[Asterisk-biz] FCC and 9-1-1

[Matt]

I do know about the mobile issue.. and here's the thing...(I have not
yet consulted our lawyer about this)... on page 48 of the FCC
regulations it says:

"Advise every consumer new and existing...[when 9-1-1 may be limited
or not work at all]...Such circumstances include, but are not limmited
to, relocation of the end user's IP-comptabile CPE, use by the end
user of a non-native telephone number."

To me that sounds like if the user has a non-native telephone number,
OR relocates their device the FCC is saying it's ok to tell the user
9-1-1 services may not be available, or may be severely limited.

Obviously no one here is a lawyer, but thoughts on that?

On 6/9/05, Jason P. Talley <jason at nuvio.com> wrote:
> Matt:
> 
> I don't think your solution will comply with the FCC's order unless you
> are not allowing users to have mobile devices.  If the user can
> transport the device outside of your predefined area that you have
> interconnect agreements, you would be in violation of the FCC order.
> Just requiring your users to agree to stay in your service area is not
> enough.  I assume you are also updating the ALI database for each user
> as the 911 call has to use that database if possible.
> 
> I would advise you, and others on this list who believe that they comply
> to consult a good regulatory lawyer who has experience with the FCC
> before sending anything to them.  Right now, the only providers that
> could be compliant, that I know of, are operators that can physically
> prevent the user from making the device mobile, such as some cable
> providers.  Even some of the solutions that have been advertised by
> CLECs and 911 providers do not seem to be compliant.  60% or 75%
> coverage of the US is not going to meet the FCC order and you could be
> subject to fines and action by the FCC.  Your other option is to file a
> waiver petition before the FCC, which has no guarantee of being granted.
> 
> I also assume everyone is familiar with the 30 day "emergency" part of
> the order which requires affirmative acknowledgment of the limitations
> of 911 with VoIP and warning stickers.
> 
> I believe, as do some other VoIP providers that the regulations, while
> addressing an important issue, ignore the reality of what can and cannot
> be done in 120 days.  While the order has yet to be published in the
> Federal Register, which formally triggers the 120 day countdown.  Nuvio,
> in conjunction with others in the industry are exploring what options
> are available and I would be happy to include other VoIP providers that
> are interested.  At this point in time, I do not know what type of
> financial commitment will be required, but it will most likely be
> minimal.  That will all be determined when whatever action is decided.
> 
> Contact me off list and I will provide the details. It is my goal to
> make sure that the VoIP industry has a chance to mature while also
> meeting the demands of public safety in a reasonable and realistic
> manner.
> 
> -jason
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