But there’s little parity between state laws. They range from strict (Louisiana requires every PBX installed after Jan. 1, 2005, to transmit location information to the station level) to more lax (businesses in Colorado not equipped to send location information just have to tell end users to tell 911 operators their telephone numbers and exact locations). Compliance Requires Zone Programming NENA published the model legislation in an effort to guide states in the absence of federal E911 requirements. The 24-member committee behind the document includes representatives from Nortel, Avaya, AT&T, Intrado Inc., 911ETC, public safety organizations and two enterprises. The new model legislation – updated from a version written in 2000 to reflect advancements in IP telephony – includes recommendations that might have you rushing to check your system capabilities. Compliance with NENA’s recommended regulations would require roughly 75% of Nortel’s customers, for example, to take action, says Mark Fletcher, Nortel’s product line manager for emergency services and the chairman of NENA’s PBX/multi-line telephone system technical subcommittee. Systems purchased in the last five years are fully compatible, but in most cases compliance would require additional routing and configuration of emergency response locations [VR 2/14/08]. NENA doesn’t recommend specific penalties that states should institute along with its model legislation. However, the group was careful to write the law in such a way that it could be enforced at states’ discretion, says Fletcher, who is among the legislation’s authors. He reports that one state is considering fining enterprises that send location information with 911 calls that differs from the location information in emergency operators’ databases. Inconvenient though it might seem, your enterprise could benefit from the installment of E911 laws in the states where it operates. Take this excerpt from the NENA model legislation: No enterprise or multi-line telephone system manager “shall be liable for any civil damages or penalties as a result of any act or omission, except willful or wanton misconduct, in connection with developing, adopting, operating or implementing any plan or system required by this act.” In other words, as long as you’re not grossly negligent, you and your enterprise would be absolved from liability for E911 mistakes, Fletcher says. You’d likely be on the hook for full responsibility in states where no laws are in place. Recommendations by Enterprise Type Here’s a summary of the E911 capabilities your enterprise would have to provide if NENA’s model legislation were to become law in states where you have locations:
Businesses – PBXs serving business locations would be required to deliver 911 calls with an emergency location identification number, which would transmit the location to an emergency operator. The location would have to be specific at least down to the building and floor level. NENA recommends establishing emergency response location zones that match and are no larger than fire alarm boundaries. The NENA legislation makes exceptions for businesses using key systems, because they can’t easily be programmed to segment lines in a way that differentiates building floors. These offices must provide just the building address to the emergency operator. Businesses in small offices should also be excused from more detailed location reporting, many have reasoned. Three states currently have E911 laws that allow such businesses to provide only building addresses. Washington’s is the most stringent with its mandate that only businesses occupying fewer than 25,000 square feet are exempt from sending more than the building address. NENA’s law would let even fewer businesses take the easy route. Workspaces with fewer than 7,000 square feet on a single level and located on a single contiguous property would be the only ones able to transmit just a business address. Why only exempt such small businesses?, asks Andrew Brown, a partner at telecom law firm Levine, Blaszak, Block & Boothby, in Washington, D.C., who consults with roughly 20 enterprises a year on E911 compliance. The NENA committee concluded that the 25,000-square-foot threshold used in Washington’s law is simply too large, Fletcher reports. If square footage is the only criteria a state would use to determine location zone reporting, NENA believes the area should be small enough for emergency response teams to search quickly. “As that number gets smaller and smaller, it gets harder for enterprises to comply,” Brown notes. If an enterprise prefers to send 911 calls to a private, internal enterprise answering point [VR 9/11/08], NENA’s model states that these private operators must provide incident reporting to public safety emergency response centers. NENA also recommends that private operators get basic telecommunicator training from recognized public safety organizations and training companies. Shared office spaces – PBXs providing “shared telecommunications services,” as in office parks where different companies rent suites, would have to deliver unique location information for each entity using the phone services. Temporary residences – The “temporary residence” recommendations would apply to hotels, motels, hospitals, nursing homes, and campuses with dorms and PBXs. Where location information records are not provided for each individual station, NENA recommends the PBX must provide “specific location information” to the emergency operator. The proposed rule is intentionally vague to leave states latitude to customize it, Fletcher explains. But in a hotel – where travelers usually don’t know the address – NENA recommends reporting location information down to the room level, he says. Apartment complexes – PBXs used in shared residential units like apartment complexes or other housing developments would be required to deliver location information down to the living-unit level. ( | 
