[asterisk-biz] Dash911 - E911 for VoIP

[Gregory Giagnocavo]

The nitty-gritty specifics of the FCC Order on 9-1-1 for VoIP is below.

It's 90 pages, so here are only a few snippets I thought were relevant to this thread on this List.

Bottom line is that Dash911 - E911 for VoIP *does* provide a way for a VoIP provider to comply, and yes, to 'get legal' with the FCC Order. We provide enhanced 911 where that is in any way possible, and, basic 911 where E911 is not possible.  And, this is what the FCC Order figured on - that there would be cases where enhanced 911 was not going to be possible. So, the FCC gave outlines of what to do in that case. And, we're offering a service for VoIP providers to do that.

There are other companies offering a similar service for VoIP providers.. you can easily find them on google.
We think we have a unique solution set, but the fact remains that there are other companies who can offer 9-1-1 for VoIP. No problem. We like the competition.

I just wanted to make this post, and hopefully the last one on this topic, to show that Dash isn't "leading you to believe", or making false promises, and so on. We offer a service that complies with the FCC Order, and we are focused on enhancing that.

Sincerely
Gregory
FCC ORDER EXCERPTS::

Page 22/23 Par 37
As explained in paragraph 42 infra, however, an interconnected VoIP provider need only provide such call
back and location information as a PSAP, designated statewide default answering point, or appropriate
local emergency authority is capable of receiving and utilizing.
   [Gregory: exactly, which is why some are E911 and some are basic 911. And either are legal depending on the area]

page 25, par 41
By requiring that all 911 calls be routed via the dedicated Wireline E911 Network, we are
requiring interconnected VoIP service providers to provide E911 service only in those areas where
Selective Routers are utilized.(135) We expect that few VoIP 911 calls will be placed in areas that are not
interconnected with a dedicated Wireline E911 Network.(136) 
   [Gregory: Again, this is why some are basic and others are enhanced 911 areas.]

We further note that nothing in this Order
prevents interconnected VoIP providers from entering into mutually acceptable 911 call termination
arrangements with PSAPs that are not interconnected with a dedicated Wireline E911 Network.
   [Gregory: Which has been done in many, many PSAPs]

Page 26, par . 42
By way of example, NENA estimates that approximately 26.6 percent of all PSAPs are not currently capable of
receiving and utilizing wireless E911 Phase I data.(140)
  [Gregory: There you go, how about that! No matter what you do, a high percent of PSAPs aren't even capable of handling E911 calls, they are handled as basic 911.]

We therefore hold that the E911 requirements set
forth above shall be applicable when an interconnected VoIP provider provides service to a Registered
Location only to the extent that the PSAP, designated statewide default answering point, or appropriate
local emergency authority designated to serve that Registered Location is capable of receiving and
utilizing the data, such as ALI or ANI, associated with those requirements. Even in those areas where the
PSAP is not capable of receiving or processing location or call back information, however, we conclude
that interconnected VoIP providers must transmit all 911 calls to the appropriate PSAP via the Wireline
E911 Network.
   [Gregory: Which is exactly what happens, and what we do.]

Page 26, footnote 142
Nothing in this Order, however, prevents interconnected VoIP providers from entering into
mutually acceptable 911 call termination arrangements, with PSAPs, designated statewide default answering points, or appropriate local emergency authorities that are not interconnected with a Selective Router through a dedicated Wireline E911 Network. Cf. id. at 1.
   [Gregory: As before, this is exactly what  happens, and what we do.]

Page 27
45. We also require interconnected VoIP providers to take certain additional steps to minimize the
scope of the 911 issues associated with their service and to facilitate their compliance with our new VoIP
E911 rules, as explained below. First, we require interconnected VoIP providers to obtain, and facilitate
updating of, customer location information. Second, we preclude interconnected VoIP providers from
requiring subscribers to “opt-in” or allowing subscribers to “opt-out” of 911 services and expect that
VoIP providers will notify their customersPage 26 of the limitations of their 911 service offerings.