Ray Baum's act and all-softphone deployments
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?
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally. https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon * On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply. Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
The softphone app we're using (Acrobits Cloud Softphone). If you attempt to dial 911 via the app. It'll open the phones non-voip cellular dialer with 911 pre-typed. It actively doesn't allow you to call 911 via the app. Perhaps your apps are the same. On Mon, Sep 27, 2021 at 3:00 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply.
Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access
On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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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We also use Acrobits and can confirm that works. I still have to test what it does on an ipad. Aryn Nakaoka anakaoka at trinet-hi.com Direct: 808.356.2901 518 Holokahana Lane Honolulu, Hi 96817 AlohaTone Mobile: https://youtu.be/PdUyuf0hTYY A Better Solution https://www.trinet-hi.com/abettersolution.pdf <https://www.trinet-hi.com/abettersolution.pdf> Aloha Tone PBX https://www.youtube.com/watch?v=96YWPY9wCeU CONFIDENTIALITY NOTICE: The information contained in this email and any attachments may be privileged, confidential and protected from disclosure. Any disclosure, distribution or copying of this email or any attachments by persons or entities other than the intended recipient is prohibited. If you have received this email in error, please notify the sender immediately by replying to the message and deleting this email and any attachments from your system. Thank you for your cooperation. On Mon, Sep 27, 2021 at 9:18 AM Nick Olsen <nick at 141networks.com> wrote:
The softphone app we're using (Acrobits Cloud Softphone). If you attempt to dial 911 via the app. It'll open the phones non-voip cellular dialer with 911 pre-typed. It actively doesn't allow you to call 911 via the app. Perhaps your apps are the same.
On Mon, Sep 27, 2021 at 3:00 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply.
Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access
On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks. I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task. On Mon, Sep 27, 2021 at 12:11 PM Nick Olsen <nick at 141networks.com> wrote:
The softphone app we're using (Acrobits Cloud Softphone). If you attempt to dial 911 via the app. It'll open the phones non-voip cellular dialer with 911 pre-typed. It actively doesn't allow you to call 911 via the app. Perhaps your apps are the same.
On Mon, Sep 27, 2021 at 3:00 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply.
Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access
On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
I wonder what ios15's new hide my ip feature will do to this. Fred Posner | palner.com Matrix: @fred:matrix.lod.com o: +1 (212) 937-7844 On 9/27/21 3:35 PM, Alex Balashov via VoiceOps wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
Ah, great, yet another challenge here. So even the city can't be determined in that case. On Mon, Sep 27, 2021 at 12:46 PM Fred Posner via VoiceOps < voiceops at voiceops.org> wrote:
I wonder what ios15's new hide my ip feature will do to this.
Fred Posner | palner.com Matrix: @fred:matrix.lod.com o: +1 (212) 937-7844
On 9/27/21 3:35 PM, Alex Balashov via VoiceOps wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
The NG911 researchers really don't want to look at the source IP of the registration: they want to get the best available location data from the mobile device (including GPS and tower-assisted data) and send that to the PSAP. I'm hoping we'll someday rfc6442 finally put to work in VoIP applications to fetch the location from the operating system and then send it with the 911 call.
On Sep 27, 2021, at 3:41 PM, Fred Posner via VoiceOps <voiceops at voiceops.org> wrote:
I wonder what ios15's new hide my ip feature will do to this.
Fred Posner | palner.com Matrix: @fred:matrix.lod.com o: +1 (212) 937-7844
On 9/27/21 3:35 PM, Alex Balashov via VoiceOps wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
It used to be, then the whole Ray Baum thing, and now it's not. Short story: 911 call failed to identify the specific floor/office, person died. Now you have to provide enough info for a first responder to reach a person without help, which also means opening main doors if needed. There's simply no way that a laptop will give that specificity. Will it be sufficient to say that they are near the AP on the third floor southwest corner? The letter of the law seems to say "no." On Mon, Sep 27, 2021 at 12:40 PM Alex Balashov via VoiceOps < voiceops at voiceops.org> wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC
Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
And how do the cell phone operators know what floor you?re on? ? Sent from mobile, with due apologies for brevity and errors.
On Sep 27, 2021, at 3:49 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
? It used to be, then the whole Ray Baum thing, and now it's not. Short story: 911 call failed to identify the specific floor/office, person died. Now you have to provide enough info for a first responder to reach a person without help, which also means opening main doors if needed. There's simply no way that a laptop will give that specificity. Will it be sufficient to say that they are near the AP on the third floor southwest corner? The letter of the law seems to say "no."
On Mon, Sep 27, 2021 at 12:40 PM Alex Balashov via VoiceOps <voiceops at voiceops.org> wrote: I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC
Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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They probably don't, and I don't think they are covered by the same law/requirements. Also, they have far more schills(COUGH) I mean lobbyists in congress. FLOOR could be determined by AP lists, probably. Maybe. Specific office seems impossible currently. On Mon, Sep 27, 2021 at 1:05 PM Alex Balashov via VoiceOps < voiceops at voiceops.org> wrote:
And how do the cell phone operators know what floor you?re on?
? Sent from mobile, with due apologies for brevity and errors.
On Sep 27, 2021, at 3:49 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
? It used to be, then the whole Ray Baum thing, and now it's not. Short story: 911 call failed to identify the specific floor/office, person died. Now you have to provide enough info for a first responder to reach a person without help, which also means opening main doors if needed. There's simply no way that a laptop will give that specificity. Will it be sufficient to say that they are near the AP on the third floor southwest corner? The letter of the law seems to say "no."
On Mon, Sep 27, 2021 at 12:40 PM Alex Balashov via VoiceOps < voiceops at voiceops.org> wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC
Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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In the top 25 cellular market areas, nationwide cell phone providers are already required to provide Z-axis (elevation) data within 3 meters for 80% of calls [for compatible devices]. The requirements increase each year; by 2026, all cellular providers are required to provide z-axis precision for dispatchable location of +/- 3 meters everywhere in the US. This is all in addition to providing +/- 50 meter horizontal (x, y axis, also known as latitude and longitude) precision for 911 calls. https://www.fcc.gov/public-safety-and-homeland-security/policy-and-licensing... 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 4:07 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
They probably don't, and I don't think they are covered by the same law/requirements. Also, they have far more schills(COUGH) I mean lobbyists in congress.
FLOOR could be determined by AP lists, probably. Maybe. Specific office seems impossible currently.
On Mon, Sep 27, 2021 at 1:05 PM Alex Balashov via VoiceOps <voiceops at voiceops.org <mailto:voiceops at voiceops.org>> wrote: And how do the cell phone operators know what floor you?re on?
? Sent from mobile, with due apologies for brevity and errors.
On Sep 27, 2021, at 3:49 PM, Carlos Alvarez <caalvarez at gmail.com <mailto:caalvarez at gmail.com>> wrote:
? It used to be, then the whole Ray Baum thing, and now it's not. Short story: 911 call failed to identify the specific floor/office, person died. Now you have to provide enough info for a first responder to reach a person without help, which also means opening main doors if needed. There's simply no way that a laptop will give that specificity. Will it be sufficient to say that they are near the AP on the third floor southwest corner? The letter of the law seems to say "no."
On Mon, Sep 27, 2021 at 12:40 PM Alex Balashov via VoiceOps <voiceops at voiceops.org <mailto:voiceops at voiceops.org>> wrote: I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com <mailto:caalvarez at gmail.com>> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC
Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/ <http://www.evaristesys.com/>, http://www.csrpswitch.com/ <http://www.csrpswitch.com/>
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org <mailto:VoiceOps at voiceops.org> https://puck.nether.net/mailman/listinfo/voiceops <https://puck.nether.net/mailman/listinfo/voiceops> _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org <mailto:VoiceOps at voiceops.org> https://puck.nether.net/mailman/listinfo/voiceops <https://puck.nether.net/mailman/listinfo/voiceops>
VoiceOps mailing list VoiceOps at voiceops.org <mailto:VoiceOps at voiceops.org> https://puck.nether.net/mailman/listinfo/voiceops <https://puck.nether.net/mailman/listinfo/voiceops> _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
Three meters is three floors of resolution, depending on whether the person is standing or laying on the ground. On Mon, Sep 27, 2021 at 1:34 PM Mark Lindsey <lindsey at e-c-group.com> wrote:
In the top 25 cellular market areas, nationwide cell phone providers are already required to provide Z-axis (elevation) data within 3 meters for 80% of calls [for compatible devices]. The requirements increase each year; by 2026, *all* cellular providers are required to provide z-axis precision for dispatchable location of +/- 3 meters everywhere in the US.
This is all in addition to providing +/- 50 meter horizontal (x, y axis, also known as latitude and longitude) precision for 911 calls.
https://www.fcc.gov/public-safety-and-homeland-security/policy-and-licensing...
*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 4:07 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
They probably don't, and I don't think they are covered by the same law/requirements. Also, they have far more schills(COUGH) I mean lobbyists in congress.
FLOOR could be determined by AP lists, probably. Maybe. Specific office seems impossible currently.
On Mon, Sep 27, 2021 at 1:05 PM Alex Balashov via VoiceOps < voiceops at voiceops.org> wrote:
And how do the cell phone operators know what floor you?re on?
? Sent from mobile, with due apologies for brevity and errors.
On Sep 27, 2021, at 3:49 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
? It used to be, then the whole Ray Baum thing, and now it's not. Short story: 911 call failed to identify the specific floor/office, person died. Now you have to provide enough info for a first responder to reach a person without help, which also means opening main doors if needed. There's simply no way that a laptop will give that specificity. Will it be sufficient to say that they are near the AP on the third floor southwest corner? The letter of the law seems to say "no."
On Mon, Sep 27, 2021 at 12:40 PM Alex Balashov via VoiceOps < voiceops at voiceops.org> wrote:
I wonder if doing GeoIP via a commercial database like MaxMind?and we all know how perfect a location mechanism that is?could be construed as a sufficient ?best effort? in this case.
On Sep 27, 2021, at 3:28 PM, Carlos Alvarez <caalvarez at gmail.com> wrote:
Ours doesn't, but that's a good idea to share with the vendor. But in most cases, people are using the softphone on a laptop and there's no native phone app, nor a GPS, nor any other location info other than proximate wi-fi networks.
I can see no feasible way to meet the letter of the law, and hate to be depending on the good graces of a bureaucrat to know that it's an impossible task.
-- Alex Balashov | Principal | Evariste Systems LLC
Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
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The technology has some limits, yeah. After all, it was designed to keep Armor and Infantry commanders from getting lost and for guiding cruise missiles through windows from 800 miles away. On Mon, Sep 27, 2021 at 1:41 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
Three meters is three floors of resolution, depending on whether the person is standing or laying on the ground.
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On 9/27/21 13:34, Mark Lindsey via VoiceOps wrote:
In the top 25 cellular market areas, nationwide cell phone providers are already required to provide Z-axis (elevation) data within 3 meters for 80% of calls [for compatible devices]. ?The requirements increase each year; by 2026, /all/?cellular providers are required to provide z-axis precision for dispatchable location of +/- 3 meters everywhere in the US.
This is all in addition to providing +/- 50 meter horizontal (x, y axis, also known as latitude and longitude) precision for 911 calls.
Interesting as elevation accuracy for GPS is worse than lat/long. So when first responders get dispatched to 34.2270545 degrees north, 117.6422397 degrees west, 538 meters AMSL, where do they go? (I just randomly typed those numbers so if it's under a mountain don't blame me.) Considering just the x/y axis, determining the right room or suite in a large single-story office building, factory or warehouse is going to be a challenge. In a huge multi-story high-rise with poor to no internal GPS reception it's going to be nearly impossible. Especially if it's in the middle of a bunch of other high-rise buildings with corresponding multipath and reflections. -- Jay Hennigan - jay at west.net Network Engineering - CCIE #7880 503 897-8550 - WB6RDV
In my experience, they are never dispatched to GPS coordinates. The PSAP gets the coordinates automatically pulled up in their mapping system showing the closest address. The only time I've ever exchanged raw GPS coordinates was in ~2003 when the Garmin was out of batteries, and the spare was missing from a rescue vehicle and we were trying to tell a helicopter where we were. I had 1/16th of a bar of service and managed to hit the neighboring 911 center. I asked them for my coordinates. They had to go to some special screen to give them to me, and then I relayed them to Life Flight. They were off by about 500 feet, but there was only one clearing in a sea of trees, and we had flares. -A On Mon, Sep 27, 2021 at 2:18 PM Jay Hennigan via VoiceOps < voiceops at voiceops.org> wrote:
On 9/27/21 13:34, Mark Lindsey via VoiceOps wrote:
In the top 25 cellular market areas, nationwide cell phone providers are already required to provide Z-axis (elevation) data within 3 meters for 80% of calls [for compatible devices]. The requirements increase each year; by 2026, /all/ cellular providers are required to provide z-axis precision for dispatchable location of +/- 3 meters everywhere in the US.
This is all in addition to providing +/- 50 meter horizontal (x, y axis, also known as latitude and longitude) precision for 911 calls.
Interesting as elevation accuracy for GPS is worse than lat/long.
So when first responders get dispatched to 34.2270545 degrees north, 117.6422397 degrees west, 538 meters AMSL, where do they go? (I just randomly typed those numbers so if it's under a mountain don't blame me.)
Considering just the x/y axis, determining the right room or suite in a large single-story office building, factory or warehouse is going to be a challenge. In a huge multi-story high-rise with poor to no internal GPS reception it's going to be nearly impossible. Especially if it's in the middle of a bunch of other high-rise buildings with corresponding multipath and reflections.
-- Jay Hennigan - jay at west.net Network Engineering - CCIE #7880 503 897-8550 - WB6RDV _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
Yeah, the intersection of the law and voice technology is interesting.. Even though RC does allow end users to update their location relatively easily, I notice they still have this disclaimer that makes it near pointless- "It may take up to several hours for the address update to take effect" I am not a lawyer, but it seems to me if your TOS says something like, "you need to tell us in writing where you are if there is to be any chance of us routing your 911 call to the right place." that should be defensible. What other option is there? Someday I could imagine voip providers held to the same or similar standard of mobile providers. Some political will and technology improvement could make it feasible in the future for a softphone on any device with location services to share that info for e911 purposes. *Brandon * On Mon, Sep 27, 2021 at 12:01 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply.
Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access
On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
We would need GPS capabilities on our Polycom / Softphones if we ever need to match cellular e911. Not only that but we need to share liability with internet connectivity... cell phone guys are vertically integrated. Aryn Nakaoka anakaoka at trinet-hi.com Direct: 808.356.2901 518 Holokahana Lane Honolulu, Hi 96817 AlohaTone Mobile: https://youtu.be/PdUyuf0hTYY A Better Solution https://www.trinet-hi.com/abettersolution.pdf <https://www.trinet-hi.com/abettersolution.pdf> Aloha Tone PBX https://www.youtube.com/watch?v=96YWPY9wCeU CONFIDENTIALITY NOTICE: The information contained in this email and any attachments may be privileged, confidential and protected from disclosure. Any disclosure, distribution or copying of this email or any attachments by persons or entities other than the intended recipient is prohibited. If you have received this email in error, please notify the sender immediately by replying to the message and deleting this email and any attachments from your system. Thank you for your cooperation. On Mon, Sep 27, 2021 at 9:22 AM Brandon Svec via VoiceOps < voiceops at voiceops.org> wrote:
Yeah, the intersection of the law and voice technology is interesting..
Even though RC does allow end users to update their location relatively easily, I notice they still have this disclaimer that makes it near pointless-
"It may take up to several hours for the address update to take effect"
I am not a lawyer, but it seems to me if your TOS says something like, "you need to tell us in writing where you are if there is to be any chance of us routing your 911 call to the right place." that should be defensible. What other option is there?
Someday I could imagine voip providers held to the same or similar standard of mobile providers. Some political will and technology improvement could make it feasible in the future for a softphone on any device with location services to share that info for e911 purposes.
*Brandon *
On Mon, Sep 27, 2021 at 12:01 PM Carlos Alvarez <caalvarez at gmail.com> wrote:
We don't have a web portal for customers to do this, so it probably can't be our position. We do have a ToS that says customers have to notify us by email or support ticket if they move. I don't believe anyone ever has. I wonder if that could still apply.
Separately, I find this ridiculous. WTF? Can't use Wi-Fi for calls? with respect to only the RingCentral Mobile Application, if you do not have mobile service, as the RingCentral Mobile Application cannot send emergency calls over Wi-Fi access
On Mon, Sep 27, 2021 at 11:47 AM Brandon Svec <bsvec at teamonesolutions.com> wrote:
I *think* this sums it up. RingCentral is big if not the biggest and I say that only because they undoubtably have a large legal team and got this right. They basically have a disclaimer that makes it the responsibility of the end user or customer administrator to update their location whenever they move around. Silly, I know.. but I think this is a defensible position to take legally.
https://www.ringcentral.com/legal/last-update-October-15-2019/emergency-serv... *Brandon *
On Mon, Sep 27, 2021 at 11:37 AM 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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
On Sep 27, 2021, at 3:28 PM, Aryn Nakaoka 808.356.2901 via VoiceOps <voiceops at voiceops.org> wrote:
Not only that but we need to share liability with internet connectivity... cell phone guys are vertically integrated.
Boy howdy do we. And probably not just for the connection?s reliability, but other aspects of the technology. For instance: I often find myself ?trapped? by captive portals from WiFi networks my iPhone magically ?knows? from prior use (in the given location or elsewhere) at the wrong moments. A good example are the ubiquitous and obnoxious ?xfinity? networks projected by a great many WAP+cable modem CPE devices. Not merely once, I have had to make an urgent call (granted, not 911) while outside, standing underneath or adjacent to a business or residence which is throwing off one of these ?xfinity? WiFi things, effectively cutting me off from the Internet until my iPhone realises it, which takes some time, and I?m transiently walking into the WiFi range. The call wouldn?t work until I angrily disabled WiFi so the cell network could be expeditiously used. The fact that stuff like that isn?t considered really gets me about these laws. ? Alex -- Alex Balashov | Principal | Evariste Systems LLC Tel: +1-706-510-6800 / +1-800-250-5920 (toll-free) Web: http://www.evaristesys.com/, http://www.csrpswitch.com/
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?
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
participants (10)
-
aaron＠heyaaron.com -
abalashov＠evaristesys.com -
anakaoka＠trinet-hi.com -
bsvec＠teamonesolutions.com -
caalvarez＠gmail.com -
fred＠palner.com -
jay＠west.net -
jeffshultz＠sctcweb.com -
lindsey＠e-c-group.com -
nick＠141networks.com