BILL ANALYSIS �
AB 911
Page 1
Date of Hearing: April 29, 2013
ASSEMBLY COMMITTEE ON UTILITIES AND COMMERCE
Steven Bradford, Chair
AB 911 (Bloom) - As Amended: April 24, 2013
SUBJECT : Telephone systems: 911
SUMMARY : Establishes various requirements, beginning January
1, 2019, regarding 911 emergency call technology that would be
applicable to multiline telephone systems (MLTS), operators of
shared telecommunications services, and businesses with a MLTS.
Specifically, this bill :
1)Requires a MLTS operator in an area that has enhanced 911
capability, beginning January 1, 2019, to maintain and operate
the MLTS, as specified, to ensure that each emergency call
placed from any telephone station on the MLTS is routed to a
public safety answering point (PSAP) and provides either
automatic location information or automation number
identification to the 911 network that connects to a PSAP.
2)Provides exemptions for buildings or structures under 7,000
square feet or where enhanced 911 service is not available.
3)Authorizes the assessment of civil penalties against a MLTS
provider that violates these requirements.
EXISTING LAW :
1)States the Warren 911 Emergency Assistance Act requires every
local public agency to establish and operate a telephone
system that automatically connects a person dialing "911" to
an established PSAP through normal telephone service
facilities.
2)Prohibits the Public Safety Communications Division in the
Department of Technology from delaying the implementation of
the enhanced "911" emergency telephone system, as provided.
3)States that A person commits a public offense if the person
knowingly and maliciously interrupts, disrupts, impedes, or
otherwise interferes with the transmission of a communication
over an amateur or a citizen's band radio frequency, the
purpose of which
AB 911
Page 2
communication is to inform or inquire about an emergency.
(Penal Code 653a(t))
FISCAL EFFECT : Unknown.
COMMENTS : According to the author, "current law tasks local
public safety organizations with administering 9-1-1 service for
emergency calls. Most public safety organizations have
implemented "Enhanced 9-1-1" (E911) service, which identifies
the phone number and location from which a 9-1-1 call
originates. However, there is currently no uniform requirement
that the information provided by the phone system making a 9-1-1
call conform to a certain standard. While some multi-line
telephone systems (MLTS) users have configured their phone
systems to provide precise location data to a Public Safety
Answering Point (PSAP), many have not.
E911 service can be extremely helpful to first responders in
situations where a caller is unable to provide his or her
location. However, it is only useful if the phone system can
provide an accurate location to the PSAP. In urban skyscrapers,
the physical address where the emergency occurred is of little
use without knowledge of which floor to go to.
Additionally, in some cases where all calls in a large phone
system are routed through a central switchboard, the switchboard
is physically located far away from where a call originates, and
the PSAP may dispatch help to the switchboard's location while
the emergency is miles away. AB 911 would help resolve these
problems and shave critical minutes off emergency response times
that can mean the difference between life and death."
1)What is a MLTS : A multi-line telephone system, or MLTS, is a
telephone system comprised
of common control units, telephones, and controls providing
local telephone service to multiple end-users. Multi-line
telephone system includes Voice over Internet Protocol (VoIP)
and includes network and premises based systems such as Centrex,
PBX, and hybrid key telephone systems, but does not include key
telephone systems. Many businesses, government agencies,
hotels, and schools use these types of telephone systems.
2)Enhanced "911" service : The digits 911 are designated as the
emergency telephone number.
The ability to access emergency services by dialing 911 is a
vital component of public safety and emergency preparedness. It
AB 911
Page 3
is imperative that consumers of telephone service be able to
reach emergency services regardless of the technology used to
place a 911 call. When a 911 call is placed from a traditional
telephone, the call in most cases is sent to a PSAP that is
responsible for helping people in a particular geographic area
or community. PSAP personnel often can automatically identify
your location and direct the closest emergency personnel to that
location.
Currently, over 240 million 911 calls are made annually to the
6187 public agencies serving as PSAPs nationwide. In
California, over 480 PSAPs receive nearly 30 million calls
annually. An increasing proportion of these calls are delivered
by wireless and internet technology (over 40 % last year).
Enhanced 911 (E911) is an enhanced version of the 911 emergency
service provided by the communications carrier which identifies
the phone number and location from which a 911 call originates.
E911 service can be helpful to first responders in situations
where a caller is unable to provide his or her location. Thus,
it is only useful if the phone system can provide an accurate
location to the PSAP. An example, in a large office building,
the physical address where the emergency occurred is of little
use without knowledge of which floor to go to. In addition, in
some cases where all calls in a multiline phone system are
routed through a central switchboard (i.e. hospital), the
switchboard is physically located a significant distance from
where the call originates (i.e. medical clinic), and the PSAP
may dispatch help to the switchboard's location while the
emergency is miles away.
3)Federal and state efforts : This bill requires MLTS operators
to equip the system with the
ability - via automatic location information identification or
automatic number identification - to provide a PSAP with the
precise location from which the call originates. Specifically,
the system must provide, at a minimum, the building and floor
where the caller is located. The genesis of this bill evolved
in response to recent action by the National Emergency Number
Association (NENA). NENA developed model legislation in
February 2011 to require MLTS's to provide a sufficiently
precise indication of the caller's location, while avoiding
imposition of undue burdens on system manufacturers, providers
and operators of MLTS.
One year prior to the adoption of the NENA model legislation,
AB 911
Page 4
the California Public Utilities Commission (PUC), in April 2010,
issued Rulemaking 10-04-011 with the objective of enhancing
Californians' public safety by addressing the California's E911
Private Branch Exchange (PBX)/MLTS public safety communication
gap. The goals of this proceeding are to reduce, where
possible, the critical time an effort needed by emergency
response personnel to locate an injured or distressed 911 caller
located within an extensive workplace comprised of several
rooms, floors, etc., and to minimize the time and exposure of
first responders to any dangerous conditions.
The Proposed Decision directs the local exchange carriers to
take certain actions designed to raise customer awareness of the
critical E911 PBX/MLTS safety issue that affects many of
California's large businesses and other public facilities. The
Proposed Decision specifically directs the local exchange
carriers to 1) distribute a PBX 911 advisory brochure to current
and prospective customers when those customers initiate services
and/or request information on PBX/MLTS E911, 2) distribute a PBX
911 advisory brochure to existing businesses and PBX/MLTS
customers, and 3) provide links on their webpages to the PUC's
CalPhoneInfo website and specifically the PBX 911 advisory. A
final vote by the PUC on this Proposed Decision is expected
later this summer.
4)Who is the MLTS operator : For the purposes of this bill a MLTS
operator is the owner/lessee
of the equipment. The MLTS operator would be required beginning
January 1, 2019 - should this bill become enacted - to install
the software on their telephone system. The bill also specifies
that the MLTS operator is responsible for updating the automatic
location information database with appropriate address and call
back information as soon as practicable. The automatic location
information database is maintained by the MLTS' communications
service provider. Provisions in the bill require the MLTS
operator to annually audit accuracy of information contained in
the automatic location information database.
5)Compliance and enforcement : Should this bill become law, an
entity who sells a MLTS
should provide, at the time of sale, to the purchaser and to
each new user, either a demonstration of how to place an
emergency call from a telephone station or informs an individual
how to place an emergency call from the telephone system. A
seller of the MLTS system could be assessed a fine if found in
AB 911
Page 5
violation of this law. It is not clear, however, what outreach
measures will be undertaken to inform existing customers with
telephone systems that they are required by law to install the
new software. Who will enforce this new mandate? Proponents of
this measure claim PSAPs will have the authority to enforce
action against businesses that do not comply with this mandate.
For instance, if an emergency situation occurs and first
responders arrive to wrong incorrect location because the MLTS
operator has not installed the software on the system, the PSAP
has the authority pursuant to existing law to inform the local
authorities of the violation which can be elevated to the State
District Attorney.
E911 regulations have been in adopted in 12 other states,
including Virginia and Massachusetts which have been in effect
since July 1, 2009. The regulations in Massachusetts permit
primary and regional PSAPs to require the operator of a MLTS to
conduct testing to confirm that the MLTS provides the same level
of enhanced 911 service that is provided to others in
Massachusetts. The State 911 Department encourages PSAPs to
notify the State 911 Department of any discrepancies or
compliance issues so that the State 911 Department may work with
the PSAP and the MLTS operator to resolve the matter. The MLTS
operator may seek a waiver from the State 911 Department. The
State 911 Department may deny a request for a waiver, grant a
waiver upon a showing that compliance with the requirements of
the regulations is technologically infeasible or of excessive
cost without public benefit, or grant a waiver with such
conditions as are necessary to ensure the public safety.
6)Exemptions for single-family residential homes and small
businesses : The bill is not
applicable to residential customers. A MLTS serving multiple
buildings or structure with a combined total of 7,000 square
feet or less is not required to provide more than one emergency
response location. Additionally the bill does not apply to a
MLTS serving a single building with less than 7,000 square feet
or less will not be required to provide more than one emergency
response location. The author may wish to add a technical
amendment to clarify that a building with a combined total
workspace of 7,000 square feet or less is not required to
provide more than one emergency response location.
7)Support : The bill sponsors, the California Chapter of the
National Emergency Number
AB 911
Page 6
Association (CALNENA) supports the bill and its intent to create
a mechanism to ensure that accurate location information is
delivered to the 911 network allowing for the emergency call to
be delivered to the correct PSAP.
The Division of Ratepayer Advocates (DRA) writes in support of
the bill claiming that in the event of an emergency it is
critical that responders can geographically locate a caller that
may be unable to provide their location. In addition, DRA
believes AB 911 would improve public safety efforts by
establishing important requirements for enhanced 911 services.
8)Opposition: The California Association of Competitive
Telecommunications Companies
(CALTEL) writes in opposition to the bill unless it is amended
to modify important definitional terms to more closely align
with those included in "model" legislation which was
collaboratively developed by the NENA and a comprehensive
stakeholder group that included service providers, equipment
manufacturers and other emergency services representatives.
Recent amendments add definitional sectionals to the bill which
may address CALTEL's concerns.
9)Technical and non-substantive amendments :
a) The bill references the term "shared telecommunications
services" that is not defined in the bill. The author may
wish to consider an amendment to define shared
telecommunications as follows: Includes the provision of
telecommunications and information management services and
equipment within a user group located in discrete private
premises in building complexes, campuses, or high-rise
buildings, by a commercial shared services provider or by a
user association, through privately owned customer premises
equipment and associated data processing and information
management services, and includes the provision of
connections to the facilities of a local exchange and to
interexchange telecommunications companies .
b) The author may wish to consider an amendment to change
"telecommunication" to "voice communications" to assure the
bill pertains only to voice communication with the 911
PSAPs .
AB 911
Page 7
REGISTERED SUPPORT / OPPOSITION :
Support
California Chapter of the National Emergency Number Association
(CALNENA)
California Fire Chiefs Association (CFCA)
California Professional Firefighters (CPF)
California State Sheriffs' Association (CSSA)
Division of Ratepayer Advocates (DRA)
Opposition
California Association of Competitive Telecommunications
Companies (CALTEL) (unless amended)
Analysis Prepared by : DaVina Flemings / U. & C. / (916)
319-2083