[Asterisk-biz] 911 Thread

[alex at pilosoft.com]

On Sat, 7 May 2005, Paul wrote:

> 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?
Not FCC but many states have requirement already for PS/ALI support for
PBXs with >N users. N varies by state. There are specific rules
state-by-state that require ps/ali support for certain institutions
regardless of their number of users (schools, hotels).

See this for summary:
http://www.nena9-1-1.org/9-1-1TechStandards/state.htm


> 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)?
It may be illegal to use depending on state. see specific laws.

> 3) If only up-to-date switches are legal does the FCC require battery
> backup in case of power failure?
Not to my knowledge, but that may vary by state.

> 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?
The requirement for a dedicated POTS "red telephone" for fire warden
exists, it is by by NFPA, and it applies to every single state, to my
knowledge.

> 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.
Not really. See above.
> 
> 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.
Stop feeling persecuted. FCC is finally doing something for the consumer,
and I applaud them. Now, *imposing* 3-month-implementation requirement on
ITSPs is insane - it took 10 years for wireless industry to conform to the 
e911, and they had cooperation of the ILECs (because, wireless companies 
*are* ILECs in most places). Now, I think the proper way to do this is to 
require ILECs to provide interconnection for selective router access at a 
reasonable price, and require intrado/nena to provide access to PS/ALI 
database at a reasonable price. And yes, require ITSPs to provide E911 in 
a reasonable timeframe (say, 12 or 24 months).

-alex