Subject: Re: [Ecrit] ECRIT Framework: Dial Strings

From: "Brian Rosen" <[email-masked]>
Date: Fri, 4 Apr 2008 16:05:20 -0400

If you are currently located in the U.S., I believe it is a regulation that
9-1-1 work from a telephone.  Not 9-9-9, but 9-1-1.  If you are in the U.K.,
I suspect that it is required that 9-9-9 work.  The regulation is of course,
antiquated, and doesn't really speak to current technology capabilities.

If you are a customer of a U.S. carrier, but you have roamed to the U.K.,
there is no requirement that 9-1-1 work, but there is a requirement that
9-9-9 work.  That is in current regs.  That is more or less a by-product of
how roaming is implemented in mobile telephone networks, but the reality is
that local is required.

I wouldn't presume to speak for any U.S. government agency, but I've had
some discussions on the subject, and I think they don't care what happens
when a customer of a U.S. carrier is located in the U.K., but they do care
what happens when a customer of a U.K. carrier is located in the U.S.  They
want 9-1-1 to work.  I know that's how NENA feels.

Brian

-----Original Message-----
From: Stark, Barbara [mailto:[email-masked]] 
Sent: Monday, March 31, 2008 9:29 AM
To: Brian Rosen; Hannes Tschofenig; [email-masked]
Subject: RE: [Ecrit] ECRIT Framework: Dial Strings

I'm not aware of any country that requires that companies operating in
foreign countries recognize "local" dial strings, when their customers
are traveling into the "local" country.

Likewise, I'm not aware of any country that has emergency dialing
legislation regarding devices that visitors bring into the country or
that residents bring in from foreign countries.

I think the "legal requirements" argument is empty. But I don't see that
requiring end devices to request local dial strings is a bad thing. 

I also think that there's a strong likelihood that "home" governments
will require "home" service providers and "home" devices to support
"home" dial strings, no matter where the device may go. Since the BCP
doesn't preclude this, and sufficiently describes how this can be done,
I'm ok with the phonebcp language.

So, I'm fine with the requirements as they are. But I still think that
this "legal" argument is backwards and incorrect.
Barbara

-----Original Message-----
From: [email-masked] [mailto:[email-masked]] On Behalf
Of Brian Rosen
Sent: Sunday, March 30, 2008 2:35 PM
To: 'Hannes Tschofenig'; [email-masked]
Subject: Re: [Ecrit] ECRIT Framework: Dial Strings

No current systems recognize the home dial string unless they happen to
be
the same, or there is some fixed strings always recognized.  There are
legal
requirements for the local one, and there are none for the home one.

Unless you have some good reason, I think there is no requirement to
support
the home dial string.  I'm not even sure it's a good idea. 

Brian

-----Original Message-----
From: [email-masked] [mailto:[email-masked]] On Behalf
Of
Hannes Tschofenig
Sent: Sunday, March 30, 2008 10:06 AM
To: [email-masked]
Subject: [Ecrit] ECRIT Framework: Dial Strings

You write:
"
Therefore, the visited dial string must
   work while having the home dial string work is optional.
"

I don't understand this reasoning on why the home dial string is
optional.
 From an implementation point of view you have to implement the home 
emergency dial strings since in most cases devices will be used "at
home".
Why isn't the ability to understand the home dial string mandatory?

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---

From: "Stark, Barbara" <[email-masked]>
Date: Mon, 7 Apr 2008 09:35:10 -0400

We need to distinguish between cellular environments where the access
network can control what calls the end device can make, and VoIP
providers that have no roaming arrangements and place the burden of
getting on the Internet on the customer.

I'm not aware of any regulations that require these VoIP providers to
recognize "local" strings for wherever their customers may be. I'm also
not aware of any current regulations on Internet Service Providers or
Hotspot providers.

I'm not aware of any current regulation that says my SIP phone must
understand 9-9-9 to be a request for emergency services when I take it
to the UK. Can you point me to such a regulation? Is the regulation on
the all phone manufacturers worldwide, the ISP (who is local but doesn't
currently sniff for VoIP), or the foreign VSP? Or the customer? Is there
a law that says travelers may not bring SIP phones into the country that
do not support 9-9-9 as an emergency string? Just who do these
regulations apply to? If the regulations don't exist today, who do you
expect them to apply to? Also, if they don't exist, and you have no
knowledge of even proposed text for such a regulation, is the IETF
trying to guide the creation of such regulations?
Barbara

-----Original Message-----
From: Brian Rosen [mailto:[email-masked]] 
Sent: Friday, April 04, 2008 4:05 PM
To: Stark, Barbara; 'Hannes Tschofenig'; [email-masked]
Subject: RE: [Ecrit] ECRIT Framework: Dial Strings

If you are currently located in the U.S., I believe it is a regulation
that
9-1-1 work from a telephone.  Not 9-9-9, but 9-1-1.  If you are in the
U.K.,
I suspect that it is required that 9-9-9 work.  The regulation is of
course,
antiquated, and doesn't really speak to current technology capabilities.

If you are a customer of a U.S. carrier, but you have roamed to the
U.K.,
there is no requirement that 9-1-1 work, but there is a requirement that
9-9-9 work.  That is in current regs.  That is more or less a by-product
of
how roaming is implemented in mobile telephone networks, but the reality
is
that local is required.

I wouldn't presume to speak for any U.S. government agency, but I've had
some discussions on the subject, and I think they don't care what
happens
when a customer of a U.S. carrier is located in the U.K., but they do
care
what happens when a customer of a U.K. carrier is located in the U.S.
They
want 9-1-1 to work.  I know that's how NENA feels.

Brian

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

Brian

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

You write:
"

*****

The information transmitted is intended only for the person or entity to which it is addressed and may contain confidential, proprietary, and/or privileged material. Any review, retransmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from all computers. GA622

---

From: "Brian Rosen" <[email-masked]>
Date: Mon, 7 Apr 2008 11:36:33 -0400

Do you think the user experience of cellular roam and VoIP nomadic should be
different?  

As I said, current regulations are antiquated.  They apply to telephone
carriers, and, in the U.S., VoIP service providers.  I don't think there are
any emergency service obligations on ISPs or hotspot providers currently.

Given that the wording of the regulations really don't adequately cover
technology evolution, the intent is pretty clear.  When you are in the U.S.,
U.S. rules apply.  When you are in the U.K., U.K. rules apply.  As with all
Internet services, it's pretty hard for a U.S. law to apply to a service
provider operating outside the U.S. even if the service is provided to a
U.S. consumer while he is in the U.S. (and the same for any other country).

IANAL.  I'm not as familiar with U.K. law applicable to VoIP, but let's take
U.S. regulations.  If you were in the U.S., and you had dial in and dial out
capability to the U.S. PSTN, regardless of whether your VoIP provider was a
U.S. service provider, I believe you would come under the VoIP E9-1-1
regulations, and 9-1-1 has to work.  I think the FCC would say that the
(foreign) VoIP provider has to meet the requirements and not the ISP, or
even the underlying carrier who would be providing PSTN connections and
telephone numbers.  And it doesn't matter where you got your phone.

I don't want to see more regulation (less would be better).  However, I
think we have to be cognizant that the local regulator, and the rules
applicable to a local provider, should apply to a roamer or a nomad, even if
the reach of the regulator doesn't actually extend that far.  I also think
the local PSAPs want their local emergency number to work for all visitors.
I don't think they care if the home dial string works, they do care if the
local one works.

Brian

-----Original Message-----
From: Brian Rosen [mailto:[email-masked]] 
Sent: Friday, April 04, 2008 4:05 PM
To: Stark, Barbara; 'Hannes Tschofenig'; [email-masked]
Subject: RE: [Ecrit] ECRIT Framework: Dial Strings

Brian

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

Brian

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

You write:
"

*****

The information transmitted is intended only for the person or entity to
which it is addressed and may contain confidential, proprietary, and/or
privileged material. Any review, retransmission, dissemination or other use
of, or taking of any action in reliance upon this information by persons or
entities other than the intended recipient is prohibited. If you received
this in error, please contact the sender and delete the material from all
computers. GA622

---

From: Henning Schulzrinne <[email-masked]>
Date: Mon, 7 Apr 2008 11:49:31 -0400

I'm not sure anticipating or guessing at regulation is particularly  
helpful. I think we have the chance, with minimal effort, to create a  
system that works better, for the user, than the current system. Our  
job is not to satisfy regulators or lawyers, but to engineer for those  
that actually need emergency services. We've discussed several times  
in the past why having both dial strings is useful, such as the lack  
of familiarity of tourists with the dial string in the country visited  
and the "good samaritan" situation.

It should also be noted that the current cellular system, having both  
1-1-2 and 9-1-1 hardcoded (among others), already offers the visited/ 
home functionality to hundreds of millions and users/tourists, so it  
would seem peculiar to regress below that functionality.

Henning

---

From: "Brian Rosen" <[email-masked]>
Date: Mon, 7 Apr 2008 11:53:05 -0400

I have no problem with MUST local and SHOULD home.
I think MUST local is required.
I think you don't need to have MUST home.

-----Original Message-----
From: Henning Schulzrinne [mailto:[email-masked]] 
Sent: Monday, April 07, 2008 11:50 AM
To: Brian Rosen
Cc: 'Stark, Barbara'; 'Hannes Tschofenig'; [email-masked]
Subject: Re: [Ecrit] ECRIT Framework: Dial Strings

Henning

---

From: "Stark, Barbara" <[email-masked]>
Date: Mon, 7 Apr 2008 12:02:23 -0400

I agree. This is why I stated that I think the "legal requirements"
argument is empty. It's not an appropriate justification. But I think
the capabilities that have been defined are good and sufficient.

Namely, 
- LoST provides a mechanism to supply local dial strings.
- phonebcp requires devices to recognize dial strings supplied by LoST
- phonebcp encourages devices to support configuration of home dial
strings, and recognize such strings

I'm ok with the current phonebcp statements relating to service provider
support of dial string recognition.

Again, I think the requirements are fine. I just wish we'd drop this
"legal requirement" justification. I'd be fine with no justification. Or
with "good Samaritan" and "tourist" justifications.
Barbara

-----Original Message-----
From: Henning Schulzrinne [mailto:[email-masked]] 
Sent: Monday, April 07, 2008 11:50 AM
To: Brian Rosen
Cc: Stark, Barbara; 'Hannes Tschofenig'; [email-masked]
Subject: Re: [Ecrit] ECRIT Framework: Dial Strings

Henning

*****

---

From: Henning Schulzrinne <[email-masked]>
Date: Mon, 7 Apr 2008 14:28:24 -0400

SHOULD without reasons when not to do is is just weaseling out of  
making a decision.

There's nothing difficult about declaring that phonebcp-compliant  
devices MUST allow configuration of a "home country". If LoST is  
available and that country information is reachable, it can then be  
used to retrieve the home dial string. Obviously, if there's no such  
service, we can't create one out of thin air, but MUST/SHOULD here are  
implementation guidelines, not "MUST work" guidelines.

I'm less enamored with a user-configured home dial string (such as  
911), although the likelihood of getting this wrong is relatively low.

Like Barbara, I'd also prefer the user-focused motivations rather than  
hiding behind lawyers and regulators.

Henning

---

From: "Brian Rosen" <[email-masked]>
Date: Mon, 7 Apr 2008 14:36:04 -0400

If there are no other objections, I'll do it this way. 

Brian

-----Original Message-----
From: Henning Schulzrinne [mailto:[email-masked]] 
Sent: Monday, April 07, 2008 2:28 PM
To: Brian Rosen
Cc: Barbara Stark; ECRIT
Subject: Re: [Ecrit] ECRIT Framework: Dial Strings

Henning