[Asterisk-biz] Re: 911 Thread

[alex at pilosoft.com]

On Sat, 7 May 2005, Jason P. Talley wrote:

> 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.
I call bullshit. 2-5 years is very achievable given cooperation from
ILECs. Frankly, it only takes for *one* smart carrier to interconnect to
all PSAPs and provide service to the wholesale industry at reasonable cost
- and you have the solution. I'm positive it isn't rocket science for
someone like L3 who are in all the LATAs and already have interconnects to
the ilec tandems (which in all the crappy latas are usually the same as 
selective router tandems. in larger latas, it really isn't a big deal to 
do get another cama trunk). Then, you pay intrado to upload your ps/ali, 
and presto, I-2 solution, here you go.


> 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.
I think its fairly clear that location determination will not happen 
anytime soon, and all we are working on is *ability* for a customer to 
identify their current location for their next 911 call. This isn't all 
that much to ask.

-alex