I haven't read the whole ruling, but so far from our perspective we're still left not knowing what really constitutes an "outage." We have multiple types of connectivity and multiple carriers to connect to. If we lose an origination carrier, for example, that has no impact on emergency calls, but some customers won't receive inbound calls. Is that an outage under this? I can't think of an outage we have had that would prevent a customer dialing 911. But the customers themselves have plenty of internet issues that might cause that. On Wed, Feb 15, 2012 at 9:31 PM, Ujjval Karihaloo <ujjval at simplesignal.com> wrote:

Correct and the VoIP services rely on the Internet backbone in general that causes issues which ITSPs has no control over as well

On Wednesday, February 15, 2012, Bret Palsson <bret at getjive.com> wrote:

...

This is an interesting move. The way I see it, the FCC isn't going to get very good data. Say a VoIP provider has one datacenter, and they have an outage. How will the FCC track who didn't have 911 service at that time? For all they know, the datacenter went down and that location might not have access to 911. What about the potentially hundreds of thousands of endpoints and their location? It makes more sense for wireless and wired operators that have localized towers and central offices. If one of those locations experience an outage, they have a better idea of who doesn't have access to 911, geographically ?speaking. Another scenario: What happens when a customers ISP goes down? It's not the job of the VoIP provider to monitor that connection to say it's down. I really don't think they will get the data they expect with this ruling. The only good data they will get is, provider A has more uptime than provider B. Other opinions? -Bret

On Feb 15, 2012, at 8:38 PM, Ujjval Karihaloo wrote:

What is the impact of this ?

http://news.cnet.com/8301-1023_3-57378872-93/fcc-requires-voip-providers-to-...

Ujjval Karihaloo

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-- Carlos Alvarez TelEvolve 602-889-3003

This might actually put some voip providers feet to the fire, kind of like lec's/clec's have to report to the PUC's when they have major outages, and start handing down fines. Carlos Alcantar Race Communications / Race Team Member 101 Haskins Way, So. San Francisco, CA. 94080 Phone: +1 415 376 3314 / carlos at race.com / http://www.race.com -----Original Message----- From: Justin B Newman <justin at ejtown.org> Date: Thu, 16 Feb 2012 10:21:18 -0600 To: Carlos Alvarez <carlos at televolve.com> Cc: VoiceOps <voiceops at voiceops.org> Subject: Re: [VoiceOps] Reproting VoIP outages FCC ruling On Thu, Feb 16, 2012 at 10:04 AM, Carlos Alvarez <carlos at televolve.com> wrote:

I haven't read the whole ruling, but so far from our perspective we're still left not knowing what really constitutes an "outage." We have

Last I knew they hadn't actually released the order, just a series of statements and press releases. (Helpful to have the press coverage, but not actually answers to any real questions). As of the moment, their web site does not yet appear to include a copy of 12-22. -jbn _______________________________________________ VoiceOps mailing list VoiceOps at voiceops.org https://puck.nether.net/mailman/listinfo/voiceops

On 2/21/2012 2:13 PM, Mark R. Lindsey wrote:

The new outage reporting rules are finally out: http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-12-22A1.pdf

My musings are based on a brief review.

1. 911 Outage Reporting

The most interesting element is the requirement to notify the FCC of any outage involving a 9-1-1 special facility if that outage lasted 30 minutes or more.

It's a 911 outage if for 30 minutes or more, -- Customers can't have a working conversation with 911 -- You can't deliver calling party information accurately -- You don't have working re-route capability

You only have four hours to file a report about one of those outage. So if you have an outage from 1:00am until 1:30am, then you've got until sometime around 5:00am to get it reported.

For ordinary traffic, you now have to report an "outage" that affects 900,000 user minutes of service, as long as that outage lasted 30 minutes or longer.

2. IP Network Outages

But if a VoIP Service Provider accesses its customers through T1s, MPLS, Ethernet, etc., then do outages on those networks constitute reportable outages? In some cases, it appears so.

"Our intention is that non-facilities-based VoIP providers report service outages that meet the threshold to the extent that they have access to information on service outages affecting their customers."

If the VoIP SP actually owns, operates, leases, or otherwise utilizes those links to their customers, then, yes, an outage on an IP network would be considered a reportable outage.

And if the VoIP SP can detect a problem with the networks connected to their customers, then that contributes to the number of user minutes affected. E.g., a Level3 outage might affect 30% of the user population, and we have 50,000 users in the user population, and service was down for 90 minutes, then that's 0.3 * 50000 * 90 = 1,350,000 user minutes. So this would be a reportable outage.

3. Ordinary Outages

If customers can't have working non-911 phone calls for 900,000 user-minutes or more, and it lasts at least 30 minutes, then it appears you have to report it.

4. Example Cases

So how about a SIP trunks to Intrado or Dash that's installed for 911?

What about a SIP trunk that's used for both ordinary calls and for 911?

So how about those MPLS tails from Level3 or XO?

Or how about those T1s you lease from Verizon?

What if they have packet loss great enough to interrupt working RTP flows, but not high enough to prevent SIP registration?

I'm not a lawyer.

I can see it now... Carrier: "Technically, we didn't have an 11 hour outage" Powers that be: "Can you elaborate?" Carrier: "We're not sure 1) which carrier is to blame and 2) why they're really at fault so at this point we can't" Powers that be: "Can you clarify your comment before we impose what is now going to be a bigger fine on your business?" Carrier: "We have multi-homed redundancy from 6 upstream carriers and all were available however, some rebels without a cause using silly masks were DDoSing DNS servers" Powers that be: "What is DDoSing?" Carrier: "They were overwhelming the services enough so that individuals placing real requests were denied legitimate access" Powers that be: "What is a DNS server" Carrier: "DNS servers resolve names to IPs. Our customers weren't able to get to www.MyVoIPIsBetterThanYours.biz but they were able to get to our address at 20x.xxx.xxx.xxx" Powers that be: "Who's responsible for the DNS server" Geeks at the Carrier: "Dan Kaminski!" ;) -- =+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+ J. Oquendo SGFA, SGFE, C|EH, CNDA, CHFI, OSCP, CPT, RWSP, GREM "It takes 20 years to build a reputation and five minutes to ruin it. If you think about that, you'll do things differently." - Warren Buffett 42B0 5A53 6505 6638 44BB 3943 2BF7 D83F 210A 95AF http://pgp.mit.edu:11371/pks/lookup?op=get&search=0x2BF7D83F210A95AF