[Asterisk-biz] Re: 911 Thread

[Jason P. Talley]

I have appreciated the responses that many of you have had to my prior
posting regarding what the FCC is contemplating doing this month
regarding E911 and VoIP.  The simple fact is that there is huge
political pressure to present a solution to the problem regarding 911
and VoIP.  I understand the argument that this is not POTS and was not
designed to be POTS, but that is not going to carry the day anymore.  We
are going to have to implement some type of solution.  Nuvio has lobbied
hard that the I-2 NENA standard is not an acceptable solution, certainly
not achievable in any short time frame (2-5 years), and would force most
providers out of business due to the hardware costs, ongoing
interconnection cost to EVERY PSAP in the country, and lack of legal
right to actual interconnect with that PSAP.  We are advocating that
there be a modified I-3 solution which would provide for IP
interconnects and some standard for which the ALI databases and other
relevant information is verified and then implemented.  The cellular
world was provided close to 10 years for a similar 911 type system
(which is only working sporadically across the country) and I think VoIP
providers can do much more in much less if necessary.

 

That being said, for those of you that feel like writing a technical
letter to the FCC detailing the various problems of nomadic VoIP,
interconnection rights issues, location determination, access to PSAPs
in locales where you do not have CLEC arrangements, etc, I would
encourage that to happen within the next 2 days.  By law, I believe the
record will close on this either Tuesday or Wednesday and after that you
will have no chance to issues comments on any order.  The proceeding is
04-36 and you can file ex-parte comments.  Nuvio has filed many such
letters regarding this, broadband discrimination, etc.  You can search
the FCC system to see how those filings look.  I would be more than
happy to email any of you interested our latest regarding 911 for
guidance.  These filing need to be technical in nature and not simply
concerned with rants and other issues about consumer choice (ie they
can't choose not to have 911), this isn't POTS type arguments, and other
various "political" arguments. We would be happy to shoulder the legal
costs of preparing another filing based on smaller independent providers
as a type of coalition.  If you are interested in signing onto this,
please let me know off-list with pertinent details of your company,
where based, type of service, etc. 

 

Similarly, if you feel that you do not have the time or inclination to
draft a technical ex-parte letter, it is going to be increasingly
important to have your local congressional representative or senator
send a letter to Chairman Martin talking about the harmful effect of
overbroad orders and what it will do to this emerging industry.  I have
a draft letter that I will be happy to share with anyone come Monday.
Contact me off-list.

 

-jason

 

 

Jason P. Talley

Chief Executive Officer

NUVIO CORPORATION

Phone: 816-444-4422 ext. 6711

Fax: 816-333-5915

http://www.nuvio.com <http://www.nuvio.com/> 

jason at nuvio.com

 

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