[VoiceOps] Ray Baum's act and all-softphone deployments

[Mark Lindsey]

1. These are legal questions and IANAL so get a legal advisor. Here's one you can start with because these guys are very technical: Jonathan Marashlian, jsm at commlawgroup.com. Penalties can be $10k from the FCC for noncompliance, and one operator was ordered to pay $41M by a jury for mismanagement of VoIP. 

2. The FCC summarizes all the requirements here: https://www.fcc.gov/911-dispatchable-location
Softphone VoIP apps that can make or receive calls using phone numbers are examples of "non-fixed Interconnect VoIP". 

"Fixed" VoIP is more-or-less something that requires a technician to relocate. "Non-fixed" means that thet end user can move it themselves. So a 4 pound desk phone that can be connected to any Ethernet network and REGISTER via the Internet could be "non-fixed".

3. As for updating your callers' location, by January 6, 2022, you either need to either:

A. Automatically detect it "if technically feasible" (Redsky is the market leader here) 

OR

B. Allow the user to update it using only the CPE which might mean the smartphone, or it could mean the desk phone. 
(47 CFR § 9.11(b)(4)(ii)(B).)


4. As of NOW (since January 6, 2021) VoIP providers already must be providing dispatchable location for every outbound 911 call, which includes enough information to a first responder to find the victim inside a campus, and inside a building. There are other obligations too, like notifying a central location.

This isn't legal advice - this is just for information purposes only. But these are some of the guidelines we're using for all of our Voice engineering efforts.


The requirements on anyone who sells Voice service using phone numbers have grown a lot in complexity and technical specificity in the past few years.  

Mark R Lindsey, SMTS | +1-229-316-0013 | mark at ecg.co | https://ecg.co/lindsey/ <https://ecg.co/lindsey/>







> On Sep 27, 2021, at 2:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
> 
> I just had a call with Bandwidth about using their Dynamic Location Routing product to fill in the very specific location info required by this act.  However, I asked them a question he said had never been asked; what are we to do with permanently mobile (all softphone) companies.  I can't believe that in 2021, people are still insisting on physical phones all the time.  I've get several soft-only customers, or maybe a physical phone for a couple of receptionist type people.  Some have offices that they almost never use.
> 
> So...what are the rest of you doing with this?
> 
> I thought there was a legal option to say "don't use your mobile softphone" but maybe not?
> 
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