[VOIPSEC] Odd e911 VoIP Regulatory Question

[Dustin D. Trammell]

On Wed, 2009-01-28 at 10:39 +0100, Victor Pascual Ávila wrote:
> On Tue, Jan 27, 2009 at 9:17 PM, J. Oquendo <sil at infiltrated.net> wrote:
> > Client --> VoIP_Provider --> Carrier (me) --> Calle
> >
> > In the scenario where I have to disconnect a mini
> > VoIP_Provider who I'm supplying trunks to, THEIR
> > clients won't be able to access e911. Am I mandated
> > to send e911, is it on the VoIP_Provider...
> >
> > Any documentation clarifying this would be greatly
> > appreciated.
> 
> IANAL, but from [1]: "Interconnected VoIP providers must transmit all
> 911 calls"
> 
> [1] http://www.fcc.gov/cgb/consumerfacts/voip911.html
> 
> So, I assume you are mandated to forward them-- this is just my
> understanding from the text.

I am also not a lawyer, but here's my take on this:

If he's disconnecting them due to nonpayment, I would argue that it's
safe to say that they are no longer a customer.  You left off the second
half of that bullet point.  Here it is in it's entirety:

"Interconnected VoIP providers must transmit all 911 calls, as well as a
callback number and the caller’s registered physical location, to the
appropriate emergency services call center or local emergency
authority."

This assumes that they have a callback number (not likely when
disconnected) and the caller's registered location (not likely kept when
no longer a customer).  Reading that entire page, you get the sense that
this is a requirement only for the caller's provider in regard to their
customers, and if they are no longer a customer I don't see the
requirement likely to apply.  The first and second bullet points under
the requirements strengthens this assumption, and in regard to the one
quoted above, how is it even possible to receive a 911 call to then
transmit if the customer's credentials no longer work due to being
disconnected?

If an interconnected VoIP provider were mandated to pass 911 calls for
anyone that was ever their customer, what would prevent me from creating
a business that explicitly provided free VoIP 911 service, getting
trunks with as many providers as I can, not paying my bill until they
disconnect my regular service, and then enjoying the fact that they have
to route any 911 calls that I route to them forever?

-- 
Dustin D. Trammell
Security Researcher
BreakingPoint Systems, Inc.