Remember to setup E911

[billsimon]

He's a lawyer, doubt he needs your advice on interpreting the law.

I don't get the hostility here. Samot has written at length on this forum and elsewhere about E911 because he has studied the new laws carefully--something that not many have done or have done well. One would think that expertise would be appreciated.

Besides not every lawyer is an expert at understanding every kind of law.

 

[dhoppy]

Expertise is appreciated. But, there are ways of sharing one's expertise without seeming condescending.

 

[Samot]

Expertise is appreciated. But, there are ways of sharing one's expertise without seeming condescending.

There was no condescension, at least towards you.

 

[phinphan]

Here is the entire text of Kari's law

Public Law 115-127
115th Congress

An Act



To amend the Communications Act of 1934 to require multi-line telephone
systems to have a configuration that permits users to directly initiate
a call to 9-1-1 without dialing any additional digit, code, prefix, or
post-fix, and for other purposes. <<NOTE: Feb. 16, 2018 - [H.R. 582]>>

Be it enacted by the Senate and House of Representatives of the
United States of America in Congress assembled, <<NOTE: Kari's Law
Act of 2017. 47 USC 609 note.>>
SECTION 1. SHORT TITLE.

This Act may be cited as the ``Kari's Law Act of 2017''.
SEC. 2. CONFIGURATION OF MULTI-LINE TELEPHONE SYSTEMS FOR DIRECT
DIALING OF 9-1-1.

(a) In General.--Title VII of the Communications Act of 1934 (47
U.S.C. 601 et seq.) is amended by adding at the end the following:
``SEC. 721. <<NOTE: 47 USC 623 note.>> CONFIGURATION OF MULTI-
LINE TELEPHONE SYSTEMS FOR DIRECT DIALING
OF 9-1-1.

``(a) System Manufacture, Importation, Sale, and Lease.--A person
engaged in the business of manufacturing, importing, selling, or leasing
multi-line telephone systems may not manufacture or import for use in
the United States, or sell or lease or offer to sell or lease in the
United States, a multi-line telephone system, unless such system is pre-
configured such that, when properly installed in accordance with
subsection (b), a user may directly initiate a call to 9-1-1 from any
station equipped with dialing facilities, without dialing any additional
digit, code, prefix, or post-fix, including any trunk-access code such
as the digit `9', regardless of whether the user is required to dial
such a digit, code, prefix, or post-fix for other calls.
``(b) System Installation, Management, and Operation.--A person
engaged in the business of installing, managing, or operating multi-line
telephone systems may not install, manage, or operate for use in the
United States such a system, unless such system is configured such that
a user may directly initiate a call to 9-1-1 from any station equipped
with dialing facilities, without dialing any additional digit, code,
prefix, or post-fix, including any trunk-access code such as the digit
`9', regardless of whether the user is required to dial such a digit,
code, prefix, or post-fix for other calls.
``(c) On-Site Notification.--A person engaged in the business of
installing, managing, or operating multi-line telephone systems shall,
in installing, managing, or operating such a system for use in the
United States, configure the system to provide a notification

[[Page 132 STAT. 327]]

to a central location at the facility where the system is installed or
to another person or organization regardless of location, if the system
is able to be configured to provide the notification without an
improvement to the hardware or software of the system.
``(d) Effect on State Law.--Nothing in this section is intended to
alter the authority of State commissions or other State or local
agencies with jurisdiction over emergency communications, if the
exercise of such authority is not inconsistent with this Act.
``(e) <<NOTE: Applicability.>> Enforcement.--This section shall be
enforced under title V, except that section 501 applies only to the
extent that such section provides for the punishment of a fine.

``(f) Multi-Line Telephone System Defined.--In this section, the
term `multi-line telephone system' has the meaning given such term in
section 6502 of the Middle Class Tax Relief and Job Creation Act of 2012
(47 U.S.C. 1471).''.
(b) <<NOTE: 47 USC 623 note.>> Effective Date.--The amendment made
by subsection (a) shall apply with respect to a multi-line telephone
system that is manufactured, imported, offered for first sale or lease,
first sold or leased, or installed after the date that is 2 years after
the date of the enactment of this Act.

Approved February 16, 2018.

LEGISLATIVE HISTORY--H.R. 582 (S. 123):

I dont think it applies to me (my opinion and my risk) but I am trying to comply with it anyway as it makes sense to do so. Our situation this week points out the need to be aware and get 911 working.

I don't hold myself out as a telecommunications lawyer. I just read the plain language of the law. I am not giving legal advise to anyone other than myself. I think we should comply with the law because it makes sense and protects us, our clients and people using our phone system.

 

[phinphan]

As in most things, a simple law has a very complicated interpretation. See the FCC fact sheet. I now know more about it than I ever want to. FCC Fact Sheet on Kari's Law

 

[Halea]

I don't get the hostility here. Samot has written at length on this forum and elsewhere about E911 because he has studied the new laws carefully--something that not many have done or have done well. One would think that expertise would be appreciated.
Besides not every lawyer is an expert at understanding every kind of law.

@billsimon : I don't think that there is any hostility here, at least with the arguments that I've seen thus far. If you want to see hostility I would suggest that you actually visit some forums where legal texts are being debated.

As for Samot's "studies of the law" and "writing extensively" about it, you would forgive me for the bluntness, but being talkative or repetitive is no expertise or proof of knowledge. If all laws were interpreted by everyone in a maximalistic way, as Samot does, there would be no need for courts, the screaming voices would always prevail.

It's ok that people talk about how they interpret the law, after all nobody is entitled to not-know the law. So everyone needs to know something and consequently have an opinion. On the other hand it's best to let the law professionals to make the assertions about the implications of the law.

So, to be clear, Samot is entitled to his opinion about what he thinks the new law says and he should be able mention it any which way he pleases.
But he should abstain himself from claiming that someone else is making the wrong interpretation of the law, especially when that someone else is apparently a law professional and most obviously Samot himself is not.
(I actually don't know whether Samot is a lawyer, but I am inclined to think that he is not, for the simple reason that one of the first things that they teach you at law school is to not wear a lawyer's hat for the purpose of showing-off when you are in a social environment).

 

[phinphan]

If I ran an IT company or sold MLTS, I'd err on the side of implementation under all circumstances. It makes both economic and legal sense to see it that way. Its too expensive to hire lawyers to interpret the law for all circumstances (and they'd be just guessing for a decade at least, IMHO) and too risky to end up a defendant in a tragic case. Err on the side of implementation.

 

[Samot]

@phinphan This is the from the fact sheet they released last year on this:

https://docs.fcc.gov/public/attachments/DOC-358435A1.pdf

f. Definition of Person Engaged in the Business of Installing an MLTS

79. Kari’s Law also places obligations on any “person engaged in the business of installing, managing, or operating” an MLTS. Such persons may not install, manage, or operate the MLTS for use in the United States unless it is configured for direct dialing of 911. In addition, such persons shall, in installing, managing, or operating the MLTS, configure it to provide notification if the system is able to be configured to provide notification without an improvement to the hardware or software of the system. In the Notice, the Commission proposed to define a person engaged in the business of installing an MLTS as:

A person that configures the MLTS or performs other tasks involved in getting the system ready to operate. These tasks may include, but are not limited to, establishing the dialing pattern for emergency calls, determining how calls will route to the Public Switched Telephone Network (PSTN), and determining where the MLTS will interface with the PSTN. These tasks are performed when the system is initially installed, but they may also be performed on a more or less regular basis by the MLTS operator as the communications needs of the enterprise change. The MLTS installer may be the MLTS manager or a third party acting on behalf of the manager.203

 

[dhoppy]

He/she is not engaged in "the business of installing," "the business of managing," or the "business of operating." He/she is engaged in the business of being a lawyer. The rest of it doesn't apply to him/her. (I may have previously incorrectly assumed phpinphan is male, forgive me if I was wrong).

 

[Samot]

He/she is not engaged in "the business of installing," "the business of managing," or the "business of operating." He/she is engaged in the business of being a lawyer. The rest of it doesn't apply to him/her. (I may have previously incorrectly assumed phpinphan is male, forgive me if I was wrong).

OK, I'm not going to try to convince you of anything. Some of us may have hired lawyers that specialize in telecom law and had them review the law to ensure it was being interpreted right.

If the claim is "I'm not in the business of installing/managing MLTS/PBX systems" then installing and managing a PBX for a business should be the last thing you do.

 

[ext-104]

This reminds me of the amy coney barrett confirmation hearings.

 

[krzykat]

If you are an admin of a PBX, one or many, just for your office or not. It applies to you.

There is a caveat ... When the system was put into service. If you are running a system from 5 years ago, I don' think this applies to you. I only play a lawyer on TV

Compliance date (MLTS direct dialing and notification) and Exemption for Legacy MLTSsort by: Kari’s Law and the Commission’s rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020. (See 47 CFR § 9.17(b).)

All other MLTS (i.e., systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020) must meet the following compliance date:

 

[Samot]

There is a caveat ... When the system was put into service. If you are running a system from 5 years ago, I don' think this applies to you. I only play a lawyer on TV

Compliance date (MLTS direct dialing and notification) and Exemption for Legacy MLTSsort by: Kari’s Law and the Commission’s rules are forward-looking and do not apply with respect to any MLTS that is manufactured, imported, offered for first sale or lease, first sold or leased, or installed on or before February 16, 2020. (See 47 CFR § 9.17(b).)

All other MLTS (i.e., systems manufactured, imported, offered for first sale or lease, first sold or leased, or installed after February 16, 2020) must meet the following compliance date:

You are correct in that but you need to scroll down on that page to where it has the MLTS FAQ link: https://www.fcc.gov/files/mltsfaqspdf

Because in there you will find this:

Q. What happens if an MLTS that was manufactured before Feb. 17, 2020 is installed or upgraded after Feb. 17, 2020?

A. An MLTS that was manufactured before February 17, 2020 but is first installed on or after February 17, 2020 would be covered by Kari’s Law. If the MLTS was installed before February 17, 2020 but is upgraded on or after February 17, 2020, it could be subject to Kari’s Law depending on the magnitude of the upgrade. While not all upgrades trigger coverage by Kari’s Law, we generally consider upgrades to core MLTS software or hardware functions to be of sufficient magnitude to bring an MLTS within the scope of the statute and rules.

So FreePBX released an update earlier this year to support Kari's Law which so that means FreePBX systems fall under the law. In regards to something like a hardware based PBX (Matrix, Mitel, etc) if it is a significant purchase to update then it is exempt.

Now what's really going to be the kicker is Section 506 of Ray Baum's Act which covers the Dispatchable Location and that isn't going to have exemptions. So in some cases it will require PBX's to be replaced and thus make them have to comply to Kari's Law (new PBX install). It's looking like that is Feb 6th 2021 for fixed devices and Feb 6th 2022 for non-fixed. However, there are things being worked out still for information collection and recordkeeping requirements. The Office of Management and Budget hasn't approved it yet. Until they approve it and it goes in the Federal Register compliance won't be enforced for Dispatchable Locations.

 

[Eliad]

IncrediblePBX already handles notifications on the outbound route screens for emergency calls. It can even announce via the paging system.

View attachment 3064

It looks this feature could work for 911 call notification. The only issue I see is when you use same trunk for regular calls too. How can you make the notification work for only 911 calls?
I did enable 911 calls for all my trunk providers although in actuality I use only one trunk provider for the 911 calls. I figured about $1 a month per DID is far less than the penalty for calling 911 through a trunk which is not enabled for 911

 

[kenn10]

It looks this feature could work for 911 call notification. The only issue I see is when you use same trunk for regular calls too. How can you make the notification work for only 911 calls?

The notification is by OUTBOUND ROUTE, not by TRUNK. You have a separate route for 911 or whatever emergency numbers you want.

 

[Eliad]

The notification is by OUTBOUND ROUTE, not by TRUNK. You have a separate route for 911 or whatever emergency numbers you want.View attachment 3066

To make it clear to me. I create an Emergency route and for the dial pattern will be just 911 and then I choose the trunk 911 enabled. Then on this outbound I will enable notification. Also make sure this is route is at the top. Is this all correct?

 

[kenn10]

That is correct. If you had multiple locations, you could have separate outbound 911 routes that were restricted by extension number or extension ranges and each route could have different notification options.