Telecom Industry Changes - Kari's Law / Ray Baum's Act / STIR/SHAKEN / TRACED Act

Work is in progress as noted in the recent community announcement.



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I’ve posted a blog today on Kari’s Law and Section 506 of the Ray Baum Act. In this blog, I outline what your responsibilities are if you plan on selling, leasing, installing, managing, operating, manufacturing, or importing, FreePBX® Based Systems after February 16, 2020.

Admittedly it is a long read just over 3000 words, but considering the FCC Guidelines document for this stuff is over 70 thousand words, I hope this is a pretty good primer as to the details of Kari’s Law and the Ray Baum Act Compliance for the community here. Link to Blog

As @tonyclewis stated above there will also be a webinar on the same topic this week; you can sign up here

Note: All trademarks, service marks, trade names, trade dress, product names and logos appearing in this post are the property of their respective owners :wink:

Just a little update if you haven’t seen it. This was the notice of the effective date for Kari’s Law / Ray Baum’s Act. That date is Jan. 6th 2020 so that means certain parties have until Jan 6th 2021 to be compliant and Jan. 6th 2022 for the rest.

Who has until Jan. 6th 2022?

On-Prem MLTS with non-fixed endpoints such as softphones, wifi devices or devices that move locations. It must be able to update the location details automatically or a manual method must be provided. The example was dialing a voice prompt to set the location.

Off-prem devices to the MLTS, Devices that remotely connect to the MLTS and can be at different locations such as a home. So basically for your telecommuters.

Who has until Jan 6th 2021?

On-Prem MLTS with fixed devices (hotels, fixed desk phones, etc) so most of your standard MLTS installs would be under this.

Fixed Telephony Providers/VoIP Interconnects/Outbound Only VoIP Interconnects.

Basically if you have a “standard” MLTS setup for your business where every phone is fixed and doesn’t move regularly you’ve got a year. If you are any sort of provider/interconnect you’ve got a year.

@BlazeStudios you are correct in stating that there are different dates from the February 16th 2020 date, however, you are intermingling Kari’s Law and the Ray Baum Act here. Although they both, in essence, modify rules and guidelines for the FCC, they are being viewed differently internally.

For new systems or installs the dates are as follows (Note One thing that the FCC has declined to cover at this point is at what level of upgrades (software or hardware) that they are going to determine what you would be required to comply with. They would prefer to work that out on a case by case basis, which to me says, you should C.Y.A. and comply if you run updates on your systems or move to new hardware.):

Compliance dates for Kari’s Law were actually listed in the law, so for those requirements, the FCC has listed an adoption compliance date of February 16, 2020:

  • No Prefix dialing for 911

  • 911 Notification of calls

For providing Dispatchable Location which comes from Section 506 of the Ray Baum Act.

That does have staged implementation dates, as the FCC had their discretion to set adoption dates.

On-Premise - is going to cover the location of the business, as well as any remote facilities or remote phones that are utilized from a regular working location.

Feb 2021 Fixed Devices that are ‘on-premise’ - This would include the obvious hotel phones and desk phones, it would also include phones in which users can utilize hotdesking, as there is no need for someone else to help them move. (although it does make you wonder if the FCC doesn’t understand how IP phones work, you can pick them up and move them to another port on your network within your building, or even another location, and they will still work if registered to a routable system, so that’s bit is going to be fun :slight_smile:
Feb 2022 Non-Fixed that are on-premise - would be Softphones, wifi phones, etc that can be moved, within the premise of the business

Feb 2022- Off-Premise Phones - remote softphones, mobile devices, etc, not located on-prem, this would not include phones in which would be classified as a remote user with a regular workplace (home office etc.).

Also one other item to note is that the FCC’s regulations are not meant to supplant any existing State Laws requiring MLTS e911. So although the FCC may give you a year, depending on your location you may already have some requirements to provide the specific location of your phones.

For example in Michigan varied (based on size and type of facility) MLTS e911 “dispatchable location” requirements are going into effect this month, they won’t start fining until the end of the year, but once again… CYA… who wants to do an install or configuration twice.

Michigan statute

Over 20 other states have similar requirements already.

Alaska, Arkansas, Colorado, Connecticut, Florida, Illinois, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, New Hampshire, Oklahoma, Pennsylvania, Tennessee, Texas, Utah Vermont, Virginia, Washington . All have various laws.

OK Preston I’ll bite. I read your blog and I am trying to figure out if what you are selling is actually helpful - or is it basically nothing more than a disguised advertisement to push people into replacing phones.

If I switch over to using ClearlyIP sip trunks but I do NOT wish to replace instruments with “Brandable IP phones” or any other phones for that matter, and all my phones are fixed location phones, am I screwed or not?

Let’s play some “what do I need” games to get a handle on this:

Scenario #1: 1 dispatchable location (a small office, single floor, front and back door,) 4 extensions on a FreePBX system with 1 SIP trunk, 1 callback location because all 4 phones are programmed to ring when a call comes in the trunk.

Scenario #2 2 dispatchable locations, 1 is “first floor” 1 is “second floor” 12 extensions scattered over a group of offices on both the first floor and the second floor. Slightly larger office. 4 ClearlyIP SIP trunks. I assume that means 12 emergency callback profiles?

Scenario #3 3 physical locations, tied together via private fiber networks, 6 phones on one location that has 6 cubes in a large room, 8 phones on another location that has 6 offices scattered throughout a larger facility, 40 phones at the last location located in 35 offices that are on 3 floors. I assume this means 54 callback profiles, lets say 13 dispatchable locations. The organization has 10 ClearlyIP sip trunks.

In all 3 scenarios, NONE of the phones can move without IT help. (organizational rules)

In Scenario 2 and 3, how do you allocate Callback profiles to the sip trunks? Does the customer just say “gimmie 10 trunks and 54 callback profiles” and the profiles just float around in between the trunks? Or do you have to pay for 540 callback profiles and duplicate each 54 on each trunk because you never know when a specific extension is going to seize a specific trunk? And how does the trunking module tie into all of this?

I don’t see how this ISN’T tying up a minimum of 54 DIDs on Callback profiles. Unless you have a “pool” of DID’s that you allow to “float” around in between customers, and you have some proprietary protocol that communicates from the FreePBX module to you that passes location info, but then once a “floating” DID is assigned to a customer how long does it stay assigned? What if the 911 call center calls back 3 hours later and the DID has “floated” to another customer?

As AdHominem said, this regulation really looks to me like it’s only answerable with statically assigned DID numbers. Even if you have some super-kewel method of dynamically assigning DIDs to your SIP trunks or something, nobody else in the industry is going to do it. Not other SIP providers and definitely not other PRI providers. The telco industry is absolutely going to find some de-facto way of answering this regulation that uses standardized currently available technology, and it just seems that DIDs are the obvious choice that will just drop in. And they are also pretty cheap anyway. And it works with the current programming in existing digital PBXes. For example I have a customer with 100 Nortel digital phones and a Nortel key system that is older than dirt. I’d love to replace it. But their existing “phone guy” sells replacement extensions to them for $200 a phone. So, to them they view this system as having $200,000.00 of phones and they won’t even discuss replacing it. If I bring this law up to them as part of a pitch to dislodge their phone guy and move them off this system, their phone guy will just kick back that the system can do DIDs and it’s being fed by a PRI right now from Frontier Telephone. All that Frontier would have to do to make them compliant is setup a website where they can type in each DID and the address and location it’s in and their phone guy can get them a DID block from Frontier and badda bing. I can’t pitch them 100 “Branded IP” extensions at $200 a pop, don’t you see?

Like most government regulations dealing with technology nobody has bothered thinking about the unintended consequences. And I will point out that Greg Walden is one of my home state’s representatives and 80% of the states residents think he’s an idiot, the only ones that love him are the pro-gunner Bible-thumpers in Eastern Oregon, and that is a fact.

The unintended consequence I see is this is just going to force hundred of new prefixes into every state as each prefix exhausts DID’s, so they can open a new prefix and start assigning DIDs out of it. And when they did this in California the Telcos just loved it because they could then charge LD charges for direct dialing people who live 5 miles away. You know, I had 1 customer last year who after they moved, the NEVER BOTHERED to install deskphones - every single one of their employees had a company-paid cell phone. And the lines were cheap. I would not be surprised if the flood of demand for DIDs, the excuse of new prefixes to gouge the public, is just going to accelerate the move away from deskphones in businesses to cell phones.

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I’m going to be short and sweet about this. Please do not do this in the thread, it is unwelcome. Your post was long, filled with misinformation and lack of knowledge of what is happening, what has been happening and the solutions that are available.

What ClearlyIP is offering is Dynamic 911. It is not a new service, it is a service that has been around for some time because half the country already had most of Kari’s Law in their own versions before Kari’s Law was even drafted.

This thread is about the new regulations, laws and what is need to be in compliance with them. Not for rants like what you just did.

And, Tom, your posts have been short, and lack information on what is happening. So which is better, a long post that is asking for clarification on a bunch of stuff the poster is misinformed on, or a short post that has virtually nothing at all?

Seems to me that you could have dissected my “long” post point by point, responding to each issue, and thereby provided a lot of illumination. For everyone like me bold enough to risk looking misinformed publicly, who posts, there’s 50 other lurkers here just as misinformed who say nothing because they are afraid of someone more informed slapping them down with a non-answer, answer.

Everything I have read on Dynamic 911 talks about the additional locating information sent TO the emergency dispatchers, not the new callback regulation. Much of what ClearlyIP talks about is the callback regulation but they are hazy in their blog on just how they implement it, and whether their phones are required for their implementation. I have to assume that ClearlyIP is offering something in addition to what is currently being sold as “Dynamic 911” but I will wait and see if Preston responds or not. I’d love for it to be hardware independent and I’d look at using it if it was.

At least I am bothering to spend time on this. Most owners of small businesses with PBXes will almost certainly not spend the time and will not make required upgrades. The large ones will because they are targets but 50% of all businesses in the US are small. The vast majority will probably go for decades without having an emergency incident in their facilities and nobody will say anything because they are all small fry and not worth suing. Even ClearlyIP stated in their blog on this that the original e911 regulations took 20 years for everyone to fully implement.

I’m in the “half the country” that DIDN’T have “Kari’s Law, Oregon Version” already. Most of my customers are small and have under 20 extensions in a “small” building but very few of those are sprawled out in a single level. Picking up 100 DID’s might be costly for a 100 seat company but picking up 2 DID’s with 1 on 1 level and 1 on another level, as AdHominem suggested, for a 20 extension company is a dirt cheap solution for a small business - but you shot that down. So OK I get it that your upcoming webinar solution is cheaper than getting 100 DIDs. But for a small business that has 20 extensions - I’m guessing 2 DID’s are cheaper than you or ClearlyIP’s solution. Even ClearlyIP stated that “purchasing additional DID’s is exponentially more costly” which means if you are only purchasing a few you haven’t hit the exponent curve yet and its cheap.

I’ve been involved a high level with starting four telecom companies’s a Wireless Carrier, a Facilities based CLEC, a SIP Provider, and now a new SIP Provider with ClearlyIP. I like to think that we learn from our prior experiences and avoid mistakes we may have made in the past, so we are trying to do just that. It’s also easier to build things right the first time as opposed to making significant modifications after your network is in production. So when designing our platform, with the deadlines for requirements of providing call-back numbers and a dispatchable location coming up soon, we decided to build the system from the start to provide support for these regulations, from looking around at similar providers we seem to be the first to tackle this, others will follow I’m sure.

Your assumption that you would need to utilize a bunch of extra DIDs to provide call-back numbers and the dispatchable location is valid of how many carriers currently provide e911 service. Most providers pair an e911 address directly to a DID, your PBX sends that DID as the caller ID of your emergency route, and your provider picks that up and provides the e911 validated address on their system to the 911 Call Center/PSAP. So if you need to add additional e911 addresses with those providers, you would need to purchase another e911 location, and potentially another DID for that specific location. (Making some MSRP assumptions that a DID with those providers is $1.00 per month and an additional e911 location is $1.95, each combination would be $2.95 ) These carriers need the extra DID, as that is how they are mapping their validated e911 addresses.

With ClearlyIP e911 service, you do not have to associate one of our DIDs with a specific e911 profile. We specifically designed that to provide the highest cost savings and flexibility here.

There are two pieces of data you can configure with our service, an Emergency Call-Back Profile , and second an optional Dispatchable Location. If you have an Unlimited SIP Trunk associated with your account on our system, we include (1) Emergency Call-Back Profile and (1) Dispatchable Location. If you are on a Minutes of Use (MOU) plan, you would need to purchase any Emergency Call-Back Profiles or additional Dispatchable Locations you required.

Emergency Call Back Profile - MSRP $1.00

An Emergency Call-Back Profile Consist of four pieces of information:

  1. Company Name

  2. e911 Validated Location Address (also defines what locality we pay taxes to on your account.)

  3. Caller ID to be sent with the 911 call (which can be one of our DIDs or your DIDs from another carrier if utilizing multiple providers)

  4. A Call Back Number to be sent with the 911 call.

The second piece of data we have is the Dispatchable Location , and you can purchase as many Dispatchable Locations as you need.

Dispatchable Location - MSRP 50 Cents

A Dispatchable Location is a detailed location delivered to the 911 call center or Public Service Answering Point “PSAP” with a 911 call. It consists of the validated street address of the calling party, plus additional information such as suite, apartment, or similar information necessary to adequately identify the location of the calling party.

A Dispatchable location does not modify the call-back number associated with the Emergency Call-Back Profile provided. You can associate many dispatchable locations with the same Emergency Call-Back Profile. A Dispatchable location is provided from the emergency responders’ point of view, information sufficient for guiding first responders to the right door to kick down. For calls placed from multi-story buildings or campus environments, first responders will typically require specific floor and room information, in addition to the street address of the building. For calls placed from many small businesses, on the other hand, a street address alone may provide first responders all the information they need to locate the caller quickly.

So now let’s look at your examples, I’ll compare our solution to what would be existing with similar providers.

In this scenario, as with most small businesses, the dispatchable location is going to be the primary address. Your emergency route would send the single dispatchable address and a single call back number and make a notification at that location (email, SMS, and page group) that the call has been placed.)

With Call-Back numbers, you do NOT have to send a Call-Back number to a specific phone that calls 911. It is preferred, of course, but not a requirement, so you can define the call back number to go back to a front desk or management office, etc. I’ll assume with 4 SIP trunks that they only need 1 call back number. So in this scenario, I would say (1) Emergency Call-Back Profile and (2) Dispatchable Locations.

So Our MSRP would be $.50 per month for the additional Dispatchable Location. An imaginary competitor would be an extra $2.95 to $5.95, depending on whether they provided a free e911 location for you as some do.

In all 3 scenarios, NONE of the phones can move without IT help. (organizational rules)

So this one, of course, is a little tougher and can vary a bit depending on the actual layout and use of the facility, the floor plan, and size of the o


One call-back profile, 1 dispatchable location

A first responder is going to go to that one big room, so the requirements here are easy,

Location 2

Since it sounds like the offices are separated and could be confusing for the first responder, I would go with one call-back profile, 6 dispatchable locations.

Location 3

Once again, depending on the layout and use of the building, you could have some variables here, but a first pass I would go with 1-3 call-back profiles, 3-35 dispatchable locations. You have about ten offices per floor that’s not a huge number, so potentially you could dispatch to the floor level, although if they spread out or an odd floor plan, you may decide to dispatch to each office. I’ll show you the most expensive option here, which would be three call back profiles and 35 dispatchable locations for that location.

So in total, in this scenario, we have five call back profiles and up to 42 dispatchable locations. So about $25 per month in additional charges with ClearlyIP. Our imaginary competitor would be $123.90 by my estimate per month to provide the same level of dispatchable address.

The way this works with our module, from within the module itself, you can map your Emergency call-back Location and Your Dispatchable Location from each extension on your system. Making this stuff easy to deploy within FreePBX, otherwise, you would need to dig around in the emergency notification CID of each extension and make sure they are on the correct route, which can be timely and a bit error-prone.

As for your question about using ClearlyIP phones, indeed, you can do that :wink: but it’s not a requirement. There are advantages in areas such as hotdesking and having a default profile for 911 calls to be enabled even without an end-user logged in. Plus, being able to have end users modify their e911 address using a phone application, as well as a bunch of other cool stuff we are building, but it’s not going to be required here.

You don’t even have to use us for your voice traffic since we are not pairing our e911 services with our own DIDs you can continue to use your existing services and use us just for your e911 support and compliance. In some areas, like where I live in South Carolina, there are not a lot of options for over the top SIP Providers. Local carriers with rural telecom protections and don’t have to port out their numbers. Most businesses are still stuck on analog and PRI lines. Using services like ours, you can provide the location-based e911 to your product offerings and continue to utilize the same voice providers, although we wouldn’t mind providing both where we can.

To get the details about how the modules work, and likely a better explanation of all this from @tonyclewis I would suggest signing up for the webinar here, he will cover not only these pieces but also show how the required notification is integrated within our module as well:

BTY, @BlazeStudios I do think what we are doing here is different and unique, and as far as I know, there are Not other providers with modules and integration into FreePBX doing the same thing at this point. We were in a position to build something new, so that’s how we got here first. If others are already doing similar stuff, please point them out, it would be great to take a look and see if there are things we have missed, we would be happy to let anyone that wanted to try this for free to do so, There are a lot of moving pieces to all of this stuff, and it’s likely we will learn more and have to make adjustments as we go like everyone else reach out to us if you want to bang on this stuff for yourself on your own systems.

In regards to Dynamic 911? Not really, I’m rolling it out. My upstream provides the ability so if I have that option so does everyone else on my upstream. In regards to making it happen with a module in FreePBX, yes you are. Then again, and don’t take this the wrong way, my business model doesn’t focus on FreePBX users. I have users with Mitel’s, Matrix’s, PhoneSuites and other types of analog/TDM based PBX systems.

Again, don’t take this the wrong way, I’m not looking to be another SIPStation. That is to say everything is based on my end users having FreePBX to connect to be for SIP Trunking so I would have modules, etc to integrate with FreePBX. The reality is the majority of my customers are on my hosted/multi-tenant platform and the rest that do SIP Trunking well only 4-6 have FreePBX boxes that I installed a few years back and now their contracts are up, they want it gone. They’re going fully hosted.

Installing PBX systems is something I will do when the customer absolutely needs/wants it and is looking for something other then a Mitel that they are used to. However, at the end of the day I’m an Interconnected VoIP provider and that’s where my focus is. I am more concerned by multiple PBX systems working with my service vs making FreePBX systems do flips and jumps with my service.

OK I get most of this except there is one piece of that I don’t completely understand and that is the “callback”

What it appears to be is the following:

  1. An organization can provide a CID callback number to PSAP that is a DID for the extension, assuming every extension in the organization has a DID on it. In that case notification to a “front desk” is_not required.


  1. An organization can provide a CID callback number to PSAP that is their “main number” that rings at their “front desk”. In that case notification to a “front desk” from the extension originating the 911 call is required.

But what I find strange is that someone said that the regulation apparently does NOT require that front desk location to be staffed 24x7??? If that is the case what about the scenario where it is 7pm and someone is working late in organization #2, they make a 911 call and hang up, the PSAP calls back the main number and gets after hours voicemail? Isn’t that a hole in the regulation large enough to drive a fire truck through?

As for the rest of it - ultra kewel, baby. Particularly the ability to use it with analog/PRI lines. So someone with a FreePBX system and POTS handoff is covered.

Now one point I will bring up is you mentioned rural areas. For example I have a customer in Seaside OR. There are basically 2 broadband choices for data, one is Spectrum Cable the other is CenturyLink. Spectrum and CenturyLink do not offer SIP except over fiber from them. If you get just a data line from either of those ISPs, and find a “national” SIP provider, all your SIP trunks will be hauled over the Internet to a remote server in Portland (if you are lucky, it might be even more remote)

So if there is a storm that cuts the fiber lines from Seaside OR to Portland OR, well while you could still pick up an analog line from CenturyLink and make a 911 call that would connect to the PSAP, you could not make a 911 call to your SIP provider. (or to you guys, ClearlyIP)

In regards to the callback, part of the law covers notifications (if possible for older systems/must for newer ones) and that there will be at least one emergency contact(s). These contacts would receive alerts over SMS, email, etc. and should be there as the point of contact for EMS. These contacts can be on site or remote, if remote they must be able to be on site if required. So the preference is that the person that made the 911 call be the one that is called back, however, the emergency contact(s) are acceptable as they should be with EMS.

I will say that RingCentral and a few others submitted comments to the FCC that business of certain employee sizes should be exempt, however, they were overruled on them. There is a caveat that a small single level office space can use a global location/callback for all stations in the building. This generally falls under, as pointed out, EMS gets to point of entry and can easily get to the location because there’s people around or they can see it on entry.

As for POTS lines these are going to be unsuitable for this. As they traditionally do not allow multiple CallerIDs to be sent over them. One line = 1 DID. So a hotel or school with 6 POTS lines for their PBX cannot present the require Dispatchable Location details. The service doesn’t support it.

Lastly, and this one is often conflated that some how doing things over IP/SIP is not as reliable infrastructure wise and then presents a scenario that would impact a PRI/T1 just as much as a Fiber/DSL/Cable line. If the storm takes out the line or something is cut or a tree lands on a junction box, the lines are down. If the F2 connectors get exposed or wet, it can do down or be filled with static (PRI/T1). In both cases there would need to be a POTS line as a back up and where ever that POTS is, that is the Dispatchable Location. Which means someone has to get to that POTS line, call 911 and either go to the point of entry or sit in the room the location specifies to meet EMS.

OK this is really lastly. To touch on non-fixed and mainly rural areas. Yes, there are locations where there isn’t an actual address or postal code etc. The law accepts that and states that in instances where there is no postal address, etc to locate the call or there is no local 911 service the call must go to the regional emergency center to be routed to the proper emergency services.

In cases of non-fixed services (I take my ATA from MI to FL for the winter) the provider or PBX admin must provide a wa y to either automatically update the location, offer a manual option to update the location by the user or route the call to a national emergency center to be routed.

So there are specific cases where circumstances will not allow a fixed dispatchable location and they are addressed.

As a point of information my Seaside customer DOES use a single POTS line as a 911 backup at their site because they understand the reliability issues with the SIP trunks they have going in there. Of course, from a reliability standpoint if Seaside OR ever suffered a Cascadia subduction quake then everything - sip, internet, pots, you name it - will likely be a jumbled mess after the tsunami waters roll back out to sea.

My last point was that if ClearlyIP is the e911 provider and access to them from the freePBX system is via the same internet connection that SIP trunks come in on, and those SIP trunks go down then ClearlyIP goes down also.

POTS trunks wouldn’t likely be compatible with a hotel PBX. However I will point out that a multitenant apartment dwelling might have 20 POTS lines coming in 1 to each apartment, each line would have a separate extended destination even though they all have the same street address (different apartment numbers) so it doesn’t seem that the POTS technology is incompatible because it’s POTS, it’s how the POTS lines are USED that determine compatibility.

But getting back to the heart of my question - the availability of the emergency contact. Is or isn’t the designated emergency contact required to be available 24x7 or at the least, every time that there are people who could potentially pick up an extension? What good is notification of the emergency contact if the call comes at 2am and the contact is a sound sleeper??? Does the law allow for unavailability of the emergency contact or not?
I would have knocked the RingCentral objections too because in that case at least all ring central extensions are known to ringcentral and they can easily setup location data for each extension.

Would Page Pro be sufficient for the notification portion of the law? Or is Sangoma planning on releasing an update that would not require a commercial module?

I wouldn’t see why not. You are calling them, which is acceptable.

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Tom you seem to always be in the loop, I thought I seen a Sangoma employee post that they were going to make a statement on all of this(I assume about upcoming updates). Have you heard anymore on that?

I know as much as you on that one.

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I think (there has been a lot this week) it was a comment from @jsmith. I think his comment was there is stuff in motion but I am not sure if there was an expectation of an official comment.

With the due date being 1 month away even if not a member of the open source team, I would expect their marketing/product management to release something soon on social media/blog etc.

Edit See


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