I need to call 911 Emergency NOW!

<This document only applies to US Emergency Dialing Laws>

“One day, while busy working, a worker at an oil & gas refinery met with an accident. His colleague, with much grief & shock calls 911 hurriedly, but the call did not go through. He panicked. Why do you think the call did not connect?“

An employee dials 911 using a MS Teams softphone using his enterprise’s network. How do you think PSAP gets the exact location of the user?“

“Sales employee move from location to location, they need the capability on their phone to call the correct PSAP, incase of emergency. How it this possible?“

Before we answer the questions above, it is very important to understand the US FCC (Federal Communications Commission) laws for 911 calling.

In August 2019, two federal laws came into action:

1. Kari’s Law

2. Section 506 of Ray Baum’s act

Kari’s Law

Kari’s Law requires direct 911 dialing and notification capabilities in multi-line telephone systems (MLTS), which are typically found in enterprises such as office buildings, campuses, and hotels.  The statute provides that these requirements take effect on February 16, 2020, two years after the enactment date of Kari’s Law.   In addition, Kari’s Law and the federal rules are forward-looking and apply only with respect to MLTS that are manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020.

Direct 911 dialing enable the user to dial 911 without having to dial any prefix or access code, such as the number 9 before 911.

Notification requirement is intended to facilitate building entry by first responders.  When a 911 call is placed on a MLTS system, the system must be configured to notify a central location on-site or off-site where someone is likely to see or hear the notification.  Notification shall include, at a minimum, the following information:

• The fact that a 911 call has been made;
• A valid callback number; and
• The information about the caller’s location that the MLTS conveys to the public safety answering point (PSAP) with the call to 911.

Note: The notification does not have to include a callback number or location information, if it is technically infeasible to provide this information.

Ray Baum’s Act

Under Section 506 of RAY BAUM’S Act, FCC has adopted rules to ensure that “dispatchable location” is conveyed with 911 calls to dispatch centers, regardless of the technological platform used, including 911 calls from MLTS.  Dispatchable location means a location delivered to the PSAP with a 911 call that consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party. 

Please note, Kari’s law & Ray Baum’s Act are forward looking and does not apply to MLTS installed on or before February 16, 2020.

MLTS are subject to compliance deadlines of January 6, 2021 and January 6, 2022, depending on the nature of the device from which the MLTS 911 call originates.* 

Compliance Deadlines

Jan 6th 2021

Provision of dispatchable location from MLTS On premises/ Fixed devices.

On Prem fixed devices associated with MLTS must provide dispatchable location with 911 calls.

Jan 6th 2022

Provision of dispatchable location or alternative location information from MLTS on-premises, non-fixed devices and off-premises devices

On-premises, non-fixed devices associated with an MLTS must provide automated dispatchable location to the appropriate PSAP when technically feasible or should provide alternative location.

Alternative location option for MLTS on-premises, non-fixed devices:

Alternative location information may be coordinate-based, and it must be sufficient to identify the caller’s civic address and approximate in-building location, including floor level, in large buildings. 

Enhanced location option for MLTS off-premises devices:

Off-premises devices associated with an MLTS must provide to the appropriate PSAP automated dispatchable location if technically feasible or enhanced location information.

Enhanced location information may be coordinate-based, and it must consist of the best available location that can be obtained from any available technology or combination of technologies at reasonable cost.  

Note: I have intentionally copied the language from an official FCC website, so that there is correct interpretation.

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Once we know the law, what do we do?

We Follow it!

Jokes apart, but as the organizations are running heterogenous platforms with a mix of on premises and cloud, how do we make sure we follow it, for the safety of our employees. To follow, we need to understand technicalities and how it can be implemented in your UC solutions.

Let’s begin by understanding some technical jargons.

Emergency Address

A Civic Address—the physical or street address of a place of business for your organization.” Microsoft Teams creates a CivicAddressID which is how the address will be referred to in PowerShell.

Emergency Location

A location is a Civic Address—with an optional place. If your business has more than one physical location, it’s likely that you’ll need more than one emergency location.

When you create an emergency address, a unique LocationID is automatically created for this address in Teams.

If you add a place to an emergency address—for example, if you add a floor to a building address—a Location ID is created for the combination of the emergency address and place.

In this example, there will be two Location IDs: one for the Civic Address; one for the joined Civic Address and associated place.

When you assign an emergency location to a user or site, it’s this unique location ID that’s associated with the user or site.”

Dispatchable Location

Dispatchable location describes both a civic address plus more specific information, such as building, floor, suite, room number, etc. This satisfies Ray Baum’s Act.

 Place

“Typically a floor, building, wing, or office number. Place is associated with an emergency address to give a more exact location within a building.

A single emergency address can be associated with multiple places. For eg, a building having 5 floors will have same address but different places for each floor.

Registered address

An emergency address that is assigned to each user. A registered address is sometimes referred to as a static emergency address or address of record.

Dynamic Location

Location Information Service (LIS)

A database within Teams which is queried for location information at the time of an emergency call.  

Trusted IP Address

The internet external IP addresses of the enterprise network. They determine whether the user’s endpoint is inside the corporate network before checking for a specific site match.”

Network Subnet

“Each subnet must be associated with a specific network site. A client’s location is determined based on the network subnet and the associated network site. You can associate multiple subnets with the same network site but you can’t associate multiple sites with the same subnet.

For example, the New York site in the North America region can be assigned the following IP subnets: 172.29.80.0/23, 157.57.216.0/25, 172.29.91.0/23, 172.29.81.0/24. If Bob, who usually works in Detroit, travels to the New York office for training, turns on his computer and connects to the network, his computer will get an IP address in one of the four ranges that are allocated for New York, for example, 172.29.80.103.”

Network Site

A network site represents a location where your organization has a physical venue, such as an office, a set of buildings, or a campus. Network sites are defined as a collection of IP subnets. Each network site must be associated with a network region.

Network Region

“A network region contains a collection of network sites. It interconnects various parts of a network across multiple geographic areas.

The same network regions are shared by Location-Based Routing for Direct Routing and enhanced emergency services. If you already created network regions for one feature, you don’t have to create new network regions for the other feature.”

Presence Information Data Format-Location Object (PIDF-LO)

PIDF-LO is the HTTP, XML tag format of the location information within a 911 call. PIDF-LO includes a “location object” that supports the dynamic capabilities within Teams.  

ERSP

In the United States, there are numerous certified Emergency Routing Service Providers (ERSPs) that can automatically route emergency calls based upon the location of the caller.

• If an Emergency Routing Service Provider is integrated into a Direct Routing deployment, emergency calls with a dynamically acquired location will be automatically routed to the Public Safety Answering Point (PSAP) serving that location.
• Emergency calls without a dynamically acquired location are first screened to determine the current location of the user before connecting the call to the appropriate dispatch center based upon the updated location.

ELIN

Emergency Location Identification Number

Incase the 911 call disconnects, PSAP can use this ELIN to call back the same user. The ELIN application will do the reverse called number substitution to that of the original emergency caller.

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How to configure in MS Teams?

Note: Assuming you use an Emergency Routing Service Provider method to configure emergency dialing on MS Teams.

1. Address Whitelisting by adding it to your ERSP portal.

For an organization, every site has an address associated to it. It’s called a Civic address.

We need to get this addresses whitelisted with the ERSP first, before we add on our Teams Admin Center.

You can place this request manually one by one or in bulk, either on ERSP online portal or open a ticket with them.

Usually, we need to provide the below information. ERSP uses geo tags on their side and you do the same in Teams.

Street No	Street Name	Location	Suburb	City	State	PostCode	Country
1234	Xyz St			Merrillville	IN	46410	USA

Please note: Address that will be configured in Teams Portal must be same as Address shared with ERSP, otherwise correct PSAP may not be called.

2. Adding Emergency Addresses in Teams Admin Center

First, Teams Administrator using their credentials, login to Teams Admin Portal: https://admin.teams.microsoft.com.

In Teams Admin Portal Go to “Emergency addresses”

Click on Add button and enter Name and Description for the location. If the address isn’t found, then please add the address manually. Please use online map service to identify the “Latitude” and “Longitude” information (if you already don’t know)

Try and search the address in Google Maps as below and note down the Latitude and Longitude information. E.g.,

Latitude = 41.47047

Longitude= -87.35432

Please add the identified “Latitude and Longitude” information manually.

Note: Make sure the ERSP address matches with your address in Teams Admin Portal.

Once address is added, it will be shown as below:

Now it’s time to add “Places” for this address. Click “+ Add” button and add place such as “Floor 4 – Suite 400”.

Places can be Floors (Floor 1,2,3..), Buildings (Building 1,2,3..) which are under one address.

Place is associated with an emergency address to give a more exact location within a building. You can have an unlimited number of places associated with an emergency address. For example, if your organization has multiple buildings, you might want to include place information for each building and for every floor within each building.”

3. Configuring Location information Services Identifiers

It’s important to understand that in Microsoft Teams, there are 4 ways to populate LIS

1. LIS WAP’s
2. LIS Switch & Ports
3. LIS Switch
4. LIS Subnets

When a user makes an E911 call, this is the information used to identify their location.

For a user making a 911 call, the match is performed in the following order with the first matched result being returned.

1. WAP – Service Set, BSSID.
2. Ethernet switch/port – Defining port with switch MAC address.
3. Ethernet switch – Switch MAC address
4. Subnet – Branch office or floor or building

Obviously, this is associated with your validated location (Emergency address + Place).

4. Configuring Network Settings (Network Topology)

Network Topology, as you know it, has to be built in MS Teams for configuring Dynamic Emergency Calling. Based on the network topology, the Teams client provides network connectivity information in a request to the LIS. If there’s a match, LIS returns the location to the Teams client. The Teams client includes this location data as part of the emergency call.

To build network topology, we need to collect & define the below information:

• Trusted IP’s

Trusted IP addresses contain a collection of the internet external IP addresses of the enterprise network and are used to determine if the user’s endpoint is inside the corporate network. An attempt to obtain a dynamic policy or location will only be made if the user’s external IP address matches an IP address in the trusted IP address.

As some organizations are moving to cloud VPN solutions, it could be your Zscaler IP’s.

In MS Teams Admin Center, Go to: Location >> Network Topology >> Select Trusted IP

And use “+Add” button to add the IP’s.

• Network Regions

In MS Teams Admin Center, Go to: Location >> Network Topology >> Click on Manage Network regions

For eg, This can be configured as US region.

• Network Sites

In MS Teams Admin Center, Go to: Location >> Network Topology >> Click on Network Site “+Add”.

For eg, Sites could be Cities in US like Washington, Merriville, Dallas etc.

• Network Subnets

In MS Teams Admin Center

In the left navigation of the Microsoft Teams admin center, go to Location > Network Topology, and then click the Network Site we created.

Select Subnet and click “+Add” button to add Subnet information.

• Configuring Emergency Policies

In Teams, there are 2 types of Emergency Policies:

1. Emergency Call Routing Policy (Applies to Direct Routing Only)
2. Emergency Calling Policy (Applies to Calling Plans and Direct Routing)

Emergency Call Routing Policies help configure Emergency numbers, dial masks per number, PSTN route (usage) per number and Enable Dynamic Emergency calling. This policy can be applied to a user, network site or both.

Emergency Calling Policy on the other hand, helps us configure Security Desk Notifications. We can set “who to notify” and “how they are notified”.

Who: Users or group (O365) for emergency calls notifications

How: There are three options which we can choose in order to notify a certain set of users.

           Send notification only: A Teams chat message is sent to the users and groups that you specify.

       Conferenced in muted and unable to unmute: A Teams chat message is sent to the users and groups that you specify and they can listen (but not participate) in the conversation between the caller and the PSAP operator.

        Conferenced in muted but are able to unmute: A Teams chat message is sent to the users and groups that you specify and they can unmute to listen and participate in the conversation between the caller and the PSAP operator.

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Implementation Considerations

When starting to work out this activity, In my experience, First, make a list of all the stakeholders who will be required for this project:

1. Site Owners
2. A Legal Consultant
3. UC Architecture & Implementation Team
4. Project Management Team
5. Network (Data, firewall etc) Team representatives
6. Carrier representative providing ERSP services.

Second, it’s important to understand, what all PBX’s & devices (users, phones, meeting room equipment) need to comply! Is Microsoft Teams using calling plan, Direct Routing, Operator Connect or a mix of all.

Third, need to understand which device/ user needs dynamic emergency routing.

Fourth, for MS teams, we need to choose which method will be used:

1. ESPR’s
2. ELIN Gateways

Let’s Assume, you want to use an Emergency Service Provider to provide you with the 911 services. There are few vendors but the best ones are Bandwidth & Intrado.

Fifth, engage various site owners & educate them about the laws, so that you get necessary cooperation when configuring it.

Sixth, understand if the org has some mining sites or critical sites, which may already have their own in campus emergency support and may or may not be under the purview of local PSAP.

Seventh, with help from network team, understand how infrastructure is setup. This is important to create Network Topology in Teams.

In my experience, we can categorize sites as below:

Category 1 – Single Building

Category 2 – Single Floor in a Building

Category 3 – Multiple Floors in a Building

Category 4 – Two or more Buildings

Category 5 – Group of Buildings

Now, figure out the total number of soft client users, desk phones, meeting rooms equipment. This will help us know Static and Dynamic Emergency calling requirements.

Hopefully this blog provides insight into configuring E911 services based on the FCC laws.

That’s it Folks! Let me know what you think about the blog. Please post for any comments, questions. I can also be reached at LinkedIn, Twitter, Facebook.