911 address policy for company phones at home

We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case. So two questions... Does anyone here allow their customers to do this? What is the best document to give the customer to support our position? -- Carlos Alvarez TelEvolve 602-889-3003

The FCC?s wireless 911 rules apply to all wireless licensees, broadband Personal Communications Service (PCS) licensees and certain Specialized Mobile Radio (SMR) licensees. Mobile Satellite Service (MSS) providers, however, are currently excluded. *The FCC?s basic 911 rules* require wireless service providers to transmit all 911 calls to a PSAP, regardless of whether the caller subscribes to the provider?s service or not. *Phase I Enhaced 911 (E911) rules* require wireless service providers to provide the PSAP with the telephone number of the originator of a wireless 911 call and the location of the cell site or base station transmitting the call. *Phase II E911 rules* require wireless service providers to provide more precise location information to PSAPs; specifically, the latitude and longitude of the caller. This information must be accurate to within 50 to 300 meters depending upon the type of location technology used. The FCC recently required wireless carriers to provide more precise location information to PSAPs. As a result, wireless carriers will be required to comply with the FCC?s location accuracy rules at either a county-based or PSAP-based geographic level. The new standards apply to outdoor measurements only, as indoor use poses unique obstacles. Compliance The FCC recently established benchmarks that wireless service providers must meet over a period of eight years ? providing wireless carriers with a reasonable amount of time to meet the agency?s more stringent location accuracy requirements. Beginning in 2011, wireless service providers have been required to file with the FCC a list of counties, or portions of counties, that they seek to exclude from the location accuracy requirements. The FCC will permit wireless carriers to exclude counties, or portions of counties, only where wireless carriers determine that providing location accuracy is limited, or technologically impossible, because of either heavy forestation or the inability to triangulate a caller?s location. Wireless carriers must report any changes to their exclusion lists within thirty days of such changes. The exclusion lists and changes must be reported in the record of the FCC?s docketed proceeding addressing location accuracy, PS Docket No. 07-114<http://apps.fcc.gov/ecfs/proceeding/view?name=07-114>, which is publicly available on the FCC?s Electronic Comment Filing System (ECFS) webpage. On Fri, Jan 18, 2013 at 10:51 AM, Carlos Alvarez <carlos at televolve.com>wrote:
We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case.
So two questions...
Does anyone here allow their customers to do this?
What is the best document to give the customer to support our position?
-- Carlos Alvarez TelEvolve 602-889-3003
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
-- Paul LaRegina www.SIPRoutes.com <http://www.siproutes.com/> 516-413-9893 Skype : sirpaul05

I can't look up the document now, but all registered exchange carriers are required by law to route 911. If you don't populate the e911 info, the call will still go through, only it'll route to the national 911 line and the response will be delayed. I, personally, would avoid exposing my organization to such a liability if at all possible. That being said, the accuracy of e911 information is questionable at best. What if I'm talking on my soft phone? What if I'm talking on my soft phone on the other side of the country? The FCC does not strictly regulate VoIP communications technology unless you're a LEC. Even then it's all quite unclear (see pending rulings on MagicJack et al). My point is this: e911, from a regulatory standpoint, is a strange beast. I am not a lawyer, but you might ask your counsel what the implications of a delayed 911 call are and who is culpable from a financial perspective. Hope that helps!! Cheers, Joshua Sent from my iPhone On Jan 18, 2013, at 7:53 AM, "Carlos Alvarez" <carlos at televolve.com> wrote:
We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case.
So two questions...
Does anyone here allow their customers to do this?
What is the best document to give the customer to support our position?
-- Carlos Alvarez TelEvolve 602-889-3003
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Hi Carlos, Here is the link to exactly what you were looking for: http://transition.fcc.gov/cgb/consumerfacts/voip911.pdf As you can see, what they are asking for is quite specifically illegal for you to do. You seem to have a duty to refuse. Regards, Mike Mike Ray, MBA, CNE, CTE Astro Companies, LLC 11523 Palm Brush Trail #401 Lakewood Ranch, FL 34202 DIRECT: 941 600-0207 http://www.astrocompanies.com -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Joshua Goldbard Sent: Friday, January 18, 2013 11:08 AM To: Carlos Alvarez Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home I can't look up the document now, but all registered exchange carriers are required by law to route 911. If you don't populate the e911 info, the call will still go through, only it'll route to the national 911 line and the response will be delayed. I, personally, would avoid exposing my organization to such a liability if at all possible. That being said, the accuracy of e911 information is questionable at best. What if I'm talking on my soft phone? What if I'm talking on my soft phone on the other side of the country? The FCC does not strictly regulate VoIP communications technology unless you're a LEC. Even then it's all quite unclear (see pending rulings on MagicJack et al). My point is this: e911, from a regulatory standpoint, is a strange beast. I am not a lawyer, but you might ask your counsel what the implications of a delayed 911 call are and who is culpable from a financial perspective. Hope that helps!! Cheers, Joshua Sent from my iPhone On Jan 18, 2013, at 7:53 AM, "Carlos Alvarez" <carlos at televolve.com> wrote:
We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case.
So two questions...
Does anyone here allow their customers to do this?
What is the best document to give the customer to support our position?
-- Carlos Alvarez TelEvolve 602-889-3003
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

I don't have a document - BUT - ask them to sign something accepting FULL LEGAL and FINANCIAL RESPONSIBILITY for compliance in the unfortunate event that their staff member needs 911 and cannot dial it. Aaron D. Osgood Streamline Solutions L.L.C P.O. Box 6115 Falmouth, ME 04105 TEL: 207-781-5561 MOBILE: 207-831-5829 ICQ: 206889374 GVoice: 207.518.8455 GTalk: aaron.osgood <mailto:AOsgood at Streamline-Solutions.net> AOsgood at Streamline-Solutions.net <http://www.streamline-solutions.net/> http://www.streamline-solutions.net Introducing Efficiency to Business since 1986. From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 10:51 AM To: voiceops at voiceops.org Subject: [VoiceOps] 911 address policy for company phones at home We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case. So two questions... Does anyone here allow their customers to do this? What is the best document to give the customer to support our position? -- Carlos Alvarez TelEvolve 602-889-3003

http://transition.fcc.gov/cgb/consumerfacts/voip911.pdf send your customer this which shows that you are required by law to provide the 911 service [cid:image001.png at 01CDF570.586BBB50] From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Aaron D. Osgood Sent: Friday, January 18, 2013 11:15 AM To: 'Carlos Alvarez' Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home I don't have a document - BUT - ask them to sign something accepting FULL LEGAL and FINANCIAL RESPONSIBILITY for compliance in the unfortunate event that their staff member needs 911 and cannot dial it. Aaron D. Osgood Streamline Solutions L.L.C P.O. Box 6115 Falmouth, ME 04105 TEL: 207-781-5561 MOBILE: 207-831-5829 ICQ: 206889374 GVoice: 207.518.8455 GTalk: aaron.osgood AOsgood at Streamline-Solutions.net<mailto:AOsgood at Streamline-Solutions.net> http://www.streamline-solutions.net<http://www.streamline-solutions.net/> Introducing Efficiency to Business since 1986. From: voiceops-bounces at voiceops.org<mailto:voiceops-bounces at voiceops.org> [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 10:51 AM To: voiceops at voiceops.org<mailto:voiceops at voiceops.org> Subject: [VoiceOps] 911 address policy for company phones at home We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case. So two questions... Does anyone here allow their customers to do this? What is the best document to give the customer to support our position? -- Carlos Alvarez TelEvolve 602-889-3003

The icing on the cake All interconnected VoIP providers must automatically provide 911 service to all their customers as a standard, mandatory feature without customers having to specifically request this service. VoIP providers may not allow their customers to ?opt-out? of 911 service On Jan 18, 2013 7:12 AM, "Todd Wolf" <twolf at unifiedtechnologies.com> wrote:
http://transition.fcc.gov/cgb/consumerfacts/voip911.pdf send your customer this which shows that you are required by law to provide the 911 service****
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*From:* voiceops-bounces at voiceops.org [mailto: voiceops-bounces at voiceops.org] *On Behalf Of *Aaron D. Osgood *Sent:* Friday, January 18, 2013 11:15 AM *To:* 'Carlos Alvarez' *Cc:* voiceops at voiceops.org *Subject:* Re: [VoiceOps] 911 address policy for company phones at home*** *
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I don?t have a document ? BUT ? ask them to sign something accepting FULL LEGAL and FINANCIAL RESPONSIBILITY for compliance in the unfortunate event that their staff member needs 911 and cannot dial it.****
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Aaron D. Osgood ****
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Streamline Solutions L.L.C****
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P.O. Box 6115****
Falmouth, ME 04105****
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TEL: 207-781-5561****
MOBILE: 207-831-5829****
ICQ: 206889374****
GVoice: 207.518.8455****
GTalk: aaron.osgood****
AOsgood at Streamline-Solutions.net****
http://www.streamline-solutions.net****
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Introducing Efficiency to Business since 1986. ****
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*From:* voiceops-bounces at voiceops.org [ mailto:voiceops-bounces at voiceops.org <voiceops-bounces at voiceops.org>] *On Behalf Of *Carlos Alvarez *Sent:* Friday, January 18, 2013 10:51 AM *To:* voiceops at voiceops.org *Subject:* [VoiceOps] 911 address policy for company phones at home****
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We have a customer who wants us to block 911 on the phones that they give to key employees to take home. They don't want to pay fees for 911 service at each home (which is stupid, since it's so cheap, but that's a digression). I told them this is "illegal" but they asked to see the law, and I can't actually find something that says so. Yet that's the common knowledge around the industry. I do have the FCC documents that require an ITSP to provide the service, but the customer contends it doesn't apply to this specific case.****
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So two questions...****
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Does anyone here allow their customers to do this?****
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What is the best document to give the customer to support our position? ****
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-- ****
Carlos Alvarez****
TelEvolve****
602-889-3003****
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_______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops
participants (7)
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AOsgood@streamline-solutions.net
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carlos@televolve.com
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erik@eespro.com
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j@2600hz.com
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mike@astrocompanies.com
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Plaregina@siproutes.com
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twolf@unifiedtechnologies.com