[VoiceOps] Misrouting 911 Calls?

[Mary Lou Carey]

You shouldn't have needed a number for each extension. You can just 
associate each extension with a dedicated TN for that particular 
building. Any call that comes from that building would be routed to the 
same PSAP. You'd just want to provide the main desk in each building 
with the physical location of each TN within the building so when help 
arrives they know where to go.

What you're describing is actually 2 different issues. The contract 
being up may fix the problem of getting the call to the correct PSAP, 
but it may not fix your address problem. If the location is routed to 
the right PSAP but identifies the wrong building in that PSAP area it's 
still an issue. My guess would be that Comcast had problems getting your 
addresses to validate in the ALI database so they listed the address 
associated with your SIP trunks instead because the system took that. 
What clients may not be aware of is that the address in the ALI database 
(used to identify locations for 911) doesn't always match the address 
that the customer was given by USPS.

The ALI database gets its address options from the MSAG database. The 
MSAG uses whatever the original carrier assigned. If the customer writes 
their address as 123 Main Street, but the MSAG lists it as 123 Main St, 
the address won't validate. It has to match EXACTLY! There are also many 
instances where the street name or abbreviation for the city may be 
different. For example, in my area you can take 50 mile stretch of road 
that goes from Columbia TN all the way up to Nashville. In Columbia they 
call it Nashville Highway. In Spring Hill they call it Main Street. In 
Franklin they call it Columbia Ave, and in Nashville they call it 
Highway 31. Just because the Post Office assigned someone's address as 
Nashville Highway doesn't mean the phone company used the same address. 
They may have listed it as Nashville Highway /Columbia Ave and if you 
don't type it exactly that way, your address won't validate. If your 
address doesn't validate, then you get fined! So even though carriers 
are supposed to give their customers a way to update their address, they 
don't want to give them direct access because the address the customer 
thinks they have may not be the address in the ALI database.

Its crazy that anyone gets the service they need when something as 
simple as an address is SO messed up!


MARY LOU CAREY
BackUP Telecom Consulting
Office: 615-791-9969
Cell: 615-796-1111

On 2022-01-08 05:11 PM, Aaron C. de Bruyn wrote:
> I filed a complaint with the FCC about a year ago.
> The FCC reached out to Comcast and Comcast reached back out to me.
> Their response was that we would basically have to purchase ~200
> numbers (one for each extension on our system), set our outbound 911
> caller ID to those numbers, and then provide Comcast with a list of
> mappings between phone numbers and addresses.
> It would have added a huge tracking burden for IT as well as increased
> our bill by about $2,500 over the contract term.
> 
> It's all moot now as BulkVS cost less than $50 to set up, we've
> already had one successful 911 call from an office that was
> continually misrouted by Comcast, and the contract is up "soon".
> 
> -A
> 
> On Sat, Jan 8, 2022 at 2:37 PM Mary Lou Carey
> <marylou at backuptelecom.com> wrote:
> 
>> I was just going to say the same thing. If you give Comcast or any
>> carrier a chance to fix it and they can't/won't/don't, then you have
>> to
>> escalate it above their heads.
>> 
>> The 911 network has always operated separately from the PSTN world
>> for a
>> reason. That's because misroutes can result in people dying!
>> Carriers
>> can get in HUGE trouble if they don't address routing issues
>> immediately
>> and VOIP carriers can also get in trouble if they don't allow the
>> customer a method of updating their location themselves.
>> 
>> MARY LOU CAREY
>> BackUP Telecom Consulting
>> Office: 615-791-9969
>> Cell: 615-796-1111
>> 
>> On 2022-01-05 09:08 AM, Mike Hammett wrote:
>>> Escalate to the PUC and ETSBs.
>>> 
>>> Unfortunately, with companies like that, honey doesn't work. You
>> need
>>> vinegar.
>>> 
>>> -----
>>> Mike Hammett
>>> Intelligent Computing Solutions
>>> http://www.ics-il.com
>>> 
>>> Midwest Internet Exchange
>>> http://www.midwest-ix.com
>>> 
>>> -------------------------
>>> 
>>> From: "Aaron C. de Bruyn via VoiceOps" <voiceops at voiceops.org>
>>> To: "Paul Timmins" <paul at timmins.net>
>>> Cc: voiceops at voiceops.org
>>> Sent: Tuesday, January 4, 2022 6:07:52 PM
>>> Subject: Re: [VoiceOps] Misrouting 911 Calls?
>>> 
>>> When I handed Comcast a list of phone numbers years ago, they said
>>> there would be no problem porting them over or using them.
>>> That was it.
>>> 
>>> Then after the service was installed, someone mentioned "a few of
>> the
>>> numbers will be RCF'd", but we wouldn't have a problem using them.
>>> 
>>> Then 3 months into using the service (after our cancellation
>> period
>>> expired and we were locked-in), we suddenly started having
>> problems
>>> with the RCF'd numbers being re-written.
>>> 
>>> No less than 30 calls to Comcast over the years has resulted in
>> widely
>>> different responses including:
>>> * Ok, we just changed an option in the AdTran to allow you to
>> specify
>>> your own caller ID, everything should work now (it doesn't)
>>> * Give us a list of phone numbers and associated addresses so we
>> can
>>> update our e911 information (they respond with "done!", not "we
>> can't
>>> set e911 for phone number xxx-yyy-zzzz)
>>> * I'm going to escalate this (followed by nothing happening and
>> the
>>> case gets magically closed)
>>> 
>>> After talking with Comcast this morning, I had a rep send me what
>> they
>>> had listed for addresses associated with phone numbers...and
>>> unsurprisingly found that they had reset everything to the address
>> of
>>> our SIP trunk service.  None of our offices have valid 911 contact
>>> info.
>>> 
>>> They're allegedly in the middle of updating the list again, but
>> I'm
>>> not holding my breath.
>>> 
>>> It's Comcast's job to provide phone service and 911 routing for
>> this
>>> client.  They shouldn't be re-writing anything.  They weren't in
>> the
>>> beginning, but I'm guessing it has to do with STIR/SHAKEN.  I'm
>>> vaguely familiar with it, but I'm not a telco or a phone service
>>> provider.  Just someone they hired to clean up their FreePBX phone
>>> mess. ;)
>>> 
>>> -A
>>> 
>>> On Tue, Jan 4, 2022 at 3:01 PM Paul Timmins <paul at timmins.net>
>> wrote:
>>> 
>>>> I'm going to be the unpopular one here, and point out that
>> Comcast
>>>> is not really responsible to route 911 calls for you when you use
>>>> numbers that they don't provide. For the cost of an hour of an
>>>> attorney's time, you could just set up trunking to basically
>> anyone
>>>> else to handle those offnet/off circuit numbers and the 911
>> routing
>>>> for those numbers.
>>>> 
>>>> On 1/4/22 1:30 PM, Aaron C. de Bruyn via VoiceOps wrote:
>>>> 
>>>>> One of my clients has a large SIP trunk with Comcast based out
>> of
>>>>> Washington State.
>>>>> 
>>>>> They have all their offices across Oregon and Washington hooked
>>>>> into a FreePBX phone server that is attached to the Comcast SIP
>>>>> trunk.
>>>>> 
>>>>> 911 calls *constantly* get misrouted to the local PSAP where the
>>>>> SIP trunk lives.
>>>>> 
>>>>> I must have called Comcast 30 times over the last few years to
>> try
>>>>> and get this addressed, but Comcast flat-out refuses to fix the
>>>>> issue.
>>>>> 
>>>>> The short answer is that Comcast refuses to fix it.  In some
>> (but
>>>>> not all) cases, our phone numbers are RCF'd numbers, so they
>> don't
>>>>> actually exist on the trunk...and Comcast forcibly re-writes
>> them
>>>>> to our 'main' number...and then routes the 911 call incorrectly.
>>>>> In other cases, we have provided Comcast with the e911
>>>>> information, they say it's updated, and then we find out months
>>>>> later (when an office dials 911 during an emergency) that it's
>>>>> still not correct.
>>>>> 
>>>>> Not only does this affect 911 calls, but also customers who get
>>>>> the re-written caller ID and have no idea which office called
>>>>> them.
>>>>> 
>>>>> The "easy" solution is to ditch Comcast and move to a provider
>>>>> that doesn't play the RCF and caller-ID-rewrite games.
>>>>> Unfortunately my client is locked into their Comcast contract
>> for
>>>>> another ~18 months.  Early termination would incur a ~$35,000
>>>>> bill.
>>>>> 
>>>>> Is there a list of PSAP numbers somewhere so I can set up an
>>>>> internal redirect to the PSAP 10-digit number?  I know those
>>>>> 10-digit numbers are guarded like Fort Knox, so I'm betting this
>>>>> option isn't very realistic.
>>>>> 
>>>>> Maybe a separate service provider that can just handle 911 calls
>>>>> without "owning" my client's phone numbers?
>>>>> 
>>>>> Any other thoughts on how I can route around Comcast brain
>> damage?
>>>>> 
>>>>> Thanks,
>>>>> 
>>>>> -A
>>>>> 
>>>>> _______________________________________________
>>>>> VoiceOps mailing list
>>>>> VoiceOps at voiceops.org
>>>>> https://puck.nether.net/mailman/listinfo/voiceops
>>>> 
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