[VoiceOps] RAY BAUMS Act - How are people planning on complying?

[Brandon Martin]

On 1/23/20 12:10 PM, Zilk, David wrote:
> 1)When several lines at a site don’t have DIDs, and uses a common site 
> phone number for their CLID.  How do you provide different location 
> information for them.

Most folks I've talked to have been urging customers to get more DIDs 
for years rather than continuing to hide tons of desks behind a single 
inbound number with extension dialing.  This works well for your typical 
office and, while not necessarily cheap, comes with obvious additional 
benefits.

For situations where this is either impractical due to cost or silly due 
to the fact that nobody's going to call those phones directly anyway 
(e.g. courtesy phones in a warehouse or shopping center), the approach 
I've heard of is to either have the phone itself add a SIP header or 
translate from SIP registration identity to location at the SIP proxy 
and add a similar header defining such a "dispatchable location" which 
is then passed on to the PSAP.

My understanding is that such headers are vendor/operator specific.

The latter complicates callback options which I gather is also an issue 
(I'm not a PSTN regulatory expert by any means, I mostly stick to 
slinging IP datagrams around).  Approach I've heard of is to reserve a 
few DIDs for E911 callback and re-route them on the fly as outbound 911 
calls are placed by putting that in the CLID field.  IDK if that's 
kosher or not.

> 2)      When there are shared lines on devices in different locations at a site using the same DID.  How do you distinguish the correct location of an emergency call made from one of them.

The above approach works here, too.

> 3)      When the caller uses a softphone that doesn’t have a fixed location.

This one's complicated.  If you control the softphone and it's on a 
mobile device, you can have it provide you with the device's notion of 
location, which is often quite accurate especially if GPS is usable, and 
put that in the aforementioned headers.

If you don't control the softphone, or it's on a PC, you're pretty much 
sunk.  You may not be able to even offer service in such situations 
without taking additional steps.  I'm not sure what these new regs have 
to say about that.  In the past, it was pretty well understood at least 
my reasonably technical folks that you basically had no E911 in these 
situations.

The approach my A-Z terminator takes if you don't have E911 data 
configured for a DID may be viable.  They run their own 911 dispatching 
service that you get routed to who asks the caller for their location 
and then routes it, along with the appropriate manually-collected 
metadata, to the appropriate PSAP.  Obviously they charge (handsomely) 
for this service.