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It Takes One

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  critique policy telecom

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On September 16, 2019, a bulletin was sent out to Panasonic customers, informing them that the venerable KX-TA824 PBX was going to be discontinued later that year. As of this writing, that time has already passed.

At first, I was surprised. The Panasonic KX-TA824 is truly a work of art. It's a compact, analog, partially electromechanical but mainly electronic Private Automatic Branch Exchange. With 3 trunks and 8 extensions out of the box, expandable to 24 lines, it's enough to get most people started on their never-ending journey of telephone collecting and telephone switching. Or (more boringly), serve as a home or small office phone system.

The KX-TA824 was my first PBX, and even at $99 used, it's a real bargain for what you get. It's much smaller than the 308 EASAPHONE PBX by Panasonic, which does nothing more (actually, a little bit less), but takes up almost twice as much space. In contrast, the KX-TA824 is roughly the size of a small desktop computer. It sat beneath my desk for several years, connecting all of my phone equipment together.

In the world of VoIP, Asterisk, and digital enterprise phone systems, it might be easy to lose sight of just how amazing the KX-TA824 is. Like many other Panasonic PBXs, pulse-to-tone conversion is automatic and silent, allowing rotary phone users to navigate IVRs with almost no friction at all (sans the * and # keys). With 5 REN per line, ringing real bell ringers on multiple telephone sets has never been a challenge for this small guy. The KX-TA824 brought advanced calling features to the household and small office, rivaling the features offered by standard central office switches: dial a busy extension? No problem. Dial 6, hang up, and the PBX will call you back automatically with a special ring when that line is free. Want to make a 3-way call? The KX-TA824 makes it easy peasy. Need to make a page? Just dial the paging code. Hey, was that the doorbell? No problem! The PBX will let you control your doorphone, too.

As a glance at the hundreds of pages that comprise the KX-TA824 manuals might suggest, most people don't come close to using half the features provided by the KX-TA824, but they're there for those who need them. And with hundreds of programming options, the PBX can be customized to exactly suit your needs. Controlling which extensions ring on which incoming calls at certain times of day is just one of the many hundreds of possible settings that can be tweaked.

And all this for $99.

Until I learned that the KX-TA824 had just been recently officially discontinued, I assumed that it already had been many years ago. After all, the demand for analog, direct-control PBX equipment in 2020 is, well, probably very low, save amongst telephone collectors and households desiring a compact but sophisticated telephone system. Given that such high-quality products are quite rare in a world where cheap, plastic goods are manufactured in China for worldwide distribution, it seemed unthinkable that the KX-TA824 might still actually be available, new.

Of course, all that has changed now. Going forward, the used market will not only be the most popular way to obtain these marvels — it will be the only way. They'll probably still be readily available for years to come on sites like eBay. What makes this a real tragedy is that it didn't have to be this way. Panasonic, in their bulletin, came out and straight out explained why they were forced to make this choice:

This bulletin is to announce the end of sale of the KX-TA824PK Analog Main Unit and Bundle with (3) KX-T7731-B 1-Line Analog Phones on November 1, 2019.
The FCC recently announced regulations enacted as part of the Kari’s Law & Ray Baum’s Act statutes. We are working to understand any changes needed to the PBX systems to comply with these regulations, including changes to system software or hardware. For example, the new Emergency Alerts features included in the previously announced launch of the KX-NS v8 family IP Communications Server system software upgrade was driven by compliance with these regulations.
Kari’s Law especially requires that any multi-line telephone system installed after February 16, 2020 enables users to dial 911 directly without having to dial a prefix to reach an outside line. We were notified by the FCC in 2016 of this regulation and made changes to all our PBX systems for sale at that time to comply with that regulation, including the TDA, TDE, NCP, NS and NSX series. It did not include the TA824 cabinet as those changes could not be made to that PBX.
Since the TA824 still cannot support the direct-dial 911 regulation, and we are approaching the February 2020 customer-installation deadline, we have made the decision to discontinue the TA824 before the law takes effect

The real blame doesn't lie with Panasonic. After all, what could they do? Ruin a perfectly good PBX by modifying it? That would have been no good, either.

This isn't the first time Kari's Law has been mentioned on this blog. The Ray Baum Act is an equally stupid and frivolous bill (for instance, it stresses the importance of using Wi-Fi to connect with 911 dispatchers, among other things). The only reference to "multi-line telephone systems" comes in Section 506, where they are required to provide the "dispatchable location" on 9-1-1 calls. Or rather, a proceeding is required to determine if requiring that is a good idea. This seems like a moot point, in any case. Panasonic PBXs are designed for use on loop start, not ground start, lines. The phone company itself will have the location of the address where the PBX is installed, and it can continue providing that information to 9-1-1, as it has for decades already. There's no reason to rely on customers to provide their own addresses.

More than two years ago, we denounced Kari's Law as the kind of thing that happens when people who don't understand telecommunications try to pretend that they do. Today, we lament the fact that Kari's Law, primarily, is responsible for forcing Panasonic to end the sale of the excellent KX-TA824. Direct-dialing 911 (without a prefix) is an unnecessary and unreasonable requirement for not just the KX-TA824 but any multi-line telephone system. By definition, it necessarily precludes direct-control PBXs from being sold. Direct-control in the sense that when you dial "9", the PBX gives you an outside line, lets the central office take over, and gets the heck out of your way. It requires minimal intelligence (really none at all), and is preferable for being able to directly control trunks. A PBX programmer need not specify every possible dialing pattern that is acceptable for dialing on a CO line. Instead, he can just rely on the central office. It's a very efficient way of allowing trunking.

But, because of Kari's Law, a long legacy of Panasonic PBXs are now joining the ranks of incandescent light bulbs and low-efficiency toilets — perfect first-class products that, due to bureaucracy, will flourish on the used and black markets.

The problem is not that 9-1-1 cannot be direct dialed. That never was a problem, until an idiotic kid who didn't know how phone systems worked tried doing just that. Just because a kid screws up and somebody dies because of that, no matter how tragic, doesn't mean that catering to a generation of people who don't know how phone systems work is pragmatic or wise. The real problem is simple: kids today, by and large, do not know how to use the phone. I know it sounds stupid, but there's no shortage of YouTube videos of kids who don't know how to use telephones. Having grown up in an era of area code overuse and abuse, kids do not know when to use area codes and when not to. The spirit of telephone education, which the Bell System was very diplomatic about, is no longer. Kids today are left to their own devices, and parents likely do an inadequate job explaining proper telephone procedures.

The fact that you need to dial "9" on a multi-line phone system is not much of a secret, either. It's more or less part of modern popular telephone culture — schools and businesses almost universally require dialing 9 for an outside line. Oftentimes, the second dial tone you get is fake, but the procedure is the same.

Perhaps the FCC should have considering making the phone number "11" just redirect to "911". That way, if you dial 9 from a PBX and then 11, erroneously, you'd still get to a dispatcher. Oh, wait, there might be a small problem with that anyone who picked up and hung up his telephone twice rapidly would inadvertently summon a police car to his house. Oh, and 11 is how you start off dialing a vertical service code from a single-line rotary phone, so we might need to introduce a timeout there. So that means delayed and erroneous 911 calls. Okay, maybe never mind!

The FCC is one of America's most moronic government agencies, and it's easy to see why. They're run by industry cronies, they don't know what they're doing, and they're run by incompetent morons, to put it simply. They continue to deny decades of independent science showing harm from wireless technology, and they continue to turn a blind eye to the evidence, instead choosing to roll full steam ahead with the 5G rollout, while wiser European countries are banning or slowing the rollout instead. They continue to give local exchange carriers the green light to abandon local phone services, while pushing dangerous and unreliable wireless technologies instead. More recently, the 988 suicide hotline number has made headlines in yet another gross display of FCC incompetence. We already have 211 to serve this exact purpose, and rather than requiring that 211 calls be handled by humans, rather than robots, the FCC instead decides to screw with everyone's numbering plans. Calls to 988 will involve a timeout, let's be very clear about that. There's no way of telling whether you're dialing 988 or a 988-XXXX phone number. 211, on the contrary, is a reserved N11 code that is universally supported, well known, and very easy to dial. In fact, 211 is the shortest phone number that you can dial from any phone line, even shorter than Operator, at a whopping 4 pulses for the entire number (2+1+1) compared to Operator (10 pulses) or 988, which is a whopping (9+8+8) 25 pulses! Who knows how many people will commit suicide while waiting for their 9-8-8 call to go through. For some reason, the FCC doesn't seem to understand just how bad of an idea this is.

The FCC killed off a perfectly good PBX series for no good reason, and now it wants to fudge with America's numbering plan. One thing is perfectly clear: it's not the FCC that's doing the regulating — it's the FCC that could very direly use some regulating.

In any case, common sense will flourish regardless of what stupid moves the FCC continues to push. Why not keep your sanity while giving the FCC the middle finger salute? We're happy to announce that the InterLinked PBX does not support, and will never support, direct-dialing of 9-1-1.

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