22. We agree with commentators who argue that some minimal content is necessary to ensure that the notice serves its intended purpose of assisting the company in providing assistance to first responders in the event of a 911 call. For example, NASNA states that the Commission should “absolutely” set the minimum content for notification and that it should “require that what is sent to PSAPs also be sent to PSAP.” RedSky says the notification should also include the date and time of the 911 call. Avaya suggests that the notification “should include details that cannot be transmitted to the PSAP,” such as “location information that uniquely identifies the caller`s location” and alerts with acknowledgement and escalation capabilities. 105. Based on the available documentation, we refuse to disclose the extent of improvements to an existing MLTS that would trigger compliance with the law and regulations. We disagree with NASNA that any improvement to an existing MLTS, no matter how minor, should trigger the obligation to comply with the Kari Act and implementing regulations. We conclude that such a policy would not be consistent with the clear wording of the Kari Act, which limits the application of the Act to MLTS manufactured or put into service after February 16, 2020, and with our decisions on upgrades related to the above discussion of the definition of “system hardware software enhancement”. It is also unclear what would constitute the core functions of the MLTS in this context, and a deeper and broader examination of this issue could increase the resources required to meet the requirements of the Kari Act and our regulations. It is therefore difficult for us to answer this question in the abstract and it would be more appropriate for the Commission to deal with it in response to a particular set of facts, if any. Parties may submit a request for a declaration to remove uncertainties and the Commission may remove any uncertainty in the market if necessary.
32. We also note Ad Hoc`s concern that some MLTS business owners and operators are currently reporting difficulties in configuring MLTS devices to allow simultaneous notification in addition to calling 911 emergency services. Therefore, according to Ad Hoc, the Commission should make its proposal on the timing of notification dependent on what is “technically feasible”. We associate this requirement with the technical feasibility of simultaneous notification, as required by ad hoc requests. 18. Kari`s law requires an MLTS to support notification when an end-user makes a 911 call, but it does not specify what information must be provided in the notice. In the NPRM, the Commission proposed to define “MLTS notification” as “an MLTS function that can send notifications to a central location of the facility where the system is installed, or to another person or organization, regardless of its location. Examples of notifications include screen pop-ups with audible alarms for Security Desk computers with a client application, text messages for smartphones, and emails for administrators. At a minimum, the notice must contain the following information: (1) the fact that a 911 call has been made, (2) a valid callback number, and (3) the caller location information that the MFTS transmits to the Public Safety Call Centre (PSAP) with the 911 call. `86.
In addition, the Commission sought its views on whether there were circumstances in which the proposed definitions of “manager” or “operator” of the MTLT should extend to business owners. The Commission noted that NOI commentators on corporate communications noted that some business owners purchase, operate and maintain their own on-site telephone systems using PBXs, while other business owners enter into contractual agreements with third-party hosted network and service providers. The Commission stated that it did not believe Kari`s law was intended to extend liability to business owners who purchase MLTS services but have no control over how those services are configured or delivered. Nevertheless, there may be instances where business owners acquire, operate and maintain their own MLTS systems or exercise active control over the configuration and deployment of MLTS by third parties. The Commission sought an opinion on whether, in such cases, business owners should be considered MLDM managers or operators and what evidence of active control should be considered in this decision. 104. AT&T and NASNA also raise the question of what level of upgrade to an existing MLTS would be significant enough to constitute manufacturing, importing, selling, leasing or installing that triggers compliance with the Karis Act if upgrades are made after February 16, 2020. AT&T states that upgrades that have nothing to do with basic MLTS functions in existing systems should not trigger the obligation to comply with the Kari Act and implementing regulations.
NASNA urges the Commission to ensure that any future enhancements to the MTTS hardware or software made by a company provide direct dialing and notification capabilities, as well as the same dispatcher location information that would be received from a PSAP. According to Kari`s law, multi-line telephone systems must also inform the staff of the establishment that the call has been made. Kari`s law ensures that people in need can easily call 911 and that first responders can help them quickly. The law also states that office, school or hotel staff are automatically informed of the situation and can also help in case of emergency. Kari`s law ensures that anyone can reach a 911 call centre if they dial 911 from an MLTS. The law is named after Kari Hunt, who was killed by her ex-husband in a motel room in 2013. Her daughter tried to call 911 four times, but the calls were never received because the motel`s phone system had to dial “9” before each call to get an outgoing phone line. 27. We also adopt BRETSA`s proposal to replace the term “pop-screens” in the NPRM with “visible screen messages”, which seems clearer to us.