As with any specifics such as these, it is recommended you check with your local laws to see if further information can be found. Having said that, I feel that softphones on mobile devices that are away from the main location would qualify as “off-premises” end users, which fall under what’s being discussed around paragraph 159 in this doc:
Which starts with:
159. In contrast, we conclude that MLTS providers should not be subject to the same location
requirements for off-premises MLTS calls to the extent compliance is not technically feasible. When an
MLTS end user is off-premises, the MLTS does not typically control or have access to location
And paragraph 160, which goes on to say:
160. In light of these factors, we conclude it is premature to prescribe specific standards for
location of off-premises MLTS calls when compliance with our on-site requirements would not be
technically feasible, and we therefore adopt a flexible approach that avoids imposing impossible
requirements. For off-premises 911 calls, the MLTS operator or manager must provide (1) dispatchable
location, if technically feasible, or, otherwise, either 2) manually-updated dispatchable location, or
(3) enhanced location information, which may be coordinate-based, consisting of the best available
location that can be obtained from any available technology or combination of technologies at reasonable
cost. This requirement will take effect two years from the effective date of rules adopted by this order.
The flexibility inherent in this requirement should lessen the burden and the amount of time it will take to
comply. We recognize that as a practical matter, MLTS providers are unlikely to be capable of providing
dispatchable location for most off-premises calls, and that “best-available” location information may be
limited in the near term. Nevertheless, over time this requirement will encourage development of
improved location capabilities for off-premises MLTS 911 calls.
These are just excerpts. Please see the doc for further details and context.
I agree with your second point with a lot of this stuff. In this case, it’s like they acknowledge some devices can’t meet the current requirements based on technical feasibility, but their solution is to just give these situations a later deadline.
From a practical stance, I’d advise all mobile softphone users to consider using the cell phone’s service, or a local phone when calling 911 instead of through the softphone if feasible. Or at least have them understand the difference. Although, that type of explanation would be a good idea regardless of these new rules.