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

[Dean Collins]

Not native telephone numbers are things like private enum and Freshtel
etc.



> -----Original Message-----
> From: asterisk-biz-bounces at lists.digium.com [mailto:asterisk-biz-
> bounces at lists.digium.com] On Behalf Of Matt
> Sent: Friday, 10 June 2005 8:09 AM
> To: Commercial and Business-Oriented Asterisk Discussion
> Subject: Re: [Asterisk-biz] FCC and 9-1-1
> 
> 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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> >
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