[VoiceOps] Misrouting 911 Calls?

Sun Jan 9 10:47:33 EST 2022

Are you potentially underestimating what you're required to do for 911? 

----- 
Mike Hammett 
Intelligent Computing Solutions 
http://www.ics-il.com 

Midwest Internet Exchange 
http://www.midwest-ix.com 

----- Original Message -----

From: "Aaron C. de Bruyn via VoiceOps" <voiceops at voiceops.org> 
To: "Mary Lou Carey" <marylou at backuptelecom.com> 
Cc: voiceops at voiceops.org 
Sent: Saturday, January 8, 2022 5:11:36 PM 
Subject: Re: [VoiceOps] Misrouting 911 Calls? 

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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