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

[Matt]

And.. if that DOESN'T work (as far as the F.C.C. is concerned).

When a customer does move.. 1 of two things happen.

#1 - Customer doesn't update their ALI information.
   -- Outcome... if done our way, or another way.. ALI information is
still incorrect, as is routing information... therefore, 9-1-1 call is
routed incorrectly.

#2 - Customer tries to update their ALI information.
  --  Outcome... If customer is outside of their service area they are
presented with a notice, and their service is suspended (for making
outgoing calls) and they are given a notice as to such.
   Or, if acceptable by the F.C.C. simply a notice is given notifying
the customer they are outside of their home service area, and 9-1-1
may not function.
  In part a of #2  I fail to see, again IANAL, how that would not
comply, as the customer has to update their ALI anyway, and when they
do, you can either notify them that service is not available there and
then turn off their service until they update their ALI and move back
into the area.  No?

On 6/10/05, Matt <mhoppes at gmail.com> wrote:
> I do know about the mobile issue.. and here's the thing...(I have not
> yet consulted our lawyer about this)... on page 48 of the FCC
> regulations it says:
> 
> "Advise every consumer new and existing...[when 9-1-1 may be limited
> or not work at all]...Such circumstances include, but are not limmited
> to, relocation of the end user's IP-comptabile CPE, use by the end
> user of a non-native telephone number."
> 
> To me that sounds like if the user has a non-native telephone number,
> OR relocates their device the FCC is saying it's ok to tell the user
> 9-1-1 services may not be available, or may be severely limited.
> 
> Obviously no one here is a lawyer, but thoughts on that?
> 
> On 6/9/05, Jason P. Talley <jason at nuvio.com> wrote:
> > 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
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