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Addressing the E911 Cloud Gap

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911 on a digital display
Image: frender - stock.adobe.com
The use of cloud calling has exploded over the last year. While the primary driver has been COVID-19, the transition from on-premises to cloud systems was well underway, with the pandemic simply accelerating the inevitable. Digital transformation initiatives are highly dependent on communications, and cloud systems typically deliver innovative features faster than legacy systems. At one time, moving communications to the cloud was considered risky business, but it’s now riskier to not adopt cloud systems.
 
Despite the innovation and fast adoption, there is one glaring gap in most cloud systems, and that’s E911. Some vendors are trying to solve the problems themselves; others are relying on partners to deliver the functionality. To understand E911, the implications and how to solve the challenges, I interviewed E911 guru Lydia Runnels, VP of product strategy for Bandwidth.
 
Zeus Kerravala (ZK): What are the E911 regulations that businesses need to comply with?
 
Lydia Runnels (LR): There are some recently passed federal regulations for E911. Kari’s Law requires direct access to 911, as opposed to having to dial a prefix when calling 911. Also, a designated person must be notified. This is often a security team or front desk attendant and is typically occurs via a phone call, text message, email, or through an HTTP API.
 
Kari’s Law established a compliance date of Feb. 16, 2020. While the law does not explicitly require enterprises to upgrade their communications equipment to comply, the law does state: "if the system is able to be configured to provide the notification without an improvement to the hardware or software of the system." This means that if the enterprise has the ability within their network to provide notifications, they are obligated to do so.
 
Another regulation is RAY BAUM’s Act. Section 506 requires a dispatchable location, which includes the civic address plus more granular location information such as floor number, suite, and room number (if applicable). There are two notable compliance dates. Jan. 6, 2021 is when fixed VoIP endpoints, such as an IP phone need to comply. Jan. 6, 2022 is when nomadic VoIP, such as a Microsoft Teams client, needs to be addressed. There are also state-level laws for E911, and enterprises will need to check on those individually.
 
ZK: What are the fines for not meeting E911 regulations?
 
LR: Fines and other penalties for non-compliance are determined by the FCC according to their enforcement rules, policies, and procedures. In addition to potential penalties for non-compliance, it is important to note that the family of Kari Hunt (the woman whose untimely death led to the passing of Kari’s Law) received a $41.5 million settlement. Non-compliance means businesses are playing Russian roulette and hoping nothing happens, but if it does, the penalty could be huge.
 
ZK: For RAY BAUM’s Act, how specific does the provisioned address need to be?
 
LR: While the federal regulations do not specify this information with precision, the law states: “Dispatchable location includes the validated street address of the 911 calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the caller’s location.”
 
Because of this, Bandwidth strongly recommends that our customers speak with a legal representative to help them understand how to interpret and apply these regulations to their specific enterprise.
 
ZK: What is Next Generation 911 and how does that factor in?
 
LR: Next Generation 911 (NG911) is an ongoing initiative by public safety to upgrade the nation’s 911 system to IP-based technology and infrastructure. With NG911, 911 call centers will be able to accept additional data formats such as text, video, images, etc. during a 911 call. For now, enterprises that leverage an NG911-compatible solution provider like Bandwidth will be able to leverage the dynamic E911 location, such as those within Microsoft Teams during the growing deployment of NG911 across the country.
 
ZK: What is Dynamic E911 for Microsoft Teams Direct Routing?
 
LR: Teams’ Dynamic E911 leverages the end user’s most current location for call routing and display of the address to public safety. Dynamic 911 is a departure from how 911 works for hard phones, where there’s a static emergency address per device that doesn’t often change. With dynamic emergency location capabilities, users are free to move around the corporate network and have their current location — the most accurate location available — provided at 911 call time.
 
All emergency locations are managed within the Teams Location Information Server (LIS). Enterprises assign emergency locations to network elements such as WiFi access points, switches/ports, and subnets. The emergency location should include a civic address plus any other relevant location information such as floor, quadrant, suite, or room for compliance with RAY BAUM’s Act.
 
When a 911 call is made from within the enterprise, the location of the network element the user is connected to is used to route the call to public safety, and the configured address information appears on the 911 call taker’s display. This capability provides the most accurate caller location to first responders, setting the stage for faster emergency response. It also allows the enterprise to meet the RAY BAUM’s Act dispatchable location requirement for nomadic VoIP.
 
ZK: What’s the difference between Microsoft Teams Calling Plans and Direct Routing?
 
LR: Both Calling Plans and Direct Routing provide PSTN access, so it really comes down to the amount of flexibility and control that the enterprise wants to have over their own telephony. Calling Plans includes voice, phone numbers, and E911, which makes it a fast and simplified choice for smaller organizations that don’t want to manage their telephony. We also see Calling Plans leveraged as a short-term option by large enterprises who are piloting a cohort of users on Microsoft Teams but who plan to move to Direct Routing eventually.
 
For organizations of any significant size, however, Calling Plans aren’t usually the most cost-effective option. Large enterprises that want to directly manage their telephony features or choose their carrier tend to lean towards Direct Routing.
 
ZK: Are E911 notifications supported in Teams?
 
LR: Yes. Emergency notifications configured within Teams are sent via chat, with an additional option for the notification recipient to join a live 911 call in listen-only mode or as an active participant in the call.
 
ZK: What about work-at-home users?
 
LR: This is probably the most important issue for enterprises to be aware of right now. Microsoft is currently working on a solution to support remote and teleworkers. For now, if a Teams user who is not attached to the corporate network makes a 911 call from their laptop, the call routes to a 24x7 emergency call center where they will determine the location of the caller and forward it to the appropriate 911 call center. If a user makes a 911 call from within the Teams mobile application, the result is better. In that case, the geo-coordinates of the device will be used to route the call to the appropriate public safety agency. The good news is that in either case, an emergency notification can still be configured to alert someone within the enterprise that a 911 call has been placed.
 
ZK: How do other UC platforms handle dynamic location?
 
LR: Other UCaaS providers like Zoom, RingCentral, and Cisco are all moving towards advanced dynamic location capabilities to support nomadic users. Unfortunately, there is no industry-wide standard and each platform manages their E911 implementation a little differently.
 
Zoom embeds Bandwidth’s E911 Dynamic Location Routing capabilities into their platform, offering enterprises the option to configure network elements with an emergency address. Bandwidth also powers RingCentral. However, with their solution, the enterprise assigns each Wi-Fi access point with a unique telephone number and a dispatchable address for the area in the building served by that hotspot. The good news is that all of this is usually transparent to the enterprise, allowing them to choose the platform that fits their needs knowing that the most modern E911 capabilities are supported. The key takeaway is that the dynamic E911 solutions will help enterprises meet the nomadic location requirements for RAY BAUM’s Act.

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