[Asterisk-biz] US e911 reminder

[trixter aka Bret McDanel]

On Wed, 2005-11-30 at 15:58 -0600, asterisk_help at iwishi.nu wrote:
> 
> OK, So I missed the deadline. I'm franticly putting something together 
> right now. Does anyone have any example letters they might share with 
> us/me?
> 

You are .nu do you actually operate in the US or just resell some US
providers service?  Its on the companies that actually have service here
(as stated in the FCC letter I pasted the url of).

Sorry my email was delayed, although you shouldnt trust lists for things
like this anyway :/


> We are compliant in our local calling area only. We are using the PRI 
> lines our CLEC provides us with using dedicated channels for e911. Our 
> provider changed the switch so that the ISDN CPN is set as the ANI so that 
> the selective router will take the call to the right place. All installs 
> are tested within 30 days of service turn up. Any sooner and the database 
> updates may not be in place. The PSAPs go nuts when 'no record found' is 
> the result. Our CLEC gets an ass chewing for those.
> 
> Any advice?
> 

Well part of the requirement is that you have to cease selling and
advertising if you arent compliant.  Stanaphone appears to have split
their inbound and outbound calls into 2 physically seperate servers (got
a letter from them a while back about that).  Interconnected appears to
use the word 'and' instead of 'or' for calls to and calls from the pstn.
As such they believe that this makes them not interconnected as defined
in the CFR.  I dont know if that will work, but that is what they said
they did.


> We have just 44 paying customer accounts at the moment.
You can keep those accordingto the fcc.gov link.  Just cant get new ones
unless you are compliant.  letters to the fcc are a different matter
from the way it read.

> We did send the stickers and personally called each customer.
Yeah that is a stupid requirement too, no requirement the stickers be
put on the phone just a requirement the provider pay for the stickers
and pay to mail them to the customer.  sigh.

Phone calls, unless recorded do not prove that you notified the customer
of the limitations (if any) - ie when the power is out or internet is
down they dont have 911, and all that.  You may want to see if you
qualify for proof of notification, which may come into play if something
happens.  All a customer has to say is 'nope they didnt tell me' and you
have problems.  Why many sites make you reactivate your account via some
webpage that forces you to acknowledge the limitations and their
responsibilities (ie they cant opt-out of e911, they must provide
accurate location data and must update it anytime they move to a new
location even if temporary, etc).


> We also have our customers signature on a post card. I have two customers 
> who roam with their ATA devices often, so they're the difficult ones.
roaming is part of the problem, they have to update their location
information each time they goto a new lcoation, you have to put that
burden upon them via a clearly worded notice (required by the fcc
document).

> Would I really be expected to build circuits to 7000 PSAPs so two people 
> can roam the United States?
Yes, sadly.  This whole thing is because 2 different people couldnt get
911 off vonage despite vonages clear notice that 911 is opt-in and you
have to agree to provide address details and update it.

The other alternative is to buy into a service that provides that,
however with only 44 customers that becomes a financial burden.  This is
why I wish they made some sort of dollar limit on gross revenue before
you had to do it, or phase it in over time where the smaller providers
can wait before having to comply.  Like the feds did with the ADA.  But
they didnt I think becuase the rbocs and all felt htey could have a new
service to sell to their competition to help make the costs less
favorable and slow the spread of voip.  But I have no proof of that.


-- 
Trixter http://www.0xdecafbad.com     Bret McDanel
UK +44 870 340 4605   Germany +49 801 777 555 3402
US +1 360 207 0479 or +1 516 687 5200
FreeWorldDialup: 635378
http://www.sacaug.org/ Sacramento Asterisk Users Group
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