Copper Going Away Presents Another Challenge

The Society of Communications Technology Consultants' Ted Mallires did a fine job of highlighting the impact the retirement of telco copper services is having on organizations in "Got PRI? You May Warrant a Change in Architecture." With the decommissioning of plain old telephone services (POTS) , primary rate interfaces (PRI), and other copper services taking place now and going forward, let’s discuss this subject with a twist as it applies to enterprise 911.

 

Compliance with Kari’s Law and RAY BAUM'S Act is still front and center for enterprises utilizing multiline telephone systems (MLTS). In general terms, E911 or NG911 in an MLTS environment requires finding the 911 caller, routing the call to the proper local PSAP/ECC, and notifying responders of the location of the calling party. (Find-Route-Notify).

 

With AT&T, Verizon, Lumen, and countless others retiring copper facilities and or raising prices for the same so dramatically, owners and operators of voice core multiline telephone systems (MLTS) are now facing the necessity of changing voice core configurations. As I wrote earlier, "The mantra of 911 calling in the enterprise has and will always be: find, route, and notify."

 

Let’s look at the different scenario configurations which will be impacted with the retirement of copper lines.

 

The most rudimentary form of 911 – which is also no longer compliant with FCC regulations – was POTS presenting the billing address location of a PBX and only that location. This configuration should be retired anyway right away. But with the carriers decommissioning /retiring POTs, the retirement will likely require an inevitable upgrade/reconfiguration of the PBX.

 

POTS have also been utilized as power and, or network fail-over facilities to deliver 911 calls from remote shelf sites networked in a corporate private network for years. Cisco Unified Communications Manager (CUCM) Survivable Remote Site Telephony (SRSTs) have been configured to utilize POTs as a fail-over for years. When the POTS lines go away, an alternative will be required for the failover configuration. Solutions such as Granite’s EPIK service, interfaces/integrates with the SRST to send 911 calls over LTE with proper routing instructions and dispatchable location to proper local public safety answering point (PSAP). You can read a first-person review of the Granite EPIK Edge appliance here.

 

Multiline telephone systems which utilize legacy private switch/automatic location identification (PS/ALI) services with local routing via primary rate interface (PRI) facilities could already be out of compliance with the FCC’s RAY BAUM'S Act for voice devices. Legacy PS/ALI inherently exhibits a delay in the registration of voice endpoints when moved, added, changed, or deleted on the PBX and updated into the telco PS/ALI database. The PS/ALI databases are generally updated within 24 hours. However, if errors occur with the database update transaction, the update could take days to complete. The FCC regulations require near-real-time interior dispatchable location updating. This location-update deficiency is especially notable with non-fixed voice devices of nomadic or work-from-home voice consumers.

 

A variety of configurations will replace the PRIs. The new non-copper configurations will require any MLTS owner/operator to a VoIP Positioning Carrier (VPC) as they move to a VoIP SIP facility connected to an existing voice core or as part of the migration to a cloud-based phone service. Any new facilities or core voice functionality must be E911/NG911 compliant.

 

Enterprises can utilize a PBX with PRI to call forward emergency 911 calls to a VPC media gateway for routing purposes.

 

In this present-day configuration, the enterprise’s voice core and its ability to inherently, or via third party IP discovery software, “discover” each voice device’s interior dispatchable location. The VoIP PRI with VPC configuration is very likely able to comply with the FCC’s Kari’s Law and RAY BAUM'S Act.

 

Keeping in mind the mantra of “Find-Route-Notify,” an enterprise already has “Find and Notify” via the PBX's inherent ability or the addition of a third-party software to find "discover" and to notify via emergency onsite notification. But the “Route” goes away with the PRI decommissioning. It’s an easy fix with SIP and a handoff to the VPC service provider.

 

So, all enterprise MLTS owners/operators who still utilize POTS and PRI copper facilities, take note! Plan for the inevitable decommissioning of all copper facilities in the future. And when you replace them, consider 911 and the configuration changes you will need to perform to comply with FCC regulations.

 

Note: Vita Safety Partners and their members are subject matter experts (SMEs) in enterprise 911 and the emergency response ecosystem. We are not attorneys. The information presented is our collect opinion and should not be construed as legal advice.

If you have questions or comments about the information presented, please reach out to Bill at Vita Safety Partners.

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Bill is writing on behalf of the SCTC, a premier professional organization for independent consultants. SCTC consultant members are leaders in the industry, able to provide best of breed professional services in a wide array of technologies. Every consultant member commits annually to a strict Code of Ethics, ensuring they work for the client benefit only and do not receive financial compensation from vendors and service providers.