[cisco-voip] Need some facts regarding DID's, Enterprise VoIP and LATAs

[Dark Fiber]

In the last couple of weeks I have been dealing with e911/911 issues
internally at work.  In trying to resolve and provide the best possible
solution for 911 calling to all employees throughout the region I ended
having to pull in our legal and regulatory folks to address some of these
issues and what they felt we needed to provide at a minimum to our
employees, so that we make sure we are completely covered.

In doing so I begin to layout the network and phone system for them
explaining what we have and where we are going and such.  Upon seeing this
the regulatory folk begin telling me that this is wrong / illegal.
Basically saying that the way we have deployed phones and Call Manager and
such is wrong and needs to be corrected.  I was seriously taken aback by
this, never did I question our phone deployment if you will, I mean heck
this meeting was about 911 you know.

The first thing they tell me is that DID's are for internal calling / usage,
and not meant for external or incoming calling?  I was like blown away, this
is completely OPPOSITE of what I have always thought and known.  DID's are
direct inward dialing, you can 100 DID's if you will on a PRI from your
service provider and assign them to individuals internally so that users can
have a direct inward number from the outside.  Heck even wikipedia "which I
know is not the end all source of all knowledge" but fairly reliable states
exactly what I have always known DID's as.

Next they begin telling me I have to get circuits and DID's / numbers that
correspond to each of my physical locations!

Basically, right now we have various small locations spread out in different
cities.  Say as an example Houston, Dallas and San Antonio.  Main office say
is Dallas, my call managers and gateways are there in Dallas.  I get PRI's
to terminate there and I have a large block of DID's all for Dallas.

All ip phones are setup with four digit extension, and are tied to a DID
from Dallas even though the phone and user may be in Houston or something.
User in Houston places a call it goes out of Dallas, and incoming calls
obviously go into Dallas then over our fiber to Houston.  Blah blah, nothing
new there I know alot of places that do the same thing.

Anyway, so they tell me I can't do this.  That legally I have to get
circuits in each market, and provide those users numbers in that market.

I just don't buy this.  I mean the past three employees I have been at and
managed the call managers they all had similar setups and I am not the one
who set them up so I know I was not the only one who believed it was
perfectly acceptable to do things this way.

I would love some facts to use to show that it is perfectly acceptable to do
this.  I can't find anything from a legal perspective to substantiate what
they said or what I believe.

I even pointed out VoIP providers like Vonage and stuff, and said if it was
illegal to do then don't you think these companies that base their business
on just that sort of thing would exist?  That's one of the main selling
points you can get a number from any market in the US pretty much no matter
where you live.  Of course their answer was they are regulated differently.
And who knows maybe so.

Any thoughts or arguments out there on this?  Would love to be able to point
to some law or case or something regarding this rather then just thoughts
and examples since they would have more weight for me to prove my point.
But I would love to hear anything at this point.
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