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

[Jason P. Talley]

The interpretation that we are reading about the labels is that you use
those to inform customers that the ALI information is not automatically
updated to the new location, it must be done via some customer input.  I
think it also speaks to issue such as power outages, broadband failure,
etc.  Interesting how we don't have stickers on our cordless phones
warning us of power outages...

The rest of the order is fairly clear about the fact that if a user
moves or changes location, the new location must be provided to PSAP.  I
think it would be contrary to everything in the order, including the
issue of not allowing customer to "opt out", to think that the sticker
can preclude 911 service.  It appears that the FCC is requiring all VoIP
providers, large or small to interconnect with every selective router
and PSAP within 120 days and be able to update the ALI database.  There
is reference to pANIs which clearly demonstrate the FCC wants device
with both foreign numbers and that are mobile to be able to transmit and
connect to the proper PSAP natively.  This is the part that Nuvio
believes encompasses an unrealistic timeframe.  That being said, we are
devoting significant engineering and financial resources to try and
comply within the 120 days.

Please understand that I am not offering legal advice or analysis here,
just our interpretation of what is being stated.  As Matt has stated in
prior posts, it would be helpful to consult a regulatory lawyer who has
experience in dealing with the FCC.  I know I personally spend a lot of
time speaking with our counsel in DC.