[VoiceOps] 911 address policy for company phones at home

[Jay Hennigan]

On 1/18/13 3:26 PM, Joshua Goldbard wrote:
> If you're not using DIDs, I think you are out of luck. I don't know of
> any way around this :/  (if anyone has a better solution or knowledge of
> a live-update provider, let me know).

IANAL, but if there is no DID, one could argue that the phone isn't
connected directly to the PSTN, but is instead an extension of a
(possibly virtual) PBX at company HQ.  You can't call it directly from
the PSTN because it doesn't have a phone number.  If a device doesn't
have a phone number, it doesn't have a unique ANI and its
interconnection to the PSTN is only by virtue of the host (or hosted) PBX.

In the TDM world, the remote phone shows up at the PSAP as the location
of the host PBX.  If the host PBX loses power, the remote extension
can't call 9-1-1 (or anyone) at all.  In the hosted SIP world, it can
still call 9-1-1 even if HQ loses power, but it will continue to show
the location of HQ.

One argument would be that the VoIP provider is in compliance by
registering the HQ location as the "physical location at which the
service will first be used", and informing the customer "prominently and
in plain language, of the circumstances under which 911 service
may not be available through the interconnected VoIP service or may in
some way be limited in comparison to traditional 911 service",
specifically that remote extensions without phone numbers will have
9-1-1 calls routed to the HQ PSAP, and obtaining "affirmative
acknowledgement from all existing customers that they are aware of and
understand the limitations of their 911 service" per the following:

http://transition.fcc.gov/cgb/consumerfacts/voip911.pdf

The 9-1-1 ALI database assumes a one-to-one relationship between a
telephone number and a location.  Off-premise extension telephones
without a full telephone number break this assumption whether they are
connected via copper wire, IP networks, or cans and string.

--
Jay Hennigan - CCIE #7880 - Network Engineering - jay at impulse.net
Impulse Internet Service  -  http://www.impulse.net/
Your local telephone and internet company - 805 884-6323 - WB6RDV