[Asterisk-Users] US e911 reminder

[trixter aka Bret McDanel]

On Thu, 2005-12-01 at 11:40 -0500, C F wrote:
> On 11/28/05, trixter aka Bret McDanel <trixter at 0xdecafbad.com> wrote:
> > Enforcement Bureau Outlines Requirements of November 28, 2005
> > Interconnected Voice Over Internet Protocol 911 Compliance Letters
> > http://www.fcc.gov/eb/Public_Notices/DA-05-2945A1.html
> 
> 
> I'm just trying to clarify this, according to note 1 on that paper:
> 
> ====
> 1 ``Interconnected VoIP service'' means an interconnected voice over
> Internet Protocol service that: (1) enables real-time, two-way voice
> communications; (2) requires a broadband connection from the user's
> location; (3) requires Internet protocol-compatible customer premises
> equipment (CPE); and (4) permits users generally to receive calls that
> originate on the public switched telephone network and to terminate calls
> to the public switched telephone network.  See 47 C.F.R. � 9.3.

The FCC is quoting 47 CFR section 9.3.  
http://www.access.gpo.gov/nara/cfr/waisidx_05/47cfr9_05.html
There are a lot of legal precedents on how to interpret law in the US.
The CFR is law so those rules apply.  Generally use of the owrds 'and'
and 'or' are important.  In element 4 it uses 'and' to discuss in/out
bound calls.  So you 'generally' have to provide both (I dislike the use
of the word generally as it is unclear what that means exactly).  You
have to provide all 4 elements as well, although generally speaking the
first 3 are a given - but one could make an argument you dont require
broadband becuase you use low bitrate codecs :)


> =====
> Does that mean:
> 1. That if I allow only outbound, I'm not required to comply? (number 4 above)
correct 'and' is critical.  The supreme court has ruled on many
occasions that lawmakers words are infact binding, specifically over
interpretation of laws.

> 2. That if I setup the customer, as a remote node on my hosted
> asterisk server for inbound and outbound of just their business phone,
> but have it setup that 911 when dialed from the phone should use a
> backup proxy that is local and doesnt require a broadband connection
> (it's using the LAN), that I'm not required to comply? (number 2
> above), the setup in mind is where I use a polycom phone with a Sipura
> SPA 3000, configured that when 911 is dialed it  uses the Sipura and
> not Asterisk.
That I think is pushing it.  I really dont know how they would rule on
that, my guess is they would say that their intent was to cover that
type of activity so it sucks to be you.

I did not see a definition of broadband internet though, it could be
that they consider broadband anything greater than 56k, or it could be
that they consider it a lot higher.  Maybe I just missed the definition,
but regardless if you dont *require* a broadband internet connection to
use your service because you allow people at most 2 calls at a time via
the gsm codec for example, you dont fit all the elements to be required.

Now I am sure that was in the intent of the fccs decision but that is a
little more clear than tossing equipment at a customer site and
providing service off the lan vs off a 'broadband connection' that you
provide ...


> 3. If the answer to 2 is that yes I have to comply, then why when
> installing a lagecy pbx (like avaya) that doesn't have battery backup
> I'm not required to mail stickers? is that because I don't use the
> name VoIP? and the media hasn't caught up to this one (I'm sure it
> happended before)?
> 

I am sure that is part of it.  In effect this new legislation forces
VoIP companies to pay RBOCs for access to the PSAP (generally e911 is
provided by a direct connect to the switch where the psap is connected).
By providing a passthrough the RBOCs (who have been complaining about
unfair competition from voip for years) now get some money from their
competition.

Interresting isnt it?


-- 
Trixter http://www.0xdecafbad.com     Bret McDanel
UK +44 870 340 4605   Germany +49 801 777 555 3402
US +1 360 207 0479 or +1 516 687 5200
FreeWorldDialup: 635378
http://www.sacaug.org/ Sacramento Asterisk Users Group
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