" " Furthermore, providers of interconnected VoIP services that can be
utilized from more than one physical location must provide their end users
one or more methods of updating information regarding the user's physical
location. "
--If there was any question about not having to handle updates, it's settled
here. If they can be at more than one location, they have to be able to
update. "
* Sorry if this has has hurdled off-topic *
The real problem is all Voip service is *capable* of being nomadic. Only
ISPs can practically offer a Voip service that is non-nomadic. Every
other Vonage of the world is nomadic by it's nature. Let's just go ahead
and assume a nomadic user is not going to update a web form every time
they plug in. It's a process designed to fail. IMHO Voip providers will
need an automatic way to resolve an IP address to a street address.
While this will not work for mobile wireless IP services like
1xRTT/EVDO. It will work for most Metro Ethernet, T-1,DSL, Cable Modem,
fixed wireless services,etc. Maybe what these rules really need is to
mandate a DNS style LOC record for every IP address. The current DNS LOC
record is designed to provide latitude and longitude coordinates. Which
is not all that useful for E911 services (hello cellular!). But a street
address equivalent of LOC record system would do well. *
*Unfortunately the needed ISP rules might some how be outside the
jurisdiction of the FCC. But if this was in place Voip providers could
update the ALI database by reading the location information when the
user registers from a different IP address. If no LOC records exists
the client software can notify the end user that E911 is not available.
Privacy considerations with a reverse lookup database like this would be
significant. So perhaps a closed system that only allows authorized
queries is needed.
The big danger for the FCC is that the rules they have put in place are
creating a system dependent on end user cooperation. Bottom line is you
CANNOT depend on the consumer to help themselves.
- Dustin -
Michael Giagnocavo wrote:
Not that I know of. From the FCC order:
" To achieve these goals, the Commission adopts a broadly-stated E911
requirement that applies to all interconnected VoIP services, while allowing
providers flexibility to choose among technological solutions. "
--Key word is *all*.
" The Order recognizes that some VoIP services, particularly those nomadic
services that allow consumers to take their VoIP service from their home to
their office or their beach house, face significant implementation
challenges. Access to the trunks, selective routers, and databases of the
E911 network is essential to meet the obligations set out here."
--Here the FCC recognizes nomadic services, and adds that there might be
"significant implementation challenges".
" Furthermore, providers of interconnected VoIP services that can be
utilized from more than one physical location must provide their end users
one or more methods of updating information regarding the user's physical
location. "
--If there was any question about not having to handle updates, it's settled
here. If they can be at more than one location, they have to be able to
update.
One thing the order is not clear on is how fast the updates need to happen.
The FCC says "timely", and refuses to set any specific performance metric.
Some people are working on a "one business day" response, and others (inc.
the company I work for), are doing ~15 minutes. I personally believe the FCC
is going to see what people do and decide to then set some standards. I.e.,
if 90% of providers are doing 15 minute updates, and a few are only doing
1-day updates, I'm pretty sure they'll address the issue. (I certainly don't
think 1-day is "timely").
I personally believe it's better to side on being a bit more cautious and
implementing something that will most certainly work, versus looking for a
loophole and hoping to slide through. Even doing a rough calculation for
risk shows it's not worth it.
Disclaimer:
This is my own opinion which I believe is reasonably informed and does not
necessarily represent the views of Dash911. I work for Dash911, which
provides 911 services, so I could have some slight bias in my personal
views.
-Michael
-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED] On Behalf Of Dustin Goodwin
Sent: Monday, August 08, 2005 10:06 AM
To: Commercial and Business-Oriented Asterisk Discussion
Subject: Re: [Asterisk-biz] Status of 911 for voip providers?
Were there any exemption for nomadic services in the FCC ruling?
- Dustin -
Michael Giagnocavo wrote:
Everyone,
I've been trying to keep up with this 911 issue for voip providers. Does
anyone
have a handle on:
1. What must be done to be compliant?
<snip>
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