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Is VoIP WIthout E9-1-1 Worth the Risk? : Challenges, Approaches, and Recommendations for VoIP Service Providers.

4. Current Approaches and Limitations

VSPs are addressing the 9-1-1 issue with three main approaches. The first is to simply not offer 9-1-1 services. VSPs who adopt this approach feel no obligation to offer 9-1-1 services to their customers because VoIP is not a telecommunications service and is therefore unregulated. This approach may resolve the VSP's problem in the short term, but in the long term it is detrimental to the entire VSP industry. Without E9-1-1 services, the public is unlikely to adopt VoIP as a replacement to traditional wireline services; to protect those who do, the FCC would likely mandate VoIP E9-1-1.

The second approach uses routing tables to map a caller’s IP phone to the appropriate PSAP serving his or her area. When the caller dials 9-1-1, the VSP uses these routing tables to convert the call to a 10-digit number that rings a designated 24x7 administrative line at the PSAP. Calls to administrative lines do not receive the level of attention that regularly-routed emergency calls receive, and unfortunately they sometimes go unanswered. For this reason, and since this approach does not include automatic delivery of address information to the PSAP, the National Emergency Number Association (NENA) has deemed "10-digit routing" to be a minimally sufficient short-term solution.

A third approach requires the establishment of dedicated circuits or redundant DS-0 trunk groups over diverse T1s to the selective routers. "Direct trunking" is a non-standard approach that is unlikely to win the widespread support of PSAPs because it requires major changes to the current system: installation of a facilities-based network, deployment of specialized switches, significant investment in circuits, and interconnection agreements with the ILECs. Additionally, direct trunking is ineffective for subscribers with non-local phone numbers.

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