FCC 94-237
`
`Federal Communications Commission Record
`
`9 FCC Red No. 22
`
`Before the
`Federal Communications Commission
`Washington, D.C. 20554
`
`CC Docket No. 94-102
`
`- ---In t-he- Matter of
`
`Revision of the Commission's rules
`to ensure compatibility with enhanced
`911 emergency calling systems
`
`RM-8143
`
`NOTICE OF PROPOSED RULE MAKING
`
`Adopted: September 19, 1994;
`
`Released: October 19, 1994
`
`By the Commission:
`
`Comment Date: January 9, 1995
`Reply Comment Date: February 8, 1995
`
`TABLE OF CONTENTS
`
`TOPIC
`
`PARAGRAPH
`
`I. INTRODUCTION
`II. BACKGROUND
`Private Branch Exchange and Dispersed Private
`Telephone Systems
`Enhanced 911 and Wireless Systems
`III. COMPATIBILITY OF PBX EQUIPMENT
`WITH 911 SYSTEMS
`A. Adcomm and Industry Proposals
`Adcomm Petition
`Industry Efforts
`Comments
`B. Discussion
`911 Availability
`Attendant Notification
`ALI database maintenance
`Station Number Identification (SNI)
`Information Protocol Standard
`Network Interface Standards
`Local Exchange Company Services
`C. Implementation Schedule
`
`1
`3
`
`8
`9
`
`11
`13
`13
`14
`15
`19
`22
`23
`24
`26
`27
`28
`29
`30
`
`IV. COMPATIBILITY OF WIRELESS SERVICES
`WITH ENHANCED 911
`Discussion
`911 availability
`Grade of service
`911 call priority
`User location information
`Re-ring/call back
`Common Channel Signaling
`Access to text telephone devices (TTY)
`Equipment Manufacture, Importation, and
`Labeling
`V. ADDITIONAL CONSIDERATIONS
`Privacy
`Compatibility with Network Services
`Preemption
`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
`
`32
`37
`41
`42
`44
`45
`52
`53
`54
`
`55
`56
`56
`58
`59
`60
`62
`63
`64
`65
`
`I. INTRODUCTION
`to
`this proceeding, the Commission proposes
`In
`1.
`amend its regulations to address issues raised by the provi(cid:173)
`sion 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
`services is not compromised by new developments in tele(cid:173)
`communications. 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. 1 In this Notice of Proposed Rulemaking, we seek
`comment on proposals for ensuring the compatibility of
`private branch exchanges (PBXs) and other dispersed pri(cid:173)
`vate telephone systems with enhanced 911 emergency ser(cid:173)
`vices.
`
`1 Comments were filed by Associated Public-Safety Commu-
`- nications Officers, Inc. (APCO), Bell Atlantic, BellSouth, GTE,
`South Carolina Budget and Control Board, and the Telecom-
`
`munications Industry Association (TIA), and reply comments
`were filed by Adcomm and the North American Telecommuni(cid:173)
`cations Association (NATA).
`
`6170
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`

`

`9 FCC Red No. 22
`
`Federal Communications Commission Record
`
`FCC 94-237
`
`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 fea(cid:173)
`tures for 911 calls provided over wireless mobile units.
`Th~s action responds to a Petition for Reconsideration filed
`by the Texas Advisory Commission on State Emergency
`- Communications (TX-ACSEC) under the Office of the At(cid:173)
`torney 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 Communica(cid:173)
`tions Officials-International, Inc. (APCO), the National
`Emergency Number Association (NENA), the National As(cid:173)
`sociation of State Nine One One Administrators (NASNA),
`and the Personal Communications Industry Association
`(PCIA). 4
`
`II.BACKGROUND
`3. Since AT&T"s announcement in 1965 that the digits
`9-1-1 would be made available nationally as an emergency
`telephone number, the use of 911 for emergency purposes
`has become widespread. The Commission's Network Re(cid:173)
`liability Council, in performing a special study of the
`reliability of 911 services, found that "the American public
`depends on 911 services in its emergencies." 5 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.b Currently, about 260,000 calls nation(cid:173)
`wide are placed to 911 every day.
`4. 911 emergency services enable telephone users to re(cid:173)
`ceive, 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, na(cid:173)
`tionally 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 emer(cid:173)
`gency service providers is not readily, known. Second. be(cid:173)
`cause 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.
`5. There are different levels of 911 services available,
`depending on the location. Basic 911 service is a forward(cid:173)
`ing 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.
`6. Enhanced 911 systems help emergency services per(cid:173)
`sonnel achieve the shortest possible emergency response
`time by using Automatic Number Identification (ANI) 7 to
`route an emergency call 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 external Auto(cid:173)
`matic Location Identification (ALI) database. The ALI fea(cid:173)
`ture 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 medi(cid:173)
`cal 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 sub(cid:173)
`scriber, 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 Com(cid:173)
`mission "for the purpose [among others] of promoting
`safety of life and property through the use of wire and
`radio communication .... " 10 This Commission has jurisdic(cid:173)
`tion to license the electromagnetic spectrum, and also to
`"instrumentalities.
`facilities
`[and]
`apparatus"
`regulate
`through which wire and radio services are provided. 11 It is
`difficult to identify a nationwide wire or radio communica(cid:173)
`tion service more immediately associated with promoting
`safety of life and property than 911. We believe that broad
`
`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 Rec(cid:173)
`onciliation Act of 1993, Pub.L. No.
`l03-66, 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 Per(cid:173)
`sonal Communications Services. GEN Docket No. lJ0-314. Sep(cid:173)
`tember 23, 1993, 8 FCC Red 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 pro(cid:173)
`ceeding.
`4 This paper was filed on July 5, 1994, as an ex parte comment
`to GEN Docket No. lJ0-314. It is attached at Appendix D.
`5 Network Reliability: A Report to the Nation. National En(cid:173)
`tneering Consortium, June, 1993 at Section F, page 1.
`Wireline carriers and 911 service providers may employ
`diverse routing of interoffice facilities, multiple 9ll 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.
`7 The use of the term "automatic number identification" or
`"AN!" in this NPRM is not intended as a reference to billing
`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
`AN! merely 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.
`4 A list of the 91 I call features currently available to many
`emergency call taking organizations, listed in order of impor(cid:173)
`tance as defined by NENA/APCO leadership, is shown in Ap(cid:173)
`riendix B.
`o 47 U.S.C. §151.
`11 47 U.S.C. §151, §153(a), (b), Titles II and Ill.
`
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`

`

`FCC 94-237
`
`Federal Communications Commission Record
`
`9 FCC Red No. 22
`
`availability of 911 and enhanced 911 services will best
`promote "safety of life and property through the use of
`wire and radio communication."
`8. Private Branch Exchange and Dispersed Private Tele(cid:173)
`phone Systems. Private Branch Exchange (PBX) and other
`dispersed 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
`is critical. 12
`time-consuming in a situation where time
`While it is technically feasible to include location iden(cid:173)
`tification information in transmitting calls from stations
`served by PBX or other dispersed private telephone sys(cid:173)
`tems, there currently is no uniform means for ensuring
`that this information reaches emergency services personnel.
`Moreover, telephone users may or may not be aware that
`their telephone service is provided through PBX systems,
`and. in any event, are unlikely to be aware of 911 capabil(cid:173)
`ities 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.
`9. Enhanced 911 and Wireless Systems. While some wire(cid:173)
`less 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
`
`12
`See Adcomm Petition at 3, citing a news13aper -report of 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 The
`Wireless Factbook, Cellular Telecommunications Industry Asso(cid:173)
`ciation, Spring 1994. p. 6.
`14 Communications Daily, "NARUC Notebook" (July 27, 1994)
`quoting Leah Senitte of the National Emergency Number Asso(cid:173)
`ciation.
`15 This number for cellular telephone calls does not include
`calls from fixed cellular "Freeway Call Boxes." See, W. Clay
`Paxton, "Future Vision II: The 9-1-1 Imperative", NENA News,
`Vol. 12, No. 2, May 1994, at pp. 20-28. See also. George Raine.
`"Cellular Phone Owners Dialing (Jl l Frivolously", The San
`Francisco Examiner. February 25, 1 ()93.
`16 See W. Clay Paxton, op. cit. See also, Tony Rogers, "Cellular
`Samaritans Becoming the Eyes of the Highway Patrol", Asso(cid:173)
`ciated Press, January 5. 19Q3.
`The Wireless Factbook, Cellular Telecommunications In(cid:173)
`1
`"
`. dustry Association. Spring 19Q4 p. 36.
`18
`In Los Angeles County, 600,000 cellular/mobile q 11 calls
`were placed in 1Q92. More than 25% of the callers could not
`
`which were from cellular telephones. 15 In 1987, the Mas(cid:173)
`sachusetts 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 cus(cid:173)
`tomers will increase the number of 911 calls that are
`placed from mobile telephones. As currently configured,
`however, wireless 911 services are inferior to the wire line
`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
`
`III. COMPATIBILITY OF PBX EQUIPMENT
`WITH 911 SYSTEMS
`11. Several states and localities have passed regulations or
`ordinances for the purpose of requiring PBX equipment to
`becompatible with 911 systems. 20 The specific require(cid:173)
`ments, however, vary significantly from one state to an(cid:173)
`other. 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 emer(cid:173)
`gency services by delivering inaccurate, incomplete. or mis(cid:173)
`leading call origination information to the public switched
`telephone network. Moreover. mutually incompatible sys(cid:173)
`tems 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 ser(cid:173)
`vices. The record in this proceeding. discussed below. in(cid:173)
`dicates that market forces to date have not been effective in
`implementing a solution to this problem. States and local(cid:173)
`ities are considering separate and possibly conflicting regu(cid:173)
`lations on PBX owners and equipment. Failure to address
`the problem quickly could result in
`increased costs as
`
`identify their location. This information was related by William
`E. Stanton, Executive Director of NENA, during a presentation
`at the FCC on March 23. 1qg4_
`19 The following example illustrates the difficulties posed by
`the use of mobile radio services to reach 911 emergency ser(cid:173)
`vices. At 2:50 AM on September 22, 19Q3, 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 re(cid:173)
`ceived by the CSX Railroad office in Mobile which placed a call
`to q 11, but incorrectly identified the location of the derailment
`as Bayou Sara, several miles south of the actual location. Con(cid:173)
`sequently, dispatched rescue units were unable to find the de(cid:173)
`railed 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 sys(cid:173)
`tem. 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."
`See NENA News, "Mayday
`in
`the Mobile Delta." Dennis
`Stapleton. Vol. 12, No. 2, May 1()()4, at pp. 16-18.
`20 See. e.g., Mississippi Code 1972 Annotated. tit. 2(), Chapter 5,
`§§ 1 (J-5-303.
`
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`

`9 FCC Red No. 22
`
`Federal Communications Commission Record
`
`FCC 94-237
`
`equipment that is not compatible with enhanced 911 sys(cid:173)
`tems 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 equip(cid:173)
`ment") operate effectively with enhanced 911 systems.
`
`A. Adcomm and Industry Proposals
`13. Adcomm Petition. The Adcomm pet1t1on 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. Adcomm points out that the
`resolution of this problem will require accurate manage(cid:173)
`ment of telephone number databases and may have im(cid:173)
`plications 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 tele(cid:173)
`phone networks. Specifically, Adcomm"s proposed rules
`are " ... simply intended to align interface approaches with(cid:173)
`out proposing to control user imglementations or local
`exchange carrier (LEC) services."·3 Adcomm ·s proposal
`would: (1) require PBX equipment to provide specific loca(cid:173)
`tion information of the calling station to enhanced 911
`systems; (2) require premises owners to provide local tele(cid:173)
`phone companies with information on their PBX systems;
`(3) require certain training. verification. supervision and
`testing procedures for PBX operation; ( 4) specify signal
`power limitations: and (5) set technical standards for com(cid:173)
`patibility with enhanced 911 systems, including trunk in(cid:173)
`terface and signaling requirements.
`14. Industry Efforts. The Telecommunications Industry
`Association (TIA). through a subcommittee of its Multi(cid:173)
`line Telecommunications Committee. has been working to
`develop technical standards for PBXs to resolve the En(cid:173)
`hanced 911 problem.2
`~ 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.
`15. Comments. Commenters responding to Adcomm's
`petition generally acknowledge the need to ensure compati(cid:173)
`bility 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 pending industry consensus on
`standards. The North American Telecommunications Asso(cid:173)
`ciation (NATA) and the South Carolina Budget and Con(cid:173)
`trol Board (SCBCB) contend that the Commission should
`lead any such industry effort. SCBCB states it cannot en(cid:173)
`dorse the Adcomm rroposal due to potential technical and
`financial hardships. 2 NATA objects to Adcomm's proposed
`verification requirements and opposes new training re(cid:173)
`quirements on customer premises equipment (CPE) in(cid:173)
`stallation personnel.26 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 net(cid:173)
`work.
`16. APCO, which supports the petition, expresses con(cid:173)
`cern about PBXs that block 911 calls
`in favor of an
`internal safetv service. APCO is also concerned about the
`confusion ca~sed 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 NAT A 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 installa(cid:173)
`tions and wireless PBXs. 2g
`17. Commenters identified several specific elements that
`should be included in any resolution of the PBX/enhanced
`9l l 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 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 inter(cid:173)
`connection, and that such costs be fairly distributed. 32 GTE
`
`21 The problem may also exist for key telephone systems
`connected
`to Centrex. See TIA Technical Systems Bulletin
`(TSB-103). "PBX and KTS Support of Enhanced 911 Calling
`Service," (October, ll/93) at 3.
`22 The Commission is currently examining various issues re(cid:173)
`garding administration of the North American Numbering Plan.
`See Administration of the :Vorth American Numbering Plan, No(cid:173)
`tice of Proposed Rulemaking. CC Docket No. 92-:237. 9 FCC Red
`2068 ( l l/94 ).
`23 Adcomm Replv at 2.
`24 TIA is a membership organization of domestic and interna(cid:173)
`tional providers of telecommunications products and services.
`Through various committees. TIA develops engineering stan-
`
`dards and publications that facilitate interchangeability and im(cid:173)
`provement of products. Standards developed by TIA committees
`and adopted by TIA ballots are voluntary industry standards
`that represent an industry consensus.
`25 SCBCB at 2.
`26 NATA 7-9.
`)~ Bell South at 2; GTE at 5: NATA 2-23.
`28 Adcomm reply comments at 3.
`2g GTE at 5-6.
`.m GTE at 2-4.
`31 Bell Atlantic at 1-2. A copy of the NENA protocol is
`auached as a appendix to Bell Atlantic's comments.
`32 NATA at 4-5. 6-7.
`
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`

`

`FCC 94-237
`
`Federal Communications Commission Record
`
`9 FCC Red No. 22
`
`~sserts that a solution may also require added functionality
`m end office switches and additional telephone number
`assignments. 33
`18. TIA contends that Part 68 shou Id specify as few
`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 prop(cid:173)
`erly, TIA states that the regulations should: (1) clearly
`define the responsibilities of all entities involved; (2) refer(cid:173)
`e_nce the appropriate standards to be used, preferably na(cid:173)
`~al; (3) set reasonable deadlines for compliance; and (4)
`~n~olve regulatory agencies in educating the public regard(cid:173)
`•r:i-g the deployment and use of enhanced 911 calling ser(cid:173)
`vice.
`
`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 tele(cid:173)
`phone network (PSTN) at an optimal level for emergency
`purposes .. The Adcomm petition, the comments received,
`and pubhshed reports of difficulties in delivering emer(cid:173)
`gency 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 sys(cid:173)
`tems. 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, e.g., calling party number, to
`the PSAP that may facilitate a more timely emergency
`response._ We, therefore, initiate a Notice of Proposed
`Rulemakmg to require compatibility of PBX equipment
`with enhanced 911 systems. The proposed rules are pat(cid:173)
`terned closely after those proposed by Adcomm. with
`modifications to reflect some of the commenters' concerns.
`We seek comment on these proposed rules.
`21. In considering the proposed rules, our paramount
`concern is to ensure that PBX equipment does not hinder
`delivery of emergency services by impeding the transmis(cid:173)
`sion of adequate location information over the PSTN. We
`believe that any rules adopted must provide sufficient flexi(cid:173)
`bility to foster the development of alternative methods and
`technological innovation in resolving compatibility prob(cid:173)
`lems 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 equip(cid:173)
`ment 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 prop(cid:173)
`erly 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 par(cid:173)
`ties, 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 ser(cid:173)
`vice providers, and other affected parties. rn' 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
`ser_ve~ a physically small location, such as a single story
`bu1~dmg, or a small number of closely situated telephone
`stations. Commenters should propose specific alternative
`~anguage ~here they do not believe the proposed language
`1s appropnate.
`22. 911 Availability. Both the Adcomm proposal and
`TSB-103 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 equip(cid:173)
`ment, such as dial 9 blocking to prevent toll fraud and
`Automatic Route Selection for least cost routing, should
`not b~ 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
`h~ve the ability to reach emergency services by dialing 911
`without having to dial any additional digits. TSB-103 sug(cid:173)
`gests that some form of user education or notification may
`be 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 attempt(cid:173)
`ing to use it to call enhanced 911. We seek comment on
`these proposed rules.
`23. Auendant Notification. TSB-103 recommends that
`new PBX equipment be capable of alerting an attendant or
`other on-premises personnel and providing calling station
`information to such personnel when a 911 call is dialed.
`On-premises personnel may assist emergency services per(cid:173)
`sonnel 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 (e.g., 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 atten(cid:173)
`dant, 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 ser(cid:173)
`vice. TSB-103 contends that any regulations should clearly
`define the responsibilities of all parties involved in im(cid:173)
`plementing an enhanced 911 system. As noted above, ac(cid:173)
`curate caller locat.ion information is vital to ensuring the
`timely delivery of emergency services through the public
`
`33 . GTE at 2-3, 4-6.
`
`6174
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`9 FCC Red No. 22
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`Federal Communi