Actually, this is a real good question. Who would be liable when the customer picks up the phone and dials 911 and nothing happens?

Sam Tetherow wrote:

One interesting question would be what happens if the POTS line is down, but Matt's wonderful wireless network is up? ;) The customer would have voice service but no 911... Sorry, I just couldn't resist.

   Sam Tetherow
   Sandhills Wireless

Matt Larsen - Lists wrote:

Lets take a step back...

I never wrote anything about offering VOIP or 911 or E911 - I merely mentioned selling an Asterisk based phone system that is capable of redirecting long distance calls over VOIP. The customer that I mentioned is not getting their long distance through my VOIP system, they are getting it through another ITSP. The customer has four POTS lines and the 911 dialplan goes through those four lines for 911, and those lines are the responsibility of the ILEC to take care of 911 - e911 or otherwise. I have no more responsibility than any other PBX vendor who installs a system that uses POTS lines.

Who is really at a lot of risk? The VOIP providers that are promising virtual PBX services over the Internet. A local PBX unit with at least one local line is going to always be able to get out, whether the Internet is working or not. The virtual PBX services are heavily dependent on the Internet connection working (and working solidly) and are toast if the connection is running poorly or completely out. FWIW, I will have the same e911 functionality on my VOIP offering that the CLECs and several major VOIP carriers are using. Turns out it isn't that hard to get setup, it just costs a fair amount to get setup the first time around.

Matt Larsen

Matt Liotta wrote:

On Jun 24, 2006, at 10:15 PM, Butch Evans wrote:

If you look at what Matt Larsen posted, you will see that (as I have stated twice and he stated originally) that his PBX SUPPORTS E911. You are either forgetting that or ignoring it. Here is his post again:

Actually, he never wrote E911 and instead wrote just 911, which is not the same thing. A POTS line may or may not support E911 depending on the area one is in. Interestingly, VoIP providers are required to support E911 even in areas that E911 is not supported by POTS lines.

Some areas even have both POTS and VoIP lines that are E911 compliant, but the PSAP is not E911 capable. One might argue successfully that the VoIP provider is not compliant if they sell service in such an area. Unfortunately, the closest thing to a fact I have seen in this regard is an FCC comment stating that VoIP providers are not allowed to market services in areas that are not E911 capable.

The reason for the POTS line is so that 911 calls FROM THAT BUSINESS (BUILDING) can be directed that way. The system Matt described does support E911. Not sure how you are not seeing that. The only way it does not support E911 is if the building is over a certain number of square feet (I don't care to look up the number), in which case, he will require a POTS line for the other part of the building, or get the POTS provider to accept his ANI/ALI information. You still have not made a case that what he is doing is not compliant. It just looks like arguing to me. :-)

I've written specifically that it doesn't matter if you have a POTS line if there is VoIP service involved. If there is a VoIP phone line that is capable of making calls to the PSTN then that line MUST support E911. No where has the FCC stated that having a separate POTS line that does support E911 along side the VoIP line(s) is compliant.

I agree that providing a POTS line to a business for the purpose of 911 follows the spirit of the regulation, but unfortunately hasn't been shown to actually be legal.

BTW, I am not saying you are wrong here, but you have not convinced me (or apparently some others) that Matt is wrong. You are obviously very informed here, so please explain exactly HOW the system Matt described is NOT compliant.

See above.


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