[Asterisk-biz] Status of 911 for voip providers?

Mon Aug 8 13:54:04 MST 2005

>The real problem is all Voip service is *capable* of being nomadic. Only
>ISPs can practically offer a Voip service that is non-nomadic. Every
>other Vonage of the world is nomadic by it's nature. Let's just go ahead

Well, at a technical level, yes and no. Time Warner, for instance, offers
non-nomadic VoIP, and they technically restrict it -- your device can only
register to their VoIP services if you are in the cable "node" that you're
supposed to be in. (I say "node" because I'm not sure of the actual
technical layout of cable ISPs.). In addition, I believe their devices are
non-end-user accessible, i.e., it's not a tiny ATA that sits on your desk. 

I've talked with some companies that have similar setups, where they have a
VoIP PBX, and don't need to worry about the FCC order, since all extensions
only work on their LAN, and they already have a local 911 solution (private
ALI, or perhaps just a POTS line).

Now, for service, it's not been proven yet what this means. If you drop an
ATA on your clients desk and say "don't touch it", that probably isn't good
enough to consider it non-nomadic. If you bolt an ATA to the outside of
their house and put it in a box with a key, then perhaps it is.
Additionally, if you use other technical means (i.e., ensure their IP falls
within an allowed range), that also might be acceptable to say you have
non-nomadic, and thus don't need to handle updates.

>and assume a nomadic user is not going to update a web form every time
>they plug in. It's a process designed to fail. IMHO Voip providers will
>need an automatic way to resolve an IP address to a street address.
>While this will not work for mobile wireless IP services like
>1xRTT/EVDO. It will work for most Metro Ethernet, T-1,DSL, Cable Modem,
>fixed wireless services,etc. Maybe what these rules really need is to
>mandate a DNS style LOC record for every IP address. The current DNS LOC
>record is designed to provide latitude and longitude coordinates. Which
>is not all that useful for E911 services (hello cellular!). But a street
>address equivalent of LOC record system would do well. *

Well, there are significant problems in that. For starters, X and Y
coordinates are not enough. For instance, in an apartment complex, say, with
300 units, just knowing the street address isn't even close for emergency
response (unless, say, the entire building is on fire). If a dispatcher gets
a call "I'm having a heart attack", and then the line goes dead, and then
the medics show up at the main address, asking "where's the person who's in
trouble" probably won't be very useful. 

Then there's just the massive issue of actually getting IPs associated with
locations, dealing with NAT, VPN, people sharing connections, wireless
(unsecured default networks anyone?), etc. etc. etc.

>*Unfortunately the needed ISP rules might some how be outside the
>jurisdiction of the FCC. But if this was in place Voip providers could
>update the ALI database by reading the location information when the
>user registers from a different IP address.  If no LOC records exists
>the client software can notify the end user that E911 is not available.
>Privacy considerations with a reverse lookup database like this would be
>significant. So perhaps a closed system that only allows authorized
>queries is needed.

Well, saying 911 is not available == turning off service, as far as I can
tell from the FCC order. There's not a way to opt out. 

>The big danger for the FCC is that the rules they have put in place are
>creating a system dependent on end user cooperation. Bottom line is you
>CANNOT depend on the consumer to help themselves.

That's for sure. And that's what the FCC wants VoIP providers to do: help
their customers. One of the things we're doing at Dash911 is to call out
customers and confirm the address. We'll do this on a schedule, or when
we've detected that the device has probably moved (we won't know where it
is, but we'll have some accuracy in determining that it isn't where it was
before).

>- Dustin -

Michael Giagnocavo wrote:

>Not that I know of. From the FCC order:
>
>" To achieve these goals, the Commission adopts a broadly-stated E911
>requirement that applies to all interconnected VoIP services, while
allowing
>providers flexibility to choose among technological solutions.  "
>
>--Key word is *all*.
>
>" The Order recognizes that some VoIP services, particularly those nomadic
>services that allow consumers to take their VoIP service from their home to
>their office or their beach house, face significant implementation
>challenges.  Access to the trunks, selective routers, and databases of the
>E911 network is essential to meet the obligations set out here."
>
>--Here the FCC recognizes nomadic services, and adds that there might  be
>"significant implementation challenges". 
>
>" Furthermore, providers of interconnected VoIP services that can be
>utilized from more than one physical location must provide their end users
>one or more methods of updating information regarding the user's physical
>location.  "
>
>--If there was any question about not having to handle updates, it's
settled
>here. If they can be at more than one location, they have to be able to
>update. 
>
>One thing the order is not clear on is how fast the updates need to happen.
>The FCC says "timely", and refuses to set any specific performance metric.
>Some people are working on a "one business day" response, and others (inc.
>the company I work for), are doing ~15 minutes. I personally believe the
FCC
>is going to see what people do and decide to then set some standards. I.e.,
>if 90% of providers are doing 15 minute updates, and a few are only doing
>1-day updates, I'm pretty sure they'll address the issue. (I certainly
don't
>think 1-day is "timely").
>
>I personally believe it's better to side on being a bit more cautious and
>implementing something that will most certainly work, versus looking for a
>loophole and hoping to slide through. Even doing a rough calculation for
>risk shows it's not worth it.
>
>Disclaimer:
>This is my own opinion which I believe is reasonably informed and does not
>necessarily represent the views of Dash911. I work for Dash911, which
>provides 911 services, so I could have some slight bias in my personal
>views.
>
>-Michael
>
>-----Original Message-----
>From: asterisk-biz-bounces at lists.digium.com
>[mailto:asterisk-biz-bounces at lists.digium.com] On Behalf Of Dustin Goodwin
>Sent: Monday, August 08, 2005 10:06 AM
>To: Commercial and Business-Oriented Asterisk Discussion
>Subject: Re: [Asterisk-biz] Status of 911 for voip providers?
>
>Were there any exemption for nomadic services in the FCC ruling?
>
>- Dustin -
>
>Michael Giagnocavo wrote:
>
>  
>
>>>Everyone,
>>>
>>>I've been trying to keep up with this 911 issue for voip providers. Does
>>>anyone
>>>have a handle on:
>>>
>>>1. What must be done to be compliant?
>>>   
>>>
>>>      
>>>
><snip>
>
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