[Asterisk-biz] 911 update

[alex at pilosoft.com]

On Fri, 13 May 2005, Jason P. Talley wrote:

> The FCC went "sunshine" yesterday regarding its May 19th meeting which
> includes 911.  Thought I would give you a quick update of the draft
> language and where things stand right now.  It is not good.
http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-258669A1.pdf

That seems to be the announcement about the meeting. Do you have any 
reference to the proposed NPRM?

> It appears that the FCC is going to require "interconnected" VoIP
> providers to deliver an emergency call to the proper PSAP with ALI
> information (and update the databases).  This includes all PSAPs and
> means connections through ILECs and RLECS.  Just using the RBOCs alone
> will not even come close to satisfying the standard.  This is much more
> stringent than even the cellular industry has to adhere to.  Before
> someone on this list goes off and says that this is ok, realize that
> this means interconnecting to more than 6600+ PSAPs, devising Psuedo ANI
> type technology, updating databases, etc.  This is no small task.  And
> here is the real kicker, the FCC is currently discussing an
> implementation date of 120 days.  I am sure that some waivers will be
> possible, but obtaining a waiver is not an easy or trivial task.  We
> have no rights to interconnect with any of these services, and in some
> cases, especially RLECs, there is no legal requirement that they open
> the network up even if we were certificated in the state.  Also, the FCC
> appears to specifically preserve our liability for lawsuits.  This is
> contrary to every other telecom provider who may be subject to state
> protections (remember we are interstate now with none of those
> benefits).
This indeed would be disastrous.

> This is bad stuff for the industry.  I am hopeful that during the next
> week as staff meets to work on this a more moderate rule will be
> adopted, especially as it relates to implementation time frame.  This is
> not a question of if anymore, just a question of when.  Public safety is
> important and should be a core component of any offering, but reality
> needs to be addressed as well.
Absolutely right. If FCC mandates e911, they have to mandate ILECs to 
provide open access to e911 tandems, or mandate PSAPs to accept IP 
interconnection. 

-alex