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Three Ways the New FCC Order Impacts Your Company

On August 1, 2019, the FCC adopted an official Report and Order, which affects all enterprises nationwide.  The FCC was adamant that no exceptions be made for small businesses, non-profits, government agencies, or medical facilities.  Everyone will be required to follow these new requirements.  We are still waiting for the Order to be published in the Federal Register, which will determine exact deadlines.  However, we do know the Report and Order provides rules for both Kari’s Law and the Ray Baum Act.  These rules will affect your business’s communication system, specifically regarding its E911 capabilities.  At RedSky, we have anticipated these mandates, and are prepared to help you understand exactly what is required from your company in the wake of federal legislation.  


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We must state that we are not lawyers, and this overview represents our opinion.  However, we are experts in E911, and this Report and Order certainly falls within the parameters of our expertise.  We will be coming out with more detailed literature on each of these requirements, but we want to discuss the three overarching concepts that this Report and Order covers.  The Order outlines requirements for direct dialing, providing notification, and automatic “dispatchable location”.


Direct Dialing

Where:  This falls under Kari’s Law


What:  All new phones (whether first sale, newly manufactured, updated, or installed) must be able to directly dial 9-1-1 without any additional digit, prefix, or trunk-access code beforehand.


When:  After February 2020


Why this matters:  Businesses are now obligated to make sure their communication systems do not hinder a person from dialing 9-1-1 in any way.  A person must be able to pick up the phone, dial 9-1-1, and get through to a dispatcher.  This is required for all “new” phones after February 2020, meaning even if your company is planning a software update to an existing phone system, you will need to fulfill this “Direct Dialing” requirement in addition to the software update.  Subsequent to that update, this FCC Order states that anyone that dials 9-1-1 must be able to do so directly.  



Where:  This falls under Kari’s Law


What:  All capable MLTS devices from which 9-1-1 is dialed must provide a notification to a central location at the facility where the system is installed alerting another person (security, admin, emergency response team) to the existence of an emergency call. 


When:  After February 2020


Why this matters:   When a person dials 9-1-1 from your enterprise’s communication system, the front desk, security office, or relevant personnel must be informed.  We believe that adequate notification necessitates an awareness of end-point location.  A simple notification without the location of the 9-1-1 call is rendered useless when the emergency takes place in a multi-floor building, large campus environment, warehouse, etc.  This means that your business’s communication system should be able to provide both notification of a 9-1-1 call, as well as alert someone as to where that call is coming from within your enterprise.  RedSky’s E911 technology can do this for your enterprise. 


Dispatchable Location 

Where:  This falls under Ray Baum’s Act 


WhatFCC regulations will require automatically providing “dispatchable location” for 9-1-1 calls from fixed MLTS devices, non-fixed MLTS devices, and off-premise devices. 



  1. Fixed MLTS devices within one year*
  2. Non-Fixed devices (when technically feasible) within two years*
  3. Off-Premise devices (when technically feasible, otherwise must provide manually updated dispatchable location, or enhanced location information) within two years*

*From the date the Order is published in the Federal Register 


Why this matters:  If a person dials 9-1-1 from within your enterprise, even if off-premise, you are responsible for making sure the exact location of that caller is sent to the nearest Public Safety Answering Point.  Automatically providing “dispatchable location” means location information must be provided to the dispatcher without the caller having to speak, and must be adequate enough to effectively find the caller within the environment from where they are dialing.  This means the “dispatchable location” will differ depending on your environment.  Large campuses and multi-level buildings will require much more detailed “dispatchable locations” in order for a first responder to easily navigate to the caller.  Ultimately, the goal of this requirement is for the dispatcher to be able to efficiently send first responders to the appropriate location of the emergency without life-threatening delays.  Again, RedSky’s E911 technology can do this for your enterprise.


If you have further questions on what this FCC Report and Order means for your enterprise, or about E911 solutions for your environment, please contact us.