[VoiceOps] 911 address policy for company phones at home

Joshua Goldbard j at 2600hz.com
Fri Jan 18 14:16:08 EST 2013

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.

Just one service providers perspective; e911 is a lot of fun so I'm sure there's a lot of opinion on this topic.


Sent from my iPhone

On Jan 18, 2013, at 10:04 AM, "Carlos Alvarez" <carlos at televolve.com<mailto:carlos at televolve.com>> 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

Carlos Alvarez

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