Kari's Law and other telecom changes
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There is a mostly good conversation over on the FreePBX community about the upcoming changes to various things in the telephone industry.
Has anyone else been looking at the upcoming changes?
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Technically, according to the actual wording of the law: "Kari’s Law applies to multi-line telephone systems (MLTS), which are telephone systems that serve consumers in environments such as office buildings, campuses, and hotels."
That, in theory, means that:
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Modern VoIP delivered systems are not covered as they are not multi-line. They are generally single line (SIP channel.) There is no official line mechanism in SIP, but a single trunk is the closest analog and a standard system has only one. If there is a second, it is normally failover, not concurrent. Or in our case, international only. So in theory, SIP carries are not covered by the law as the wording carefully limits coverage to legacy carriers with "lines".
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Mobile and end user stations that are not in an environment like an office building, campus, or hotel would not be covered. Things like home offices or people in their car would be clearly "unlike" those things, so the hardest of proposed cases would not be covered by the law (and shouldn't be, that would be dumb.)
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Quoted...
What the NPRM Would Do:
• Propose to apply dispatchable location requirements to MLTS, fixed telephone service, interconnected
Voice over Internet Protocol (VoIP) services, and Telecommunications Relay Service (TRS). It seeks
comment on the technical feasibility of providing dispatchable location and the benefits and costs
associated with different technical solutions. -
I quoted the NPRM because it calls out specifically that VoIP services are not MLTS. So the wording used in conjunction with Kari's Law, in the same paperwork, clearly excludes VoIP in that singular document.
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Now according to this somewhat random source... https://www.cloudcommunications.com/client-advisory-fcc-imposes-new-obligations-on-multi-line-telephone-systems-and-other-providers-including-non-interconnected-voip-to-strengthen-access-to-e911-emergency-services/
They claim that the FCC disagrees with the wording of the law and considered MLTS to include all kinds of things that have nothing to do with the term, which legally seems to imply harmful intent in using the term to mislead as it is clearly limiting and not a term that would ever apply to modern systems, but: "The FCC further clarifies that the statutory definition of MLTS is sufficiently broad to cover the full range of enterprise communications systems, including legacy TDM MLTS, hybrid MLTS and IP MLTS systems and software, as well as all endpoints supported by MLTS including mobile and smart devices, softphone clients, over-the-top (OTT) applications, and outbound-only calling services. Outbound-only calling systems, including VoIP, also qualify as MLTS."
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Same source claims that there is an exception for systems that don't connect to the PSTN: "However, purely internal systems that do not connect to the Public Switched Telephone Network (PSTN) are exempt, as are individual components of the system. Accordingly, “manufacturers, importers, sellers, or lessors of individual MLTS components are not subject to the Commission’s MLTS rules to the extent that they manufacture, import, sell, or lease such components without the other components necessary for the system to function as an MLTS.”"
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If they intended to use it this way, the law should have simply been written that multi-user, PSTN connected, stationary location systems should implement.... blah blah. But they didn't, why?
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@scottalanmiller said in Kari's Law and other telecom changes:
law ....... simply .............. written
HAHAHAHAAHAHAHAHA
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@JaredBusch said in Kari's Law and other telecom changes:
@scottalanmiller said in Kari's Law and other telecom changes:
law ....... simply .............. written
HAHAHAHAAHAHAHAHA
LOL - yeah, pretty much this.
