On 01/18/2013 02:27 PM, Carlos Alvarez wrote:

This is a good point, and a fine line. I'd say at least 50% of our customers move phones. Almost none of them tell us. I suppose knowing that they do puts us in a tougher legal situation than having plausible deniability.

Which is why this paragraph should have been written as: "It occurs to me that conceivably, at least 50% of our customers could, hypothetically, in principle, be moving their phones, and possibly without telling us, perhaps maybe." :-) -- Alex Balashov - Principal Evariste Systems LLC 235 E Ponce de Leon Ave Suite 106 Decatur, GA 30030 United States Tel: +1-678-954-0670 Web: http://www.evaristesys.com/, http://www.alexbalashov.com/

On Fri, Jan 18, 2013 at 12:56 PM, Alex Balashov <abalashov at evaristesys.com>wrote:

Which is why this paragraph should have been written as:

"It occurs to me that conceivably, at least 50% of our customers could, hypothetically, in principle, be moving their phones, and possibly without telling us, perhaps maybe."

Heh. Of course, we have a pretty good idea on who has moved because of their IP address. Which makes me start thinking about a system that would look for "non-home" IP addresses and alert the customer. Though that gets pretty complicated when we have small businesses with DSL connections and such, which may change IP at random. -- Carlos Alvarez TelEvolve 602-889-3003

FYI, at least in Florida, providers are *required* to separately list the 911 surcharge as a separate line item, and are prohibited from marking it up or down from the actual surcharge amount, usually 0.50 per line. While one would have the ability to change or waive a provider-imposed records management charge, it would not (at least in Florida) have the ability to remove the surcharge or bundle it with the service price. 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 From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Jon Radel Sent: Friday, January 18, 2013 1:44 PM To: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home Unless I'm missing something here, you're not proposing to sell service to a stationary location and warning the customer that 911 will break if they fail to notify you that they've moved the phone, but you're selling service to stationary location A when the customer has already notified you that they'll really be using the phone in stationary location B. That really doesn't sound like the same thing at all. They've already told you that the phone is going to be in location B and you're proposing to not handle 911 appropriately. (My apologies if I've misunderstood the situation.) Be warned that the FCC has clearly signaled that they don't find waivers involving 911 the slightest bit amusing. See http://www.fcc.gov/document/vantage-communications for their side of our story. You might find the references to actual regulatory language useful. I also find myself impelled to ask: Are you actually pricing this in such a way that there's a line item for 911 service with a dollar figure next to it? That's just inviting the customers to try haggle, and could be construed that you consider 911 optional rather than a fundamental part of your service. Or is this all just a side-effect of charging for the DIDs in the additional rate center(s) where the customer's employees live? Bottom line, however, my advice is that you're treading into waters where you *really* *really* want to talk to a competent lawyer with a specialty in this arena and not take random advice on a mailing list. Not even mine. :-) Getting this wrong could conceivably destroy your company. At the very least, compare what the FCC is currently saying against what Mary Lou is saying, some of which appears to be dangerously out of date. --Jon Radel jradel at vantage.com 267-756-1014 On 1/18/13 1:01 PM, Carlos Alvarez wrote: Great answer, thanks. This really covers what the customer is asking for, which is basically the stationary option (all phones show one CLID/ANI/location). I will advise them that it's legal, just not advised, and get a written signature for liability. We do use a 911 service provider, we're not a CLEC. We currently provide the ability for a customer to have an address for each individual phone if they choose. On Fri, Jan 18, 2013 at 10:48 AM, Mary Lou Carey <marylou at backuptelecom.com> wrote: Legally VOIP providers have the option to offer roaming VOIP services or stationary VOIP services. If you offer roaming VOIP you are required to provide your customers with a way to update their address information whenever they move their phone. It can either be a website they log into to change their address or a 24 hour phone number they call, but either way you MUST provide it if you allow them to roam. If you do allow them to roam you have to get your 911 service from a VOIP 911 provider (who has connections to every PSAP in the country) or be connected to every PSAP in the country yourself because a connection to the LEC network will only cover you for the counties or parishes that you establish trunks for. Most VOIP providers I know sign up with a VOIP 911 provider because they cover a large area so it's cheaper to do that then have a multitude of connections through the LEC. If you decide to go with a stationary VOIP product, you must have the customer sign a waiver stating that they are aware that if they move their phone they will not receive 911 service. I believe the FCC ruled in the last year or so that if you also have to place some type of sticker on the phone so that the end user who uses the phone knows 911 is not available when you move it rather than just the person who ordered the phones. So the decision is not your customer's, but yours. If you choose to allow the customer to move their phone then you either have to place a sticker on the phone stating that 911 service will not be available to the customer OR you have to provide the customer with a way to change their address information when they do move the phone. While you could offer either option to customers based on how much they wanted to pay, I would think liability wise it would be better if you either offered it to everyone or no one at all because it would be too easy for one of your employees to make a mistake in setting someone up and not put them on the right plan. Mary Lou Carey BackUP Telecom Consulting marylou at backuptelecom.com Office: 615-791-9969 x 2001 <tel:615-791-9969%20x%202001> From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 9:51 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 -- Carlos Alvarez TelEvolve 602-889-3003 _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

My apologies, upon a careful re-reading of your e-mail I retract my statement about it being out of date, as you may have just phrased part of it unclearly (at least to this reader): "If you choose to allow the customer to move their phone then you either have to place a sticker on the phone stating that 911 service will not be available to the customer OR you have to provide the customer with a way to change their address information when they do move the phone." I believe FCC regulations clearly state that if the phone can be moved you must provide at least one mechanism for customers to update the physical location information There has been no "or" in this one since the interim rules went away years ago. But I may be misunderstanding your intent here. In any case, the scenario that Carlos described sounds a lot more, to me at least, like the customer saying "These phones are going to be location B but we want to save money by having the PSAP think the call is coming from location A," rather than "Oh, yes, well, sometimes our employees might sneak phones out of the building; what can you do?" By the way, if you read the Vantage Communications document, I believe you'll find the FCC never complained about us not delivering 911 calls. They complained about us delivering 911 calls to the wrong PSAP for the physical location of the phone. Which sounds pretty much like what Carlos's customer is asking him to do if the employees live far away enough from work. And yes, I quite agree that VoIP didn't originate many of the problems with 911--just made them worse. --Jon Radel jradel at vantage.com 267-756-1014 On 1/18/13 3:51 PM, Mary Lou Carey wrote:

I just wanted to point out one thing. The waiver I mentioned is NOT to avoid providing 911 service for the customer as it sounds to be the case in Vantage's situation. You MUST provide 911 service for the customer. The waiver simply states that the 911 service is for the single location that the phone was installed and while the phone might work if you move it somewhere else, the 911 service will not!

I would fully agree that relying on waivers is risky business - especially when it comes to 911. When McDonald's can be held liable for someone spilling hot coffee on themselves when they stuck it between her legs, you can most certainly be sued for not providing 911 service when the customer moved their phone. My suggestion would be to sign up for the roaming ALI database service so the customers can update their location information whenever they move the phone and then program the phones so that every time the phone is powered up, the customer has to update their location in the ALI database. That's really the safest way to operate!

I remember going on an interview years ago to a retail company (who is no longer in business) and one of the questions they brought up was a problem they were dealing with at the moment. They had two locations across the freeway from each other and when someone called the 911 from one location, the ambulance ended up showing up at the wrong building. Through a little investigation we found out that regardless of which location someone dialed 911 from, the calls were all routed to one number in their PBX. That one number happened to be associated with the main building so when 911 was called, that's where the ambulance showed up.

Mary Lou Carey

BackUP Telecom Consulting

marylou at backuptelecom.com

Office: 615-791-9969 x 2001

*From:*voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] *On Behalf Of *Jon Radel *Sent:* Friday, January 18, 2013 12:44 PM *To:* voiceops at voiceops.org *Subject:* Re: [VoiceOps] 911 address policy for company phones at home

Unless I'm missing something here, you're not proposing to sell service to a stationary location and warning the customer that 911 will break if they fail to notify you that they've moved the phone, but you're selling service to stationary location A when the customer has already notified you that they'll really be using the phone in stationary location B. That really doesn't sound like the same thing at all. They've already told you that the phone is going to be in location B and you're proposing to not handle 911 appropriately. (My apologies if I've misunderstood the situation.)

Be warned that the FCC has clearly signaled that they don't find waivers involving 911 the slightest bit amusing. See http://www.fcc.gov/document/vantage-communications for their side of our story. You might find the references to actual regulatory language useful.

I also find myself impelled to ask: Are you actually pricing this in such a way that there's a line item for 911 service with a dollar figure next to it? That's just inviting the customers to try haggle, and could be construed that you consider 911 optional rather than a fundamental part of your service. Or is this all just a side-effect of charging for the DIDs in the additional rate center(s) where the customer's employees live?

Bottom line, however, my advice is that you're treading into waters where you *really* *really* want to talk to a competent lawyer with a specialty in this arena and not take random advice on a mailing list. Not even mine. :-) Getting this wrong could conceivably destroy your company.

At the very least, compare what the FCC is currently saying against what Mary Lou is saying, some of which appears to be dangerously out of date.

--Jon Radel jradel at vantage.com <mailto:jradel at vantage.com> 267-756-1014

On 1/18/13 1:01 PM, Carlos Alvarez wrote:

Great answer, thanks. This really covers what the customer is asking for, which is basically the stationary option (all phones show one CLID/ANI/location). I will advise them that it's legal, just not advised, and get a written signature for liability.

We do use a 911 service provider, we're not a CLEC. We currently provide the ability for a customer to have an address for each individual phone if they choose.

On Fri, Jan 18, 2013 at 10:48 AM, Mary Lou Carey <marylou at backuptelecom.com <mailto:marylou at backuptelecom.com>> wrote:

Legally VOIP providers have the option to offer roaming VOIP services or stationary VOIP services. If you offer roaming VOIP you are required to provide your customers with a way to update their address information whenever they move their phone. It can either be a website they log into to change their address or a 24 hour phone number they call, but either way you MUST provide it if you allow them to roam. If you do allow them to roam you have to get your 911 service from a VOIP 911 provider (who has connections to every PSAP in the country) or be connected to every PSAP in the country yourself because a connection to the LEC network will only cover you for the counties or parishes that you establish trunks for.

Most VOIP providers I know sign up with a VOIP 911 provider because they cover a large area so it's cheaper to do that then have a multitude of connections through the LEC. If you decide to go with a stationary VOIP product, you must have the customer sign a waiver stating that they are aware that if they move their phone they will not receive 911 service. I believe the FCC ruled in the last year or so that if you also have to place some type of sticker on the phone so that the end user who uses the phone knows 911 is not available when you move it rather than just the person who ordered the phones.

So the decision is not your customer's, but yours. If you choose to allow the customer to move their phone then you either have to place a sticker on the phone stating that 911 service will not be available to the customer OR you have to provide the customer with a way to change their address information when they do move the phone. While you could offer either option to customers based on how much they wanted to pay, I would think liability wise it would be better if you either offered it to everyone or no one at all because it would be too easy for one of your employees to make a mistake in setting someone up and not put them on the right plan.

Mary Lou Carey

BackUP Telecom Consulting

marylou at backuptelecom.com <mailto:marylou at backuptelecom.com>

Office: 615-791-9969 x 2001 <tel:615-791-9969%20x%202001>

*From:*voiceops-bounces at voiceops.org <mailto: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 9:51 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 <tel:602-889-3003>

--

Carlos Alvarez

TelEvolve

602-889-3003

_______________________________________________

VoiceOps mailing list

VoiceOps at voiceops.org <mailto:VoiceOps at voiceops.org>

https://puck.nether.net/mailman/listinfo/voiceops

On Fri, Jan 18, 2013 at 12:16 PM, Joshua Goldbard <j at 2600hz.com> wrote:

We run our e911 through a service as well but price per location as opposed to per phone. We've also found that, if possible, binding the e911 to a did is preferable to device binding.

We price per location also. The extension binding versus device binding is confusing to me; don't you give a customer the same DID to ring all of their devices? That's what we do, so the home phone and office ring concurrently. -- Carlos Alvarez TelEvolve 602-889-3003

On Fri, Jan 18, 2013 at 12:46 PM, Joshua Goldbard <j at 2600hz.com> wrote:

Yeah, but you're talking about inbound.

In many corporate environments, the outbound caller ID is uniform for a location (and even if it's not, most systems support uniform caller ID for emergencies). E911 is an outbound service and the inbound and outbound caller IDs can certainly be different.

Does that help clarify my viewpoint?

Ah, yes. We very rarely get anyone who wants to do that, so it didn't cross my mind. We do have special 911 CLID/DID settings and special processing for those calls. However we bind them to a device, since the device is what has location, in most of our installations. -- Carlos Alvarez TelEvolve 602-889-3003

Nathan, CLID as it applies to the PSTN is inherently outbound. That being said, a number of switches (PBXs) have the capability of modifying the caller ID of a user. You see this with internal Caller IDs and external caller ID (extension versus CNAM). Some providers (2600hz included) have introduced a third caller ID classification: emergency. Let me give you a practical example. My Internal Caller ID is: 7923 (THE MARKETING GUY) My external Caller ID is: 415.886.7923 2600hz My emergency Caller ID is: 415.886.7900 2600hz ($Address) The purpose here is to take our block of 100 DIDs and only support emergency services in a single uniform fashion. We can override this on a user by user or per-device basis, but the point is to simplify emergency calling. Does that help clarify what we're doing? Cheers, Joshua P.S. I previously sent this email only to Nathan. Adding voiceops onto the chain just in case there's interest. Joshua Goldbard VP of Marketing, 2600hz 116 Natoma Street, Floor 2 San Francisco, CA, 94104 415.886.7923 | j at 2600hz.com<mailto:j at 2600hz.com> [cid:A04A0B25-B1C5-459F-BDCE-0E90D89EA979 at 2600hz.com] On Jan 18, 2013, at 1:04 PM, Nathan Anderson <nathana at fsr.com<mailto:nathana at fsr.com>> wrote: I'm confused, and I apologize to those who have already been involved in this discussion thread for a while since I am just now jumping in. CLID is inherently outbound, so I am not sure what you mean by "inbound vs. outbound caller IDs". Perhaps by "inbound CLID" you mean DID, or DNIS? I'm also not sure how you propose to bind E911 details to a device instead of a telephone number. The few E911 services I've looked at all only give you the option to provision E911 information via TN. So if you propose a set-up such as what is being discussed here, where each company phone only has an internal extension # and no DID, and CLID is uniformly set to a single number for all outbound calls from any phone whether it is located in the office building or at an employee's residence, then there can only be a single E911 address for all of those phones. That seems inescapable. Are you saying that there are E911 companies that can provision differently, and not use the CLID as the "key" to looking up an address? What do they use/how do they work, and can you name some names? The only other kludgey workaround I can think of that might pass muster would be to assign unique "throwaway" TNs to each individual extension that you would use as the CLID for outbound from that extension *only* when 911 is dialed, and continue to use the global office TN as CLID across all extensions for all other outbound calls. It's not a perfect solution, since if the individuals using those phones have no clue about those numbers, they might get confused when asked to verify their own telephone number by the PSAP and the dispatcher reads some number back to them that isn't their main office number. At that point, you might as well let the customer know that these numbers exist and give them the option of using them as DIDs for the extensions/devices they've been assigned to. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com<mailto:nathana at fsr.com> -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 11:49 AM To: Joshua Goldbard Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home On Fri, Jan 18, 2013 at 12:46 PM, Joshua Goldbard <j at 2600hz.com> wrote: Yeah, but you're talking about inbound. In many corporate environments, the outbound caller ID is uniform for a location (and even if it's not, most systems support uniform caller ID for emergencies). E911 is an outbound service and the inbound and outbound caller IDs can certainly be different. Does that help clarify my viewpoint? Ah, yes. We very rarely get anyone who wants to do that, so it didn't cross my mind. We do have special 911 CLID/DID settings and special processing for those calls. However we bind them to a device, since the device is what has location, in most of our installations. -- Carlos Alvarez TelEvolve 602-889-3003 _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Great questions :). So since we can override on a per device basis, you'll notice that I didn't put an actual address, I put ($Address). This is an important distinction. Suppose we could sense a users physical position (IE via GPS on their SIP-enabled smartphone). We could then insert the lat-long and approximate address instead of transmitting the HQ address. In practice, most users will set their office devices to default to the HQ Emergency info, but on their home devices, they can set a different address (typically tied to their direct DID instead of the main number). I don't believe you can send an address in real-time to a 911 service (if I'm wrong I'd be thrilled to learn of one). It's always a db lookup, which sort of negates the idea I proposed in my previous paragraph. In short, 911 is complex, antiquated and difficult. Even though we could EASILY provide live lat-long and address information to e911 the infrastructure isn't setup to support it and I think we're in agreement on this point. BTW, It's also not kludgey if I know the difference between a direct dial and a main number (which I'd wager most people do since it's printed on most business cards). Cheers, Joshua Joshua Goldbard VP of Marketing, 2600hz 116 Natoma Street, Floor 2 San Francisco, CA, 94104 415.886.7923 | j at 2600hz.com<mailto:j at 2600hz.com> [cid:A04A0B25-B1C5-459F-BDCE-0E90D89EA979 at 2600hz.com] On Jan 18, 2013, at 2:13 PM, Nathan Anderson <nathana at fsr.com<mailto:nathana at fsr.com>> wrote: Kinda/sorta. So you are doing (in essence) what I proposed in my last paragraph: transmitting a different CLID to the PSAP than you transmit to all other called parties for that station. The thing is that this doesn't seem to solve the original poster's problem. In your example, the station in question has a DID: 415-886-7923, and it (presumably) uses that DID for all external outbound calls, but uses the main switchboard number as the CLID when dialing emergency services (911). That works great if all of the stations are at the same address as what is provisioned in E911 for the switchboard number. If that station isn't at that address, I take it your solution is to "override" this so that the emergency CLID matches the external CLID, and then to provision that DID in E911 with the right address. The way I understood it, though, the original question dealt with a scenario like this: My internal Caller ID is: 330 (THE MARKETING GUY) My external Caller ID is: 415.886.7900 (no DID! You call the switchboard and ask for 330.) My emergency Caller ID is: 415.886.7900 ...so the company in question -- for whatever reason, I presume they have a good one and it's not my position to ask or judge -- does not hand out DIDs to stations and wants all outbound calls to look like they are coming from HQ regardless, and station 330 is physically at MARKETING GUY's residence (since he telecommutes), not company HQ. So, the question is, how do you transmit the correct address to the dispatcher for MARKETING GUY's residence in this scenario, instead of company HQ's address? My proposed solution was this: My internal Caller ID is: 330 (THE MARKETING GUY) My external Caller ID is: 415.886.7900 (no DID! You call the switchboard and ask for 330.) My emergency Caller ID is: 415.886.7923 ("throwaway" number) ...then you provision the dude's residential address on the 7923 number. But MARKETING GUY has no clue that this number exists, and in fact dialing that number will not lead you to his station, thus the "throwaway" label. (In addition to confusing MARKETING GUY when PSAP asks him if he is calling from 7923, if the call drops and PSAP tries to get hold of him again, that will fail. Another reason why this kludgey solution is not great.) This is all predicated on the notion that the only way that most E911 services work is by binding an address to a telephone number in a database on their end. Are there any E911 providers that you can transmit an address to in the call signalling, in real-time during call set-up? That would solve the problem entirely. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com<mailto:nathana at fsr.com> -----Original Message----- From: Joshua Goldbard [mailto:j at 2600hz.com] Sent: Friday, January 18, 2013 1:47 PM To: Nathan Anderson Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home Nathan, CLID as it applies to the PSTN is inherently outbound. That being said, a number of switches (PBXs) have the capability of modifying the caller ID of a user. You see this with internal Caller IDs and external caller ID (extension versus CNAM). Some providers (2600hz included) have introduced a third caller ID classification: emergency. Let me give you a practical example. My Internal Caller ID is: 7923 (THE MARKETING GUY) My external Caller ID is: 415.886.7923 2600hz My emergency Caller ID is: 415.886.7900 2600hz ($Address) The purpose here is to take our block of 100 DIDs and only support emergency services in a single uniform fashion. We can override this on a user by user or per-device basis, but the point is to simplify emergency calling. Does that help clarify what we're doing? Cheers, Joshua P.S. I previously sent this email only to Nathan. Adding voiceops onto the chain just in case there's interest. Joshua Goldbard VP of Marketing, 2600hz 116 Natoma Street, Floor 2 San Francisco, CA, 94104 415.886.7923 | j at 2600hz.com On Jan 18, 2013, at 1:04 PM, Nathan Anderson <nathana at fsr.com> wrote: I'm confused, and I apologize to those who have already been involved in this discussion thread for a while since I am just now jumping in. CLID is inherently outbound, so I am not sure what you mean by "inbound vs. outbound caller IDs". Perhaps by "inbound CLID" you mean DID, or DNIS? I'm also not sure how you propose to bind E911 details to a device instead of a telephone number. The few E911 services I've looked at all only give you the option to provision E911 information via TN. So if you propose a set-up such as what is being discussed here, where each company phone only has an internal extension # and no DID, and CLID is uniformly set to a single number for all outbound calls from any phone whether it is located in the office building or at an employee's residence, then there can only be a single E911 address for all of those phones. That seems inescapable. Are you saying that there are E911 companies that can provision differently, and not use the CLID as the "key" to looking up an address? What do they use/how do they work, and can you name some names? The only other kludgey workaround I can think of that might pass muster would be to assign unique "throwaway" TNs to each individual extension that you would use as the CLID for outbound from that extension *only* when 911 is dialed, and continue to use the global office TN as CLID across all extensions for all other outbound calls. It's not a perfect solution, since if the individuals using those phones have no clue about those numbers, they might get confused when asked to verify their own telephone number by the PSAP and the dispatcher reads some number back to them that isn't their main office number. At that point, you might as well let the customer know that these numbers exist and give them the option of using them as DIDs for the extensions/devices they've been assigned to. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 11:49 AM To: Joshua Goldbard Cc: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home On Fri, Jan 18, 2013 at 12:46 PM, Joshua Goldbard <j at 2600hz.com> wrote: Yeah, but you're talking about inbound. In many corporate environments, the outbound caller ID is uniform for a location (and even if it's not, most systems support uniform caller ID for emergencies). E911 is an outbound service and the inbound and outbound caller IDs can certainly be different. Does that help clarify my viewpoint? Ah, yes. We very rarely get anyone who wants to do that, so it didn't cross my mind. We do have special 911 CLID/DID settings and special processing for those calls. However we bind them to a device, since the device is what has location, in most of our installations. -- Carlos Alvarez TelEvolve 602-889-3003 _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

If you're not using DIDs, I think you are out of luck. I don't know of any way around this :/ (if anyone has a better solution or knowledge of a live-update provider, let me know). I WOULD LOVE for someone to innovate e911, but I suspect there's a lot of regulatory reasons preventing modernization of those systems. That's a startup that could probably get funding too since it's a profitable problem that everyone on this list suffers from. Cheers, Joshua Joshua Goldbard VP of Marketing, 2600hz 116 Natoma Street, Floor 2 San Francisco, CA, 94104 415.886.7923 | j at 2600hz.com<mailto:j at 2600hz.com> [cid:A04A0B25-B1C5-459F-BDCE-0E90D89EA979 at 2600hz.com] On Jan 18, 2013, at 3:17 PM, Nathan Anderson <nathana at fsr.com<mailto:nathana at fsr.com>> wrote: On Friday, January 18, 2013 2:27 PM, Joshua Goldbard <mailto:j at 2600hz.com> wrote: Great questions :). So since we can override on a per device basis, you'll notice that I didn't put an actual address, I put ($Address). This is an important distinction. Suppose we could sense a users physical position [...] Right, but as you readily admitted later, you're speaking in hypotheticals here, while the problem that the OP put forth is a very real problem that exists today and which I still have not heard a good proposed solution for. As far as I know (and your reply does not seem to contradict this), you cannot have 2 different devices at 2 different physical locations both transmit the same CLID to the PSAP but have the PSAP receive a different address for each; it's not possible to override the address on a per-device basis, only on a per-TN basis. If you're using DIDs, then great! Problem solved. But if you're not, what is the solution? That was specifically the OP's question. In this scenario, there are no DIDs, only one main switchboard number and a bunch of internal extension #s. Can a different address somehow be bound to one of the devices, even if there is only 1 phone number shared amongst all of them? If the E911 service cannot identify devices in their database on some basis other than by telephone number (MAC address, maybe? transmitted in a custom SIP field?), I don't see how that is possible given the nature of today's systems, as Mr. Blenke explained. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com<mailto:nathana at fsr.com>

On Friday, January 18, 2013 4:12 PM, Jay Hennigan <> wrote: [snip] I like this. Now we merely need the lawyers to sign off. :-) -- Nathan Anderson First Step Internet, LLC nathana at fsr.com

On 1/18/13 3:17 PM, Nathan Anderson wrote:

That was specifically the OP's question. In this scenario, there are no DIDs, only one main switchboard number and a bunch of internal extension #s. Can a different address somehow be bound to one of the devices, even if there is only 1 phone number shared amongst all of them? If the E911 service cannot identify devices in their database on some basis other than by telephone number (MAC address, maybe? transmitted in a custom SIP field?), I don't see how that is possible given the nature of today's systems, as Mr. Blenke explained.

From a practical standpoint, how does this differ from the scenario of a legacy TDM PBX with old-school OPX leased lines? What, if any, are the 9-1-1 requirements there?

-- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV

The difference here is the demarcation point. If you're handing off analog lines, there are two important differences: 1. You're not providing the PBX functionality as part of the telephone service and, 2. You're using a technology that is incapable of sending a different ANI than what's in your switch for each line. So the requirement here is that the e911 ALI address must match the physical location where you have those lines installed. If you are looking to protect yourself from the customer moving to a new location, ATA, PBX and all, you just use a contract provision requiring them to notify you of address changes. You could also require them to have you move the service to the new location for more security there. So, different animal that the hosted PBX question... 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 Nathan Anderson Sent: Friday, January 18, 2013 6:32 PM To: 'Jay Hennigan'; 'voiceops at voiceops.org' Subject: Re: [VoiceOps] 911 address policy for company phones at home On Friday, January 18, 2013 3:28 PM, Jay Hennigan <> wrote:

From a practical standpoint, how does this differ from the scenario of a legacy TDM PBX with old-school OPX leased lines? What, if any, are the 9-1-1 requirements there?

*Great* question. Would love to know the answer myself, too. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

On Fri, Jan 18, 2013 at 5:33 PM, Jay Hennigan <jay at west.net> wrote:

But there are no "lines" for DID-less extensions or for that matter an "installation" in the case of softphones.

But it's trivial for any VoIP system to add a DID to a device. Therefore would the FCC or a lawyer in a civil suit argue that there was no technological impediment to you providing proper e911 service? The FCC says that customers can't opt out of 911 service, would they also claim that they can't opt out of a DID and address service for remote phones? -- Carlos Alvarez TelEvolve 602-889-3003

On Fri, Jan 18, 2013 at 5:53 PM, Jay Ashworth <jra at baylink.com> wrote:

It is like hell. DID's are a limited and costly resource. If your PBX is properly engineered for your load with 2 PRIs and 25 DIDs, and you have 4000 extensions, they're going to make you pay the monthly cost of 4000 extra DIDs for this?

You have 4000 remote extensions? Also you are supporting 4000 extensions with only 46 lines?? DIDs cost less than the cost of providing 911 through most 911 specialists. They make you pay that, so... -- Carlos Alvarez TelEvolve 602-889-3003

Does the FCC narrative specifically parameterise the 911 requirement in terms of end-users? What about wholesale VoIP orig+term providers? -- Alex Balashov - Principal Evariste Systems LLC 235 E Ponce de Leon Ave Suite 106 Decatur, GA 30030 United States Tel: +1-678-954-0670 Web: http://www.evaristesys.com/, http://www.alexbalashov.com/

!!! Thanks for this. Very interesting. Perhaps I should be asking my E911 provider if they plan to have VPC capability any time soon, or even consider a switch to 911Enable. -- Nathan -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Frank Bulk Sent: Saturday, January 19, 2013 5:10 PM To: 'Mary Lou Carey'; 'Jay Hennigan'; 'VoiceOps' Subject: Re: [VoiceOps] 911 address policy for company phones at home It looks like there are vendors that make it possible for PSAPs to access near-realtime info: http://www1.911enable.com/resource-center/faq (see "What is a VoIP Positioning Center?") Frank -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Mary Lou Carey Sent: Saturday, January 19, 2013 8:17 AM To: 'Jay Hennigan'; 'VoiceOps' Subject: Re: [VoiceOps] 911 address policy for company phones at home PBXs can associate a single line for one location or have multiple lines, one for each location so that there is an address in the ALI database for each location. These lines are all fixed though so it's very different from VOIP because the end user can move their phone to any location that has internet access and use it without the switch being re-programmed. That's why there is a requirement for the CLEC to offer a way for the customer to update their information in the ALI database themselves. Someone asked me about who provides the VOIP ALI update solution and I couldn't find a provider, but in researching it I did find that there appears to be an issue with this method because the ALI database doesn't update in real time and since users could plug their phone in and update the address, it didn't mean that the ALI database identified the location correctly. YMAX commented to the FCC in November 2011 (see the link below) that they had a solution that could work. It involved attaching a GSM cellular transceiver to their MagicJack device so the location could be identified but it also relied on having some type of database with customer locations to help it identify which PSAP needed to be contacted so it doesn't appear that is totally thought out either. It appears to me that even though there are some requirements that the FCC put out about updating the ALI database, the details of exactly how that will work aren't totally worked out because of the issue with the ALI database. To me......that seems like a great business opportunity for someone! If you could figure out how to get a VOIP phone to automatically identify the exact location of the phone whenever its plugged in and transmit that location to a VOIP ALI database (which you'd need to create), then you could sell the service to both PSAPs AND VOIP providers! http://apps.fcc.gov/ecfs/document/view;jsessionid=c1M1QZvLvW9XfyYDpTwlMGN1QK T7yhs21npc4ThYvwR61R6JK4yv!-56284754!-224088840?id=7021744691 Mary Lou Carey BackUP Telecom Consulting marylou at backuptelecom.com Office: 615-791-9969 x 2001 -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Jay Hennigan Sent: Friday, January 18, 2013 6:33 PM To: VoiceOps Subject: Re: [VoiceOps] 911 address policy for company phones at home On 1/18/13 3:46 PM, Mike Ray wrote:

The difference here is the demarcation point. If you're handing off analog lines, there are two important differences:

1. You're not providing the PBX functionality as part of the telephone service and, 2. You're using a technology that is incapable of sending a different ANI than what's in your switch for each line.

An extension-only SIP phone doesn't have a unique ANI.

So the requirement here is that the e911 ALI address must match the physical location where you have those lines installed.

But there are no "lines" for DID-less extensions or for that matter an "installation" in the case of softphones. The company HQ where the main ANI is answered is the ALI address. Call it and talk to the receptionist. Drive there in a police car and visit the same receptionist.

If you are looking to protect yourself from the customer moving to a new location, ATA, PBX and all, you just use a contract provision requiring them to notify you of address changes. You could also require them to have you move the service to the new location for more security there.

Yes, and you should.

So, different animal that the hosted PBX question...

ATA, PBX and all is indeed a different animal than an extension-only remote phone. The problem, and I don't know if there is a full solution, is that PSTN telephone numbers have always been used to identify the destination of a call. 9-1-1 assumes that this identifier of a destination positively and unequivocally also identifies the origin. Think in terms of laptops with softphones. There is no way to make that work with the present 9-1-1 infrastructure. -- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV _______________________________________________ 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 _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

Thanks Frank....good to know! I'm sure I just wasn't searching with the right key words to find that. I wonder if they offer it as a stand alone product or you can only get it when you sign up for their VOIP 911 service. Mary Lou Carey BackUP Telecom Consulting marylou at backuptelecom.com Office: 615-791-9969 x 2001 -----Original Message----- From: Frank Bulk [mailto:frnkblk at iname.com] Sent: Saturday, January 19, 2013 7:10 PM To: 'Mary Lou Carey'; 'Jay Hennigan'; 'VoiceOps' Subject: RE: [VoiceOps] 911 address policy for company phones at home It looks like there are vendors that make it possible for PSAPs to access near-realtime info: http://www1.911enable.com/resource-center/faq (see "What is a VoIP Positioning Center?") Frank -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Mary Lou Carey Sent: Saturday, January 19, 2013 8:17 AM To: 'Jay Hennigan'; 'VoiceOps' Subject: Re: [VoiceOps] 911 address policy for company phones at home PBXs can associate a single line for one location or have multiple lines, one for each location so that there is an address in the ALI database for each location. These lines are all fixed though so it's very different from VOIP because the end user can move their phone to any location that has internet access and use it without the switch being re-programmed. That's why there is a requirement for the CLEC to offer a way for the customer to update their information in the ALI database themselves. Someone asked me about who provides the VOIP ALI update solution and I couldn't find a provider, but in researching it I did find that there appears to be an issue with this method because the ALI database doesn't update in real time and since users could plug their phone in and update the address, it didn't mean that the ALI database identified the location correctly. YMAX commented to the FCC in November 2011 (see the link below) that they had a solution that could work. It involved attaching a GSM cellular transceiver to their MagicJack device so the location could be identified but it also relied on having some type of database with customer locations to help it identify which PSAP needed to be contacted so it doesn't appear that is totally thought out either. It appears to me that even though there are some requirements that the FCC put out about updating the ALI database, the details of exactly how that will work aren't totally worked out because of the issue with the ALI database. To me......that seems like a great business opportunity for someone! If you could figure out how to get a VOIP phone to automatically identify the exact location of the phone whenever its plugged in and transmit that location to a VOIP ALI database (which you'd need to create), then you could sell the service to both PSAPs AND VOIP providers! http://apps.fcc.gov/ecfs/document/view;jsessionid=c1M1QZvLvW9XfyYDpTwlMGN1QK T7yhs21npc4ThYvwR61R6JK4yv!-56284754!-224088840?id=7021744691 Mary Lou Carey BackUP Telecom Consulting marylou at backuptelecom.com Office: 615-791-9969 x 2001 -----Original Message----- From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Jay Hennigan Sent: Friday, January 18, 2013 6:33 PM To: VoiceOps Subject: Re: [VoiceOps] 911 address policy for company phones at home On 1/18/13 3:46 PM, Mike Ray wrote:

The difference here is the demarcation point. If you're handing off analog lines, there are two important differences:

1. You're not providing the PBX functionality as part of the telephone service and, 2. You're using a technology that is incapable of sending a different ANI than what's in your switch for each line.

An extension-only SIP phone doesn't have a unique ANI.

So the requirement here is that the e911 ALI address must match the physical location where you have those lines installed.

But there are no "lines" for DID-less extensions or for that matter an "installation" in the case of softphones. The company HQ where the main ANI is answered is the ALI address. Call it and talk to the receptionist. Drive there in a police car and visit the same receptionist.

If you are looking to protect yourself from the customer moving to a new location, ATA, PBX and all, you just use a contract provision requiring them to notify you of address changes. You could also require them to have you move the service to the new location for more security there.

Yes, and you should.

So, different animal that the hosted PBX question...

ATA, PBX and all is indeed a different animal than an extension-only remote phone. The problem, and I don't know if there is a full solution, is that PSTN telephone numbers have always been used to identify the destination of a call. 9-1-1 assumes that this identifier of a destination positively and unequivocally also identifies the origin. Think in terms of laptops with softphones. There is no way to make that work with the present 9-1-1 infrastructure. -- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV _______________________________________________ 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

On 1/18/13 2:13 PM, Nathan Anderson wrote:

So, the question is, how do you transmit the correct address to the dispatcher for MARKETING GUY's residence in this scenario, instead of company HQ's address? My proposed solution was this:

My internal Caller ID is: 330 (THE MARKETING GUY) My external Caller ID is: 415.886.7900 (no DID! You call the switchboard and ask for 330.) My emergency Caller ID is: 415.886.7923 ("throwaway" number)

...then you provision the dude's residential address on the 7923 number. But MARKETING GUY has no clue that this number exists, and in fact dialing that number will not lead you to his station, thus the "throwaway" label. (In addition to confusing MARKETING GUY when PSAP asks him if he is calling from 7923, if the call drops and PSAP tries to get hold of him again, that will fail. Another reason why this kludgey solution is not great.)

And, in the real world, if MARKETING GUY's house isn't in a San Francisco suburb but in Kansas, what will the PSAP there do when you present it with an ANI of 415.886.7923? Will the 316 NPA selective router even process the call? And if it does correctly route to the Wichita PSAP and the dispatcher sees a 415 NPA on a fixed address (not cellular) call, what will they think is going on? Alternatively, does the VoIP carrier need to get a single local DID in an area far removed from his service area (and deal with some remote state's regulatory and tax administrivia and expense) just to have something that 9-1-1 can handle? Keep in mind that the number has to be dialable so that the PSAP can call back. -- Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net Impulse Internet Service - http://www.impulse.net/ Your local telephone and internet company - 805 884-6323 - WB6RDV

Before I get into my reply, I will point out that the OP is inquiring about this stuff specifically as it regards *extensions on a PBX which his company hosts as a vendor to/agent of the end user whose employees' phones are in question here. I think that materially affects the answers, but IANAL. Anyway... ----- Original Message -----

From: "Nathan Anderson" <nathana at fsr.com>

I'm also not sure how you propose to bind E911 details to a device instead of a telephone number. The few E911 services I've looked at all only give you the option to provision E911 information via TN. So if you propose a set-up such as what is being discussed here, where each company phone only has an internal extension # and no DID, and CLID is uniformly set to a single number for all outbound calls from any phone whether it is located in the office building or at an employee's residence, then there can only be a single E911 address for all of those phones.

And indeed, there used to be such an exemption for office PBX type installations; I do not remember whether it's expired, but I think so. There was quite a bit of third party activity in the "patching around your PBX to send remote extension building locations to the PSAP" space at the time...

The only other kludgey workaround I can think of that might pass muster would be to assign unique "throwaway" TNs to each individual extension that you would use as the CLID for outbound from that extension *only* when 911 is dialed, and continue to use the global office TN as CLID across all extensions for all other outbound calls. It's not a perfect solution, since if the individuals using those phones have no clue about those numbers, they might get confused when asked to verify their own telephone number by the PSAP and the dispatcher reads some number back to them that isn't their main office number. At that point, you might as well let the customer know that these numbers exist and give them the option of using them as DIDs for the extensions/devices they've been assigned to.

The "Emergency CNID", yes; FreePBX has this, and can be taught what are emergency calls; when it recognizes one, it sends a different CNID out on the "trunk". I believe that PSAPs have a protocol for dealing with this sort of situation, where a note can be put in the LIDB saying that this ANI is at a physical location and the phone may be labeled with a different number, but I am not a PSAP operator, so I might be wrong on this. Cheers, -- jra -- Jay R. Ashworth Baylink jra at baylink.com Designer The Things I Think RFC 2100 Ashworth & Associates http://baylink.pitas.com 2000 Land Rover DII St Petersburg FL USA #natog +1 727 647 1274

On Friday, January 18, 2013 3:15 PM, Carlos Alvarez <mailto:carlos at televolve.com> wrote:

We use a third party to support 911 for us, and they take care of the network details based on the CLID we deliver on a specific call. They route to a local PSAP according to the address we've put in their system, not the NPA-NXX of the CLID.

Yep, that's exactly how ours works as well.

In our system, we have two variables for each SIP device; the e911 provider and the e911 CLID/ANI. So on the system side we have granularity down to the device if desired.

Yes, but again, that doesn't help with the question of what to do if a single TN for CLID purposes is shared amongst many devices, which is what I took your original question to be. The E911 provider will look at the CLID and transmit the address provisioned for it, so in this scenario, there can only be 1 address for all of these devices because there is only 1 TN for all of these devices. There's no mechanism to identify a device *other* than by TN, so if you share a TN between devices, there is no way to achieve the 911 granularity that you want for your customers that choose to operate like this. -- Nathan Anderson First Step Internet, LLC nathana at fsr.com

If you currently provide the roaming 911 service and the customer is balking about paying for it, I think I would just tell them that you are legally required to provide 911 service to your customers and you're not willing to accept waivers for 911 when end users move their phones because it is a liability issue for you. If they want to take on the liability of choosing to not provide 911 service to their employees when they bring their phone home, then they can go look for a provider who will allow them to do that. While they may be able to find a provider to do that, they have to realize that the decision to change providers so they don't have to pay an additional 911 fee when their employees bring their phones home opens them up for a lawsuit should anything happen when an employee tries to use their VOIP phone to dial 911 from home. The waiver may be appealing in the short run because it can save you money, but chances are its really not going to be worth it in the long run. If you think about it, when something bad happens and your end user needs to dial 911 they are not going to remember that phone doesn't display their address accurately. They are going to pick up the first phone they see because they are in a heightened state of alert and common sense usually goes out the window in those moments! The reason doctor's offices always put have a recording on their voicemails stating to that if you have a life threatening emergency to call 911 is because people don't think straight when disaster strikes and they frequently call the doctor's office when they should be heading for the ER! Mary Lou Carey BackUP Telecom Consulting marylou at backuptelecom.com Office: 615-791-9969 x 2001 From: voiceops-bounces at voiceops.org [mailto:voiceops-bounces at voiceops.org] On Behalf Of Carlos Alvarez Sent: Friday, January 18, 2013 5:41 PM To: voiceops at voiceops.org Subject: Re: [VoiceOps] 911 address policy for company phones at home On Fri, Jan 18, 2013 at 4:38 PM, Nathan Anderson <nathana at fsr.com> wrote: Yes, but again, that doesn't help with the question of what to do if a single TN for CLID purposes is shared amongst many devices, which is what I took your original question to be. The E911 provider will look at the CLID and transmit the address provisioned for it, so in this scenario, there can only be 1 address for all of these devices because there is only 1 TN for all of these devices. There's no mechanism to identify a device *other* than by TN, so if you share a TN between devices, there is no way to achieve the 911 granularity that you want for your customers that choose to operate like this. Well the question was what to tell a customer who refuses to pay for the costs we incur in implementing the solution for them. On a technological level we have no problem; we assign a DID to that device, and put the appropriate address on it. We bill the customer for it to cover costs. The customer just says they don't want to pay. -- Carlos Alvarez TelEvolve 602-889-3003

On Fri, Jan 18, 2013 at 5:59 PM, Mary Lou Carey <marylou at backuptelecom.com>wrote:

If you currently provide the roaming 911 service and the customer is balking about paying for it, I think I would just tell them that you are legally required to provide 911 service to your customers and you're not willing to accept waivers for 911 when end users move their phones

From a customer relation perspective we've informed them that waivers are not allowed, and that if we know they plan to have remote phones we can't let them do it without the 911 service for each phone. They disagree with our interpretation of the FCC requirement applying to remote phones, but so be it.

As a company we are drafting a policy saying that we will tell customers they are required to notify us if they move a phone, and get the 911 service. If we casually notice that a phone has been moved, we will notify the customer that they need to have the 911 service. We do not actively monitor location/movement of a phone. Anyone who can't afford $1 per address to have this service isn't a good customer. -- Carlos Alvarez TelEvolve 602-889-3003