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

Thu Aug 2 19:06:28 EDT 2007

There is a regulatory battle going on about this between State Public 
Service Commisions and the FCC.  I have not found the FCC to state 
specifically what you are doing with your DID's is wrong but your State 
Public Service Commision may say something different. Minnesota PSC sued 
Vonage about this typeof issue but they lost. The court ruled that the 
feds have jusridiction. The Feds are concerned primarilly with 911 and 
CALEA wich is basically law enforcements ability to wire tap. If your 
legal dept can point to specific laws saying what you are doing with the 
did's is wrong I would like to see that and if they are state laws or 
Federal. 

"Mark Holloway" <mh at markholloway.com> 
Sent by: cisco-voip-bounces at puck.nether.net
08/02/2007 04:52 PM

To
"'Dark Fiber'" <d4rkf1ber at gmail.com>
cc
cisco-voip at puck.nether.net
Subject
Re: [cisco-voip] Need some facts regarding DID's,       Enterprise VoIP 
and LATAs

Out of rate center numbers are considered ?dirty? and if your phone 
company that you?re getting the TN?s from knew, they might make a big deal 
about it. 

From: techguy at gmail.com [mailto:techguy at gmail.com] On Behalf Of Dark Fiber
Sent: Thursday, August 02, 2007 2:34 PM
To: Mark Holloway
Cc: cisco-voip at puck.nether.net
Subject: Re: [cisco-voip] Need some facts regarding DID's, Enterprise VoIP 
and LATAs

Actually 911 is not the issue, we do have local gateways with a couple of 
pstn lines at each location strictly for 911.  So if someone in Houston 
calls 911 it routes out the local gateway to reach the right psap.

Appreciate the response though.

On 8/2/07, Mark Holloway <mh at markholloway.com> wrote: 
Hey man, had to skim through this one quick (busy day at work) but let me 
see if I'm getting this right.  You are assigning DID's from Dallas to 
users in Houston and San Antonio?  Yikes! How are you handling 911 for 
Houston/San Antonio users?  You should have an FXO on Houston's router and 
San Antonio's router with a 911 dial peer that displays a Houston or San 
Antonio TN to their local PSAP.  You are in major FCC violation for not 
providing local 911 access.  If Houston dials 911 and goes to a Dallas 
PSAP, that person is screwed.  That's a major law suit and a major FCC 
violation.  The reason Vonage can do it is they have the ability to give 
you a DID anywhere, but route 911 to your local PSAP.  You definitely need 
some FXO cards and 911 dial peers in each of your remote locations. 

From: cisco-voip-bounces at puck.nether.net [mailto:
cisco-voip-bounces at puck.nether.net] On Behalf Of Dark Fiber
Sent: Thursday, August 02, 2007 11:38 AM
To: cisco-voip at puck.nether.net
Subject: [cisco-voip] Need some facts regarding DID's, Enterprise VoIP and 
LATAs 

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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