Schools should have accurate, location-specific enhanced 911 (E911) systems on campus. Regardless of any legal liability or regulatory reasons that may compel these systems,concerns are more than enough to justify them. Now, with the availability of IP-enabled telephone networks, education institutions are on the cusp of a revolution in the way campus E911 programs are managed.
Colleges and universities, with sprawling campuses and many on- and off-campus buildings networked back through the primary PBX switch, present particular challenges for 911 systems. Often, the remote sites need to route to a public safety answering point (PSAP) other than the main PSAP, compounding the difficulty of determining the exact location of an emergency caller.
Network administrators know that IP-enabled voice systems have brought many converged network benefits to colleges and universities. However, they have added another level of complexity for campuses that are managing or planning a holistic E911 program for campus phones.
The evolution of IP telephony can make campus E911 programs much more dynamic and accurate. But at the same time, the programs require additional knowledge and management capabilities, especially if station information being compiled is coming from a traditional multi-line PBX system and an IP call manager.
The configuration of the environment will determine the design and installation of an E911 solution. For example, is the configuration a fully enclosed VoIP environment, or is it a hybrid environment using both VoIP and traditional telephones? Communications professionals will need to determine, for instance, how discovery and management of the hard/soft phone and its location within the enterprise are mapped and reported within the system. Procedures need to be established for the private switch/automatic location identification (PS/ALI) database upload to regional E911 data services centers. Assurances of proper call routing of a 911 call are needed, with callback capability to the desktop.
Some of these capabilities are built into VoIP PBX platforms, but others are lacking. One platform may create subnets for clusters of telephone devices, and another may detect location identity to the desktop. All IP-enabled issues are in addition to the traditional challenges associated with running a campus E911 program.
Dynamic vs. manual
One problem with traditional enterprise phone systems is that location information typically is entered manually. The information is only as reliable as what was typed into the station-management software. Without special systems in place, there often is no dynamic or automatic updating of the station-management software even when moves, adds or changes are performed in the field. Because almost all information is entered manually, it changes only when a system administrator edits the fields specifically.
Most modern PS/ALI systems that interface with IP networks provide system managers the opportunity to dynamically update and maintain the data in their enterprisesystem and ultimately in the PSAP's regional database.
IP-enabled systems create location information databases that involve these important pieces of data and more:
Predefined emergency response locations.
Predefined emergency location identification numbers that can be assigned to each data switch on a campus network or to wireless access ports.
Port information from a data switch.
Station information, including the identity and media access control (MAC) address of a station.
Other information may be collected as well (such as room,and jack), although this information often is not dynamically updated unless a campus has systems that can “push” information to the PS/ALI management software.
When an IP phone plugs into the network, it registers with the campus network call server and is assigned a campus IP address. All buildings, on campus or off, can have their locations built into the database fields. This is especially helpful for identification of stations at remote sites on the network.
IP address assignment triggers the campus call server to “push” information to a location information server or the PS/ALI system whenever a new device is on the network, or an IP phone moves its location and is assigned a new IP address. Some IP-enabled PS/ALI programs can be programmed to “discover” information regarding IP phones (MAC address/station information/switch and switch port) across a network on a routine basis. This helps ensure that the data maintained within the system is updated, accurate and reliable.
With a 911 call from within a campus' managed IP network environment, the information can be considered more accurate and thorough thanks to its dynamic updating. Also, in addition to transmission of the usual PS/ALI station-level information, an emergency response location or emergency line identification number assigned to a data switch can be transmitted to the PSAP, as well as the PS/ALI, providing enhanced location information in a campus environment.
Current versions of IP-enabled PS/ALI location software packages have the ability to dramatically improve and enhance the abilities of campus E911 programs. There are still unresolved issues, however.
One is the actual room/floor/jack location of the phone. Automatic updating of wire and jack changes often is not available. Information on the room/floor/jack can be entered manually into any campus PS/ALI database when the system is initialized and can be updated manually for moves, adds and changes. However, keeping this data accurate will remain a challenge. This information cannot be dynamically updated unless a campus has a software system in place that is maintaining location information on the wire/jacks and can dynamically send changes to this software.
Most systems can dynamically track IP phones only to the data switch level. Phones using Category 5 cable can be as far away as 315 feet, so campus E911 program managers need to realize that callers may be several floors away from the actual data switch location. Some systems can go beyond the switch level and detect the caller down to the port level.
Another challenge is routing remote callers to the proper PSAP. The ability for a campus IP voice network to consistently route remote callers to their appropriate local PSAP still is not technically feasible. Technological solutions are in development, but no large-scale solution is available.
Resolution of these issues is part of a proposal by the National Emergency Number Association (NENA). In this proposal, a version of a master street address guide would reside in the database to help route 911 calls to the local PSAP for the network that they are using, as opposed to the remote network to which the caller is authenticated for use of his or her IP phone.
Resolution of this issue is not expected soon. The challenge here is not technological, but rather the legal and operational issues surrounding the placement of this master guide into the database.
Campuses that enable remote users to authenticate and use the campus IP telephony network, whether a VPN (virtual private network) client is used or not, need to understand that remote user addresses typically are not provided unless the remote users are required to log into a management program and update their physical locations. Implementation of this on a wide scale is impractical at this point.
As more campuses leverage their wireless local area network infrastructure for voice over IP, there will be challenges to extracting accurate E911 information from Wi-Fi telephone handsets. This condition may be magnified by devices that combine Wi-Fi and cellular capabilities. This need for enhanced automated location discovery is also an issue being worked on by NENA and IP system makers.
For now, the best advice for communications technology professionals is to work closely with their IP network vendors, PS/ALI database vendors and others to identify solutions for accurately determining current and planned options for the location information of remote IP phones.
Semer is executive director of ACUTA, the Association for Communications Technology Professionals in Higher Education. Ostrom of Washington State University chairs the Legislative and Regulatory Affairs Committee for ACUTA. Peabody is deputy CTO in the Office of the Chief Technology Officer for the city of Washington, D.C.
Four main drivers for having E911 programs:
- It's the law
A number of states require owners of multi-line telephone systems to use E911 so that emergency callers — those using PBX or Centrex systems — inside their facility can be located. The number of states enacting these laws is growing. The National Emergency Number Association website has more information at www.nena.org.
Keeping faculty, students, staff and visitors safe is a priority on any campus, and E911 is an extension of that objective. Many campuses go so far as to route E911 calls right to their campus police or public-safety department. This may be done in a dual routing path, both to the department and to the PSAP, but in some cases the school designates the department as the PSAP. The logic is that internal public safety staff is more familiar with the campus and can respond more quickly.
A school can be sued for failing to provide adequate information about the location of a caller from a campus phone system. Viewed in the context of a potential liability, the cost of deploying an E911 system is much easier to justify. Also, the Occupational Safety and Health Administration (OSHA) may consider failing to adopt E911 as evidence that an institution did not maintain a hazard-free workplace for employees. That could mean regulatory fines.
Dealing with large enterprise systems is a complicated, continually changing process. With E911 systems, station locations are known and stored in a database, and are updated in response to all moves, adds and changes. PS/ALI (private switch/automatic location identification) empowers the PBX user to update the 911 database with the specific location of each extension. This provides emergency dispatchers with the most accurate information at the most critical times.
The FCC's view
There is no federal law or regulation requiring multiline telephone systems (PBX or Centrex) to comply with E911; the Federal Communications Commission (FCC) is studying whether to adopt such a requirement.
In June 2005, the FCC required interconnected VoIP providers to transmit 911 calls, as well as a callback number and the caller's registered location for each call, to the public safety answering point (PSAP) or other designated answering point. Under the order, 911 calls must be routed via the dedicated wireline E911 network using Automatic Numbering Information (ANI), and the caller's registered location must be available from or through the Automatic Location Identification (ALI) database.
Although the FCC did not specifically state whether VoIP services offered by colleges and universities fit within the definition of interconnected VoIP provider, a strong argument can be made that these institutions are not “providers” under the commission's order.
However, if an institution is considering contracting with a commercial VoIP provider to provide telecom services on campus, it is important to make sure they are in compliance with this requirement. In addition, if students independently sign up for VoIP service from a commercial provider, these rules would apply, and the provider would be required to transmit the student's calling location and callback number on campus.