[VoiceOps] 911 address policy for company phones at home

Fri Jan 18 13:44:15 EST 2013

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Mary Lou is saying, some of which appears to be dangerously out of date.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 <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
>
>
>
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