Deadline Approaching for Next Phase of E911 Rules for Hotels and Offices
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Deadline Approaching for Next Phase of E911 Rules for Hotels and Offices

Brownstein Client Alert, September 28, 2020

Jan. 6, 2021, is the deadline to begin automatically sending location information along with 911 calls made from fixed phone lines in hotels, apartment complexes, offices or other businesses locations. 

The deadline stems from the Federal Communications Commission’s (FCC) 2019 order implementing legislation to update 911 calling requirements for businesses using multi-line telephone systems or fixed telephone and Voice over Internet Protocol (VoIP) services. Under that order, enterprises should already have ensured that 911 calls from multi-line business phone systems can be made without first dialing “9” or another prefix to reach an outside line and that notice of the 911 calls is automatically sent to someone in the company when the 911 call is made. We have previously provided alerts on this issue that can be found here and here.

The next phase of these 911 rules will require enterprises to automatically send a validated street address and other “dispatchable location” information necessary to locate the person making the call. In multi-floor offices or campuses, this additional information may include a floor or room number. For smaller businesses, a street address may be sufficient. The rules are flexible and companies should be guided by asking themselves how hard it would be for first responders to find the person making the 911 call if the only information sent is a general street address of the main corporate office or hotel. 

There are important limitations to the Jan. 6 deadline. The rule does not apply to already installed, legacy multi-line telephone systems. Moreover, it only applies to 911 calls from on-premises fixed telephones, such as desk phones or a hotel room telephone. Importantly, at a time when many employees are working from home, the upcoming deadline does not apply to 911 calls made by remote workers using phones tied to the company’s phone system. The deadline for providing location information for remote workers or non-fixed phones is another year away, Jan. 6, 2022.

The FCC’s implementing order also allocates responsibilities for compliance among various parties. Companies making, selling or leasing multi-line phone systems must ensure that they are capable, once properly installed, of providing location information. Persons installing such systems must ensure that they are configured to provide location information and those managing or operating the system must ensure they are managed and operated in a way to provide location information. The same entity may play multiple roles but it is important to recognize that businesses that operate and manage their telephone systems may be liable for noncompliance. Sellers and buyers of systems should ensure that their contracts allocate responsibilities to the entity best able to perform the requisite functions.

In addition to multi-line telephone systems, the FCC requires providers of fixed telephone services to apartment buildings, including fixed VoIP services, to automatically send dispatchable location information along with a 911 call by Jan. 6, 2021. 

The current COVID-19 pandemic has changed circumstances since the FCC set these deadlines. At least one seller of multi-line systems has requested a deadline extension due to resource constraints caused by the pandemic. Other companies facing pandemic-related resource constraints might similarly consider filing such requests.

Please feel free to contact the author if you have any questions.

This document is intended to provide you with general information regarding the deadline for the next phase of E911 rules. The contents of this document are not intended to provide specific legal advice. If you have any questions about the contents of this document or if you need legal advice as to an issue, please contact the attorneys listed or your regular Brownstein Hyatt Farber Schreck, LLP attorney. This communication may be considered advertising in some jurisdictions.

The information in this article is accurate as of the publication date. Because the law in this area is changing rapidly, and insights are not automatically updated, continued accuracy cannot be guaranteed.

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