[asterisk-biz] Dash911 - E911 for VoIP

[Matt]

Gregory,
The main point that I have a question about is:
"FCC mandate that requires all 'interconnected VoIP providers' to
offer 9-1-1 services to their subscribers."
This isn't correct.  If you read the document closely you'll see that
it says that 'interconnected VoIP providers must offer E9-1-1 service
to their subscribers at locations where the PSAP is capable of
accepting an E911 call'.

IE... if the PSAP can accept an E911 call, then the VSP must send the
911 call E911.  I don't care how 'close' you are to providing it, or
if 'no one else' can provide E911 everywhere they need to, or if the
FCC requirements are 'not feasable right now'.  Either way your
suggestion that 'Dash911 makes you FCC legal' simply isn't correct.

The law from the FCC is that you MUST provide E911 911 calls to PSAPs
that can accept E911 calls.    You can not supply this service,
therefore, regardless of how many other companies are not doing it
correctly, you are not complying with the FCC rules and regulations.  
I don't see how you can look at it any other way.  Unless the FCC has
files in some document that I missed and said that 'partial compliance
is ok while you work out the kinks'.   I've seen no such document.

On 2/22/06, Gregory Giagnocavo <jgg at supernet.com> wrote:
>  In response to several recent mentions of Dash911-E911 for VoIP
>
> Dash911 provides 9-1-1 emergency calling services to VoIP providers so that smaller  VSPs (under 35,000 current voip subscribers) can afford to comply with the FCC mandate that requires all 'interconnected VoIP providers' to offer 9-1-1 services to their subscribers.
>
> As some have mentioned here on this list, Dash911 uses Intrado as a backbone which means that Dash911 can offer a small provider the same coverage that the "big boys" have, that is, national USA coverage. Dash911 is provider-agnostic, which means we can provide 9-1-1 service to any North American telephone number, regardless of who is the provider of that number (DID).
>
> This is not always the case with other 9-1-1 service providers; for example, Level3 only provides 9-1-1 services to numbers that belong or are assigned to Level3. Level3 provides an excellent 9-1-1 service, but you would find that the cost of getting set up with them is over $30,000, from what was told to me by customers of ours who are Level3 master resellers. Oh, and to deal with Level3 requires that you also make a deal with a 'steering/routing' provider such as TCS which has its own set of fees. Excellent service, but for all intents and purposes, not affordable for 'smaller' VoIP providers (VSPs).
>
> One important, very important thing, to note: the FCC mandates something that simply isn't technically possible, and that is:: "E911 coverage for all VoIP subscribers". The reason this isn't feasible, or possible, is that the routing of an "enhanced" or "E"911 call is handled very differently than a landline 9-1-1 call.  (The term and format "9-1-1" refers collectively to both basic 911 and enhanced or E911 emergency calls.)
>
> So, it is very possible that a VoIP subscriber will have only 'basic' 911 in certain areas, particularly rural areas or areas controlled by a smaller CLEC or old line mom-and-pop phone companies. Yet, the wireline phone at that same address could very well have enhanced 911. That's the nature and current status of VoIP 911.
>
> We chose Intrado as a backbone because we believed, and still do, that they have the most advanced in-house system, the most experience in handling 9-1-1 calls nationwide for over 20 years, and the most aggressive plan to spend tens of millions of dollars this year to ramp up efforts to implement enhanced 911 throughout the USA.
>
> The challenges are many, including trying to deal with PSAPs that do not want to handle VoIP emergency calls. The national 9-1-1 system and PSAPs is/are a mish-mash of all sorts of technology and protocols, so this isn't an easy task.
>
> Yet, the FCC has mandated that VSPs provide E911 emergency calling services. For all of the VSPs we have spoken to, and we have spoken to hundreds, that means that VSPs need to find the best 9-1-1 services provider they can, and sign up and get implemented. That way a) the VSP is legally in compliance, which is the best protection against liability issues, and, b) the VSP can be sure that no matter where the subscriber moves/plugs-in his VoIP phone, that the subscriber will at least have basic 911 *everywhere*.  Having at least basic 911 *everywhere* and complying with the law, is better than having enhanced E911 only at the primary address _and_ not complying with the law.
>
> It is correct that Dash911, and any other 9-1-1 services provider for that matter, does not have the ability to offer E911 for every address in the USA. That is a fact, pure and simple - nobody can do it. Heck, about 9% of the nation's PSAPs can't handle an enhanced 911 call at all, they don't have the technology at their end.
>
> The bottom line is that Dash911, and several other companies, offer the FCC-required service of "9-1-1 for VoIP, often called "nomadic" 911, "v911" or "mobility 911". The coverage from each company is similar, although not identical, for every geographic area at the moment. Level3's coverage is more complete in some areas, Intrado's is more complete in other areas. For the vast majority of the population, enhanced 911 _is_available for VoIP. But there are areas where enhanced 911 coverage is "spotty" for the moment; areas such as rural and west Pennsylvania, upstate New York, rural Nebraska, rural Wyoming, and parts of Arizona. These are not densely populated areas, but to the VoIP providers in these areas, these are obviously important areas to them.
>
> Intrado is working as fast as possible, with a "money is not an object" mentality as their strategy to have complete coverage for E911 as fast as possible - which means Dash911 will have the same wonderful coverage, currently getting more complete day-by-day as Intrado brings new PSAPs live across the country.
>
> Dash911 is also working to obtain CLEC status in specific states where we are already in contact with CLECs who have direct trunking  in place, so we can provide E911 in areas that otherwise currently have only basic 911 for voip. This is a very, very expensive undertaking, but Dash911 believes that making these investments will provide better coverage than any of its competitors - Dash911 plans to build a 'best of breed' solution by using every possible strategy to become a 'category killer' in the 9-1-1 services arena. We've so far spent/committed over $1 million dollars to build out our system, and that isn't the end of it by far.
>
> Dash911 provides a fully-managed and completely outsourced 9-1-1 services solution for VoIP providers. A VoIP provider doesn't need to contract for any circuits, hire engineers, maintain 24/7 call centers, deal with most address correction errors.... all of this is handled and managed by Dash911.
>
> And, we help in other ways..- there are now nine states that REQUIRE that VSPs with even one subscriber in their state, must file an agreement with that state. These Agreements run from a simple one-page notification of status, to 30 page Agreements that provide for periodic reports, audits and submission of 9-1-1 recovery fees to the states. Did you know Texas requires fees ranging from 65 cents to $1.17 per line per month? Iowa requires 25 cents to 85 cents per line per month, and this varies by county.
>
> Dash911 is working on entering agreements with each and every state to try to head off the nightmare that this will cause for VSPs. After all, a VSP would be required to sign a separate and different agreement with these nine states (and I believe 22 states will get in on this by end of 2006), and provide reports and submit fees.. all with potential liability and heavy fines if the VSP doesn't comply.
>
> Well, Dash911's approach is to try to sign a Master Agreement with each such state, and get permission to exempt each of the Dash911 VSP customers from doing so. In this way, Dash911 will be a sort of clearing house for reporting and for collection/remitting of payment. Dash911 will bill each VSP based on subscriber activity in that state for that month (meaning any subscriber from that or any other state who, for at least one day in that month was registered to an address in that state). Dash911 will calculate the amount due and bill the VSP; the  VSP will pay Dash911, and Dash911 will submit one check to the state, along with one master report of activity for all of our VSP customers.  We already have this arrangement with one of the big states, and we are in the works with other states. We were notified just yesterday of Iowa's new fees structure, effective February 7, 2006. To cope with this moreass and increasingly complex paperwork, we needed to come up with a Government Affairs person.
>
> I will be glad to answer individual questions, just please keep them brief and to the point. We have some info on the oeverall 9-1-1 and VoIP issue on our website and are developing an entire whitepapers section which we will post by late March along with our newly designed website.
>
> I hope this information was helpful.
> Sincerely,
> Gregory Giagnocavo, President
> Dash911 Solutions, Inc.
> www.Dash911.com
>
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