[Asterisk-biz] FCC and 9-1-1

[Jason P. Talley]

Matt:

I don't think your solution will comply with the FCC's order unless you
are not allowing users to have mobile devices.  If the user can
transport the device outside of your predefined area that you have
interconnect agreements, you would be in violation of the FCC order.
Just requiring your users to agree to stay in your service area is not
enough.  I assume you are also updating the ALI database for each user
as the 911 call has to use that database if possible.

I would advise you, and others on this list who believe that they comply
to consult a good regulatory lawyer who has experience with the FCC
before sending anything to them.  Right now, the only providers that
could be compliant, that I know of, are operators that can physically
prevent the user from making the device mobile, such as some cable
providers.  Even some of the solutions that have been advertised by
CLECs and 911 providers do not seem to be compliant.  60% or 75%
coverage of the US is not going to meet the FCC order and you could be
subject to fines and action by the FCC.  Your other option is to file a
waiver petition before the FCC, which has no guarantee of being granted.

I also assume everyone is familiar with the 30 day "emergency" part of
the order which requires affirmative acknowledgment of the limitations
of 911 with VoIP and warning stickers.

I believe, as do some other VoIP providers that the regulations, while
addressing an important issue, ignore the reality of what can and cannot
be done in 120 days.  While the order has yet to be published in the
Federal Register, which formally triggers the 120 day countdown.  Nuvio,
in conjunction with others in the industry are exploring what options
are available and I would be happy to include other VoIP providers that
are interested.  At this point in time, I do not know what type of
financial commitment will be required, but it will most likely be
minimal.  That will all be determined when whatever action is decided.  

Contact me off list and I will provide the details. It is my goal to
make sure that the VoIP industry has a chance to mature while also
meeting the demands of public safety in a reasonable and realistic
manner.

-jason