E911

VoIP and 911

It is important that Fonality PBX users be aware of the usage and limitations of dialing emergency services (“911”) from handsets and softphones connected to your PBX For most users from most phones, 911 will work just as expected; however, there are important exceptions to this.

E911 and Your Service Provider

The FCC has mandated that all providers of telephone service, including dial-tone provided via traditional analog lines, PRIs and Voice-over-IP (VoIP), provide “Enhanced-911 (E911)” information to emergency services when their users dial 911. This information includes a call-back number and the address of the location from where the call originated. All providers of analog telephone lines, and most (but not all) providers of PRI and VoIP service are compliant with this FCC mandate – they will pass the call-back and address information to the 911 service. Analog lines and PRIs use a universal service called the Automated Number Identification (“ANI”) to identify the call-back number and the associated location information. They can do this because in the “traditional” telephony world, phone lines are physical entities with physical locations. However, VoIP has changed all that. VoIP “dial-tone” is a telephone service without a physical location associated with it. Calls are routed based on a user’s IP address – if you move your computer, for instance, VoIP will still find you. This has created a problem for VoIP carriers because they are still required to provide call-back and location information when their users dial 911. Recently, the FCC has stated that VoIP providers must have at least a valid address where the VoIP service is first used, and provide a simple means for users to update that address. Of course, it is still up to the user to update their address when they move, even temporarily. This presents a problem of course, if, for instance, you happen to be using your laptop at your local Starbucks! There are some technical solutions to this problem in the works (using, for instance, your IP address to determine your location) but these are neither available nor mandated at this point.

Given this problem, the FCC has also mandated that all VoIP service providers clearly inform their users of these limitations. For more information about this, please contact your service provider.

E911 and Premises PBX

 The FCC has specifically excluded PBX manufacturers such as Fonality from their E911 mandate. As stated above, it is up to the service provider to provide E911 information on behalf of their users. (For more information, please refer to FCC Notice of Proposed Rulemaking #05-196 ("E911 Requirements for IP-Enabled Service Providers"), released June 3, 2005, footnote 78: http://www.fcc.gov/cgb/voip911order.pdf).

E911 Using Fonality

It is very important that Fonality clients understand the specific limitations of E911 when dialed from premises PBX system, and how they vary based on the type of service provider you are using:

Analog and PRI Lines

The call-back number and location information will be based on physical location of the lines used to initiate the call. That is: the location given to 911 will always be the location of your Fonality system.

VoIP Services

The call-back number and location information will be based on information you provided to the VoIP provider at sign-up. That is: the location given to 911 will always be the location you gave to your service provider at sign-up (or modified later – with the VoIP Provider)

If you use more than one type of service (VoIP with analog backup, for instance), Fonality provides you with the ability to easily select which type of service is used for 911 calls. This can be modified in the “Dial Plan” section of your Control Panel.

E911 and Telecommuters and Softphones

Fonality uses VoIP to communicate between extensions, regardless of where those extensions are. This allows us to support telecommuters, branch offices and mobile softphones. While Fonality can tell which phones are making calls from remote locations, there is currently no standard to communicate this information to the Public Safety Answering Points (PSAPs) which would route your call to the nearest 911 facility.

Therefore, all 911 calls originating from telecommuters, branch office and softphones will appear to the PSAP and the 911 service to be originating from your server’s physical location. If you are using VoIP, the location will be the one you provided to your VoIP provider; if you are using analog or PRI, it will be the location physically associated with that line.

Changing Dial Plan for 911

Changing the dial plan for 911 access is a choice that Fonality leaves to our customers and we cannot provide any legal advice regarding how our clients use our products, however, we only advocate proper legal use.

There are two reasons that we cannot answer these kinds of questions

1. We are not lawyers and cannot not dispense legal advice

2. Our products are deployed across the United States and Internationally and we cannot maintain a database of regulations for every jurisdiction where our products are used

We suggest contacting your local police via a non-emergency number to find the answer to your question. Alternatively, you might contact the local library and request a 'research librarian' to answer your question...they are very helpful and very resourceful with complex questions.