephone systems may present location identification
`problems for emergency- services personnel.
`PBX systems route
`calls between telephone stations in an organization and connect
`those stations to the public switched telephone network through
`trunk lines. A single PBX may serve a number of different
`buildings. When a caller dials 9-1-1 from a station served by a
`PBX, a PSAP attendant may be able to retrieve the street address
`of a main building (the billing address associated with the ANI) .
`Determining the precise location of the caller within a large
`building or at a station within a PBX that serves more than one
`building, however, may be complicated and time-consuming in a
`situation where time is critical. 12 While it is technically
`feasible to include location identification information in
`transmitting calls from stations served by PBX or other dispersed
`private telephone systems,
`there currently is no uniform means
`for ensuring that this information reaches emergency services
`personnel. Moreover,
`telephone users mayor may not be aware
`that their telephone service is provided through PBX systems,
`and,
`in any event, are unlikely to be aware of 911 capabilities
`or limitations of the PBX systems. Yet,
`the ability of 911
`service providers to deliver life saving services to them may
`depend on PBX compatibility with enhanced 911 systems.
`
`Enhanced 911 and Wireless Systems. While some wireless
`9.
`systems are capable of providing basic 911 service,
`few,
`if any,
`are currently capable of providing an enhanced 911 service. This
`raises public policy concerns because the number of calls to 911
`from wireless users, such as cellular telephone customers;
`is
`increasing rapidly. More than 13,000 new cellular telephones are
`installed daily in the United States. 13
`In major metropolitan
`areas, it is estimated that as many as 10% of the 911 calls
`originate from mobile radio service subscribers. 14 For example,
`in January 1993, one California Highway Patrol communication
`facility fielded 80,000 calls for emergency assistance, 25,076 of
`which were from cellular telephones. 1s
`In 1987,
`the
`
`See Adcomm Petition at 3, citing a newspaper report of
`12
`a fatality attributable partly to the misdirection of medical aid
`to a caller using a private phone system.
`
`13 This figure is based on 1993 data, as published in ~
`Wireless Factbook, Cellular Telecommunications Industry
`Association, Spring 1994, p. 6.
`
`(July 27, 1994)
`"NARUC Notebook"
`Communications paily,
`14
`quoting Leah Senitte of the National Emergency Number
`Association.
`
`This number for cellular telephone calls does not
`lS
`include calls from fixed cellular "Freeway Call Boxes." ~, W.
`Clay Paxton, "Future Vision II:
`The 9-1-1 Imperative", NENA
`
`6
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`Massachusetts state police received only about 300 cellular calls
`per month.
`By December 1992,
`that number had grown to more than
`15,700. 16 We expect growth in the use of mobile radio services
`to continue.
`It has been estimated that by 1998 there will be 32
`million cellular customers and 2.6 million Personal
`Communications Networks customers. 17
`10.
`The continuing growth of mobile radio service customers
`will increase the number of 911 calls that are placed from mobile
`telephones. As currently configured, however, wireless 911
`services are inferior to the wireline 911 services that telephone
`users have come to expect. Specifically, 911 calls originated by
`mobile radio users generally do not provide PSAP attendants with
`the caller's precise location. Because the callers may not know
`their location,18 the ability of emergency service personnel to
`respond is hindered. 19
`
`See also, George
`News, Vol. 12, No.2, May 1994, at pp. 20-28.
`Raine, "Cellular Phone Owners Dialing 911 Frivolously", The San
`Francisco Examiner, February 25, 1993.
`
`See also, Tony Rogers,
`16 ~ W. Clay Paxton, QQ. cit.
`"Cellular Samaritans Becoming the Eyes of the Highway Patrol",
`Associated Press, January 5, 1993.
`
`17 The Wireless Factbook, Cellular Telecommunications
`Industry Association, Spring 1994 p. 36.
`
`In Los Angeles County, 600,000 cellular/mobile 911 calls
`18
`were placed in 1992. More than 25 % of the callers could not
`identify their location. This information was related by William
`E. Stanton, Executive Director of NENA, during a presentation at
`the FCC on March 23, 1994.
`
`19 The following example illustrates the difficulties posed
`by the use of mobile radio services to reach 911 emergency
`services. At 2:50 AM on September 22, 1993,
`the Amtrak Sunset
`Limited derailed from the Bayou Canot Bridge in a remote area of
`the Mobile Delta.
`The mayday call from the train was received by
`the CSX Railroad office in Mobile which placed a call to 911, but
`incorrectly identified the location of the derailment as Bayou
`Sara, several miles south of the actual location. Consequently,
`dispatched rescue units were unable to find the derailed train.
`Subsequent to this action, a second call to 911 came in from an
`Amtrak employee on the derailed train using a cellular phone.
`The Amtrak employee was able to tell the 911 operator only that
`the derailment was somewhere on the Mobile River. While Mobile
`County has a modern enhanced 911 system, it was of no value with
`these calls.
`The first call displayed the address of the CSX
`station in downtown Mobile, and the second call from the derailed
`train displayed "mobile phone." ~ NENA News,
`"Mayday in the
`
`7
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`

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`III.
`
`COMPATIBILITY OF PBX EQUIPMENT WITH 911 SYSTEMS
`
`Several states and localities have passed regulations
`11.
`or ordinances for the purpose of requiring PBX equipment to be
`compatible with 911 systems. 20 The specific requirements,
`however, vary significantly from one state to another. While
`several types of equipment and services may be available to
`ensure accurate routing of 911 calls from PBX or other dispersed
`private telephone systems, a lack of uniformity in this equipment
`may impair public emergency services by delivering inaccurate,
`incomplete, or misleading call origination information to the
`public switched telephone network. Moreover; mutually
`incompatible systems for resolving this problem are likely to
`cause user confusion or higher costs in equipment or services.
`
`12. We propose to amend Part 68 our rules to ensure the
`compatibility of PBX equipment with enhanced 911 services.
`The
`record in this proceeding, discussed below,
`indicates that market
`forces to date have not been effective in implementing a solution
`to this problem. States and localities are considering separate
`and possibly conflicting regulations on PBX owners and equipment.
`Failure to address the problem quickly could result in increased
`costs as equipment that is not compatible with enhanced 911
`systems becomes more widely distributed. Accordingly, we find
`that it is in the public interest to propose rules to require
`that PBX and other dispersed private telephone systems
`(hereinafter referred to collectively as "PBX equipment") operate
`effectively with enhanced 911 systems.
`
`A. AdeoDllll and Industry Proposals
`
`13. Adcomm Petition. The Adcomm petition seeks to prevent
`situations in which the provision of emergency services to a
`caller is delayed because the caller's location cannot be
`precisely determined when the caller dials 9-1-1 from a telephone
`served by PBX equipment. 21 Adcomm proposes specific rules to
`ensure that telephone stations served by PBX equipment are
`compatible with public emergency access networks. Adcornm points
`out that the resolution of this problem will require accurate
`
`Mobile Delta," Dennis Stapleton, Vol. 12, No.2, May 1994, at pp.
`16-18.
`
`20 See,~, Mississippi Code 1972 Annotated, tit. 29,
`Chapter 5, §§ 19-5-303.
`
`21 The problem may also exist for key telephone systems
`connected to Centrex. ~ TIA Technical Systems Bulletin (TSB(cid:173)
`103),
`"PBX and KTS Support of Enhanced 911 Calling Service,"
`(October, 1993) at 3.
`
`8
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`

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`management of telephone number databases and may have
`implications for the North American Numbering Plan by creating
`additional demand for numbers. 22 Adcomm states, however,
`that
`its proposed amendments address only that aspect of Part 68
`concerned with preserving the integrity of emergency services
`provided on the public switched telephone networks.
`Specifically, Adcomm's proposed rules are II • • • simply intended to
`align interface approaches without proposing to control user
`implementations or local exchange carrier (LEC) services. 1123
`Adcomm's proposal would:
`(1)
`require PBX equipment to provide
`specific location information of the calling station to enhanced
`911 systems;
`(2)
`require premises owners to provide local
`(3)
`telephone companies with information on their PBX systems;
`require certain training, verification, supervision and testing
`procedures for PBX operation;
`(4) specify signal power
`limitations; and (5) set technical standards for compatibility
`with enhanced 911 systems,
`including trunk interface and
`signaling requirements.
`
`The Telecommunications Industry
`Industry Efforts.
`14.
`Association (TIA),
`through a subcommittee of its Multi-line
`Telecommunications Committee, has been working to develop
`technical standards for PBXs to resolve the Enhanced 911
`problem. 24
`In October, 1993, TIA issued a Technical Systems
`Bulletin (TSB-103) entitled "PBX and KTS Support of Enhanced 911
`Calling Service", which addresses dialing, call routing, and
`caller location database issues associated with PBX and KTS
`support of enhanced 911 service providers.
`TIA anticipates final
`voting by the membership on these proposals in late 1994.
`
`Commenters responding to Adcomm's petition
`15. Comments.
`generally acknowledge the need to ensure compatibility between
`PBXs and Enhanced 911 services, but take different positions on
`how compatibility may best be achieved. Bell Atlantic,
`BellSouth, GTE, and TIA urge the Commission to delay action
`
`22 The Commission is currently exam~n~ng various issues
`regarding administration of the North American Numbering Plan.
`~ Administration of the North American Numbering Plan, Notice
`of Proposed Rulemaking, CC Docket No. 92-237, 9 FCC Rcd 2068
`(1994) .
`
`23
`
`Adcomm Reply at 2.
`
`TIA is a membership organization of domestic and
`24
`international providers of telecommunications products and
`services. Through various committees, TIA develops engineering
`standards and publications that facilitate interchangeability and
`improvement of products.
`Standards developed by TIA committees
`and adopted by TIA ballots are voluntary industry standa~ds that
`represent an industry. consensus.
`
`9
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`The North American
`pending industry consensus on standards.
`Telecommunications Association (NATA) and the South Carolina
`Budget and Control Board (SCBCB) contend that the Commission
`should lead any such industry effort. SCBCB states it cannot
`endorse the Adcomm proposal due to potential technical and
`financial hardships.25 NATA objects to Adcomm's proposed
`verification requirements and opposes new training requirements
`installation personnel. 26
`on customer premises equipment
`(CPE)
`NATA argues that LECs do not offer the kind of interconnection of
`switched services that would permit PBXs to transmit station
`identification in a format that could be accepted or processed by
`the telephone network.
`
`16. APCO, which supports the petition, expresses concern
`about PBXs that block 911 calls in favor of an internal safety
`service. APCO is also concerned about
`the confusion caused when
`an extra digit must be dialed to get an outside line before
`dialing 911 from a PBX station in an emergency. BellSouth, GTE,
`and NATA express concern about
`the cost of dedicated 911 trunks
`and the impact of the proposal on the North American Numbering
`Plan (NANP) .27 Adcomm notes that the enhanced 911 trunking
`mentioned in its petition was not
`intended to require PBXs to
`have dedicated trunks to PSAPs. Adcomm states that, under its
`proposed rules, end users and LECs may choose different 'ways of
`handling trunking. 28 GTE suggests there are particular
`difficulties identifying the location of calls placed from
`college campuses, hospitals, military installations and wireless
`PBXS. 29
`
`Commenters identified several specific elements that
`17.
`should be included in any resolution of the PBX/enhanced 9i1
`compatibility issue.
`GTE states that compatibility will require
`the creation of a standard LEC/private switching system interface
`with identifying information for private switching system calling
`stations, private switching system compliance with NENA standards
`for the transmission of ALI data to the telephone company or
`caller location database, and the creation of either alternative
`number identification or Direct Inward Dial
`(DID) numbers for
`private switching system stations. 30 Bell Atlantic concurs with
`
`25
`
`SCBCB at 2.
`26 NATA 7-9.
`27 Bell South at 2; GTE at 5; NATA 2-23.
`28 Adcomm reply comments at 3.
`29 GTE at 5-6.
`
`30 GTE at 2-4.
`
`10
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`GTE that any technical standards should specifically include the
`signaling and protocol specifications that have been published by
`NENA,
`to ensure that calls sent from PBXs to 911 systems carry
`proper identifying information. 31 NATA states that any rules the
`Commission adopts should ensure that telephone companies develop
`and market
`the least costly form of Enhanced 911 interconnection,
`and that ·such costs be fairly distributed. 32 GTE asserts that a
`solution may also require added functionality in end office
`switches and additional telephone number assignments. 33
`
`TIA contends that Part 68 should specify as few
`18.
`technical details as possible to avoid stifling technological
`advancement of enhanced 911 services and equipment.
`In order to
`assure that enhanced 911 services will work properly, TIA states
`that the regulations should:
`(1) clearly define the
`responsibilities of all entities involved;
`(2)
`reference the
`appropriate standards to be used, preferably national;
`(3) set
`reasonable deadlines for compliance; and (4)
`involve regulatory
`agencies in educating the public regarding the deploYment and use
`of enhanced 911 calling service.
`
`B. Discussion
`
`19. We believe that federal rules for achieving uniformity
`are appropriate in these circumstances to avoid confusion among
`telephone users connected to PBXs and to ensure that PBX
`equipment operates on the public switched telephone network
`(PSTN) at an optimal level for emergency purposes.
`The Adcomm
`petition,
`the comments received, and published reports of
`difficulties in delivering emergency services to the proper
`location indicate that the incompatibility of PBXs with enhanced
`911 systems is hampering public safety access through the public
`switched telephone network.
`
`20. We propose to amend Part 68 of the rules to require
`compatibility of PBX equipment with enhanced 911 systems. We
`agree with Adcomm and several commenters that any Part 68
`requirements must
`take into account
`industry standards, protocols
`and technical references. Moreover,
`the comments persuade us
`that any proposal for amending our rules must consider not only
`the delivery of ANI, but also issues such as ALI database
`administration and the delivery of other information, ~.,
`calling party number,
`to the PSAP that may facilitate a more
`timely emergency response. We,
`therefore,
`initiate a Notice of
`
`31 Bell Atlantic at 1-2. A copy of the NENA protocol is
`attached as a appendix to Bell Atlantic's comments.
`
`32
`
`33
`
`NATA at 4-5, 6-7.
`
`GTE at 2-3, 4-6.
`
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`
`Proposed Rulemaking to require compatibility of PBX equipment
`with enhanced 911 systems.
`The proposed rules are patterned
`closely after those proposed by Adcomm, with modifications to
`reflect some of the commenters' concerns. We seek comment on
`these proposed rules.
`
`In considering the proposed rules, our paramount
`21.
`concern is to ensure that PBX equipment does not hinder delivery
`of emergency services by impeding the transmission of adequate
`location information over the PSTN. We believe that any rules
`adopted must provide sufficient flexibility to foster the
`development of alternative methods and technological
`innovation
`in resolving compatibility problems between PBX and other
`dispersed private telephone systems and enhanced 911 systems.
`Moreover, we believe that the proposed rules should carefully
`balance the need to achieve compatibility and the need to ensure
`that equipment owners and manufacturers are not unduly burdened
`in implementing such upgrades. We seek comment on whether the
`proposed rules permit sufficient flexibility in conforming PBX
`systems to the needs of their owners while ensuring that the
`location of callers to 9-1-1 is properly identified to PSAP
`operators. We seek comment on whether and how equipment
`manufacturers, multi-line telephone system (MLTS) service
`providers,
`local exchange carriers, public safety agencies, and
`others such as local building inspectors should be identified as
`responsible parties, as suggested in TSB-103. Commenters
`supporting this suggestion should discuss specific amendments to
`Part 68 that would achieve this objective.
`Further, we ask that
`commenters provide detailed analysis of the technical and cost
`considerations of implementing the proposed rules for equipment
`owners, equipment manufacturers, network service providers, and
`other affected parties.
`In addition, we seek comment on whether
`there are particular difficulties in applying the proposal to
`college campuses, hospitals, military installations or wireless
`PBXs, and on whether the proposed rules must be applied where the
`equipment serves a physically small location, such as a single
`story building, or a small number of closely situated telephone
`stations. Commenters should propose specific alternative language
`where they do not believe the proposed language is appropriate.
`
`911 Availability. Both the Adcomm proposal and TSB-103
`22.
`would require that PBX equipment properly route emergency calls
`dialed using the digits 911 or 9-911 (where 9 must be dialed to
`reach outside lines).
`TSB-103 notes that special dialing or
`routing features in PBX equipment, such as dial 9 blocking to
`prevent toll fraud and Automatic Route Selection for least cost
`routing, should not be implemented in ways that prevent 911
`dialing. We tentatively conclude that a caller at a PBX station
`having the capability to reach the public switched network should
`have" the ability to reach emergency services by dialing 911
`without having to dial any additional digits.
`TSB-103 suggests
`that some form of user education or notification may be
`
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`
`appropriate to ensure proper dialing by the casual user of
`terminal equipment within a PBX or dispersed private telephone
`system. We further propose to require that PBX equipment
`domestically manufactured or imported prior to the proposed
`implementation date of the rules be labelled with a warning
`describing its limitations for those attempting to use it to call
`enhanced °911. We seek comment on these proposed rules.
`
`TSB-103 recommends that new
`23. Attendant Notification.
`PBX equipment be capable of alerting an attendant or other on(cid:173)
`premises personnel and providing calling station information to
`such personnel when a 911 call is dialed. On-premises personnel
`may assist emergency services personnel
`in locating or assisting
`the caller, particularly on large premises like schools, hotels,
`or military installations.
`TSB-103 points out that some state
`laws prohibit attendant "bridge-on" to a 911 call (~, a three
`way emergency call that includes the 911 caller, an attendant,
`and the PSAP operator) because it may create confusion. We
`propose to require PBX equipment to be capable of notifying an
`attendant,
`if one is present, and seek comment on our proposal.
`See Appendix C, proposed §68.320(e). We ask that commenters
`discuss any potential conflict with existing state or local
`regulations.
`24. ALI database maintenance.
`Several commenters, as well
`as TSB-103, note that timely and accurate database maintenance is
`an essential element of enhanced 911 service.
`TSB-103 contends
`that any regulations should clearly define the responsibiolities
`of all parties involved in implementing an enhanced 911 system.
`As noted above, accurate caller location information is vital to
`ensuring the timely delivery of emergency services through the
`public switched telephone network. TSB-103 demonstrates that a
`variety of customer premises equipment configurations or network
`services may perform this function. Both Adcomm and TSB-103
`envision database maintenance as a separate issue from that of
`PBX equipment compatibility with enhanced 911.
`
`25. We propose to require coordination procedures to ensure
`accurate and timely transmission of database information by PBX
`owners to local exchange carriers. We expect that the proposed
`rules will permit accurate