[Asterisk-biz] 911 Thread

[Paul]

Jason P. Talley wrote:

> I just returned from DC where I had meetings with commissioners and 
> their staff of the FCC regarding the upcoming May 19, 2005 meeting.  
> As most of you know there will most likely be an order issued 
> regarding 911 and VoIP providers.  My concern after our meetings is 
> that the proposed order will be very harmful to the VoIP industry, 
> especially those providers without the ability or resources to provide 
> 911 solutions.  It appears that if you provide VoIP services you are 
> going to have to allow for any emergency call to be routed to the 
> proper PSAP via the selective routers and allow for ALI via the 
> database.  To my knowledge there is no provision that requires the 
> ILEC to allow you access to the selective router and there is no IP 
> method of interconnection.  This means that if you offer VoIP in a 
> single market (ie you only have DIDs from one or limited rate centers) 
> and your product is mobile (you can move it to different broadband 
> connections) you will have to interconnect with all 6600+ PSAPS 
> natively in the US.  This totally ignores the reality of having to 
> pass 10 digit numbers instead of 7 digit numbers to the selective 
> router.  This would require some type of innovation like pseudo-ani 
> that the wireless industry uses right now  and we all know how long 
> that took to implement.  As you can see, this is a tremendous burden. 
> The order essentially mandates the NENA I-2 solution in the next 3-4 
> months without the tools to be able to do it.
>
>  
>
> Here at Nuvio we have invested some serious R&D into being able to 
> offer a limited implementation of e911 in some of the rate centers 
> that we serve, but it is far from being a perfect solution.  It 
> certainly will not be sufficient for what we believe the FCC may be 
> considering.  Honestly, nobody could fulfill that right now.
>
>  
>
> While public safety is of paramount concern, and here at Nuvio we take 
> it very seriously, it is not an issue that can be resolved within the 
> next 3-4 months by simple mandate.  I expect that unless there are 
> some serious revisions that go into place, this is going to be tough 
> if not impossible for most VoIP providers to accomplish. 
>
>  
>
> We are mounting a campaign and I will be asking for help from those of 
> you interested in participating.  I believe we have a responsibility 
> for public safety, but any orders need to be technically and 
> practically possible.
>
>  
>
Jason, thank you very much for being our voice with big brother in DC.

This makes me wonder just how far the FCC intends to go when it comes to 
voip termination for business. Let's take a look at some typical 
non-voip phone system 911 issues first.

1) Does the FCC or any regulator require that the pbx switch handles 911?

2) If so, is it illegal to use or sell an old switch that doesn't handle 
911(or 9 for outside line followed by 911)?

3) If only up-to-date switches are legal does the FCC require battery 
backup in case of power failure?

4) If battery backup is required, how much runtime is required?

5) When the switch fails for any reason(including exhausted batteries) 
what are the requirements? Is there supposed to be a pots interface with 
a red telephone always plugged in? Do all outbound T-1's and PRI's have 
to include a pots interface for the "emergency phone"? Are we required 
to have an extension jack with another red telephone on every floor and 
within every n square feet of the building?

Now think about adding voip to the above setup. As long as the system 
has a single line or channel that the ILEC supports 911 on, what 
difference does it make if we use voip for most termination. As long as 
we are meeting the same requirements that go with a pbx connected to 
analog/digital telco trunking, we are providing the same level of safety.

If somebody already knows the answers to my questions above, please post 
them. Then we can draft something to send to the lawmakers that makes it 
clear that the FCC is way out of line.

One thing we can point out about residential and business users with 
traditional pots lines: There are many who only have telephones that 
require a non-telco power source. All those phones come with warnings 
that the phone will not work during a power failure. Many people never 
read the warning. Many others read it and never heed it. If a bad guy 
turns off the electricity and starts kicking the door in, how do you 
call 911 when you only have a cordless phone? I just checked 2 of mine 
to be sure. Unplug the power and you can't make calls from the handset 
or the base. So maybe the FCC needs to outlaw those. Future models will 
have to also have a trimline handset with a relay that connects it 
directly to the line when power is off?

It looks to me like the FCC already allows some possibly dangerous 
practices. They just want to beat up on the voip crowd.