California PUC demands E911 Fee explanation

integrated services digital network (PRI ISDN) trunks additional charges to pass through the automatic number identification (ANI) from a public branch exchange (PBX) on 911 calls? If so, what is the rate and what are the associated installation and recurring costs?

b. Do you charge any type of optional upgrade fees relating to allowing the calling party number of the station to be sent to the enhanced 911 (E 911) database rather than the billed and telephone number?

c. Do you have rates in tariffs or service guides applying specifically to PRI ISDN trunks for the service of allowing the PBX phone station ANI to be sent to the E911 database rather than the billed telephone number of the trunk?

Additionally, within the same timeframe, AT&T shall additionally file comment responding to the following questions raised by the County of Orange:

a. As posed by the County of Orange in the attached letter dated August 3, 2011, does the CALNET 2 contract specifically require the signees exclusivity to the providers? If so, which provision or provisions require(s) such exclusivity?

b. As posed by the County of Orange in the attached letter dated August 3, 2011, as the contract holder and service
provider, do you charge termination or other fees to customers for switching to another service provider? If so, under what circumstances would such fees be assessed?

c. Does AT&T have any further or clarifying comments responsive to the comments and concerns set forth in the
attached letter from the County of Orange.

Why the questions? Apparently, in a letter from Max Ralsten with the County Executive Office Information Technology Telephone Services Division on August 3 of this year, a rebuttal was filed with the California PUC in response to comments made by AT&T.

The letter, found as Attachment 1 to the current ALJ ruling, challenges the AT&T response "Customers are free to choose from a large number of competitors in this highly competitive space". Ralsten claims, in his four-page letter to California PUC's Michael Aguilar, that the County of Orange subscribes to the CALNET 2 contract, and is therefore limited in his choices for 911 delivery services.

Also challenged are AT&T's references to the availability of CAMA trunks as an option for 911 service delivery. In addition to being legacy technology, installing one CAMA trunk at each of their 40 PBX locations would cost taxpayers nearly $30,000 for installation in addition to more than $35,000 per year in monthly recurring fees. Compare that to a single PRI circuit that would allow up to 23 simultaneous 911 calls from any number of sites in their network, that would incur and installation cost of $2,387 and monthly recurring charges of $5664 annually.

Reading through Ralsten's comments, the main complaint is that MLTs owner operators already pay numerous fees and charges to connect to the PSTN. That level of conductivity on a PRI circuit allows station specific caller ID to be transmitted by the PBX, and received at the destination intact on normal phone calls. Yet a call over the same facility, with the same caller ID, to the 911 network in California has the caller ID "screened" by the central office, and modified to be that of the billing number unless additional services are purchased that incur monthly recurring fees.

Ralsten argues that if the delivery of Caller ID or ANI is already possible when passing calls to the PSTN, why is there an additional charge to allow this information to be displayed when calls are placed to emergency services?

The letter closes with the statement:

"In this time of government budget problems and business slowdown, it seems irresponsible to require any MLTs owner to be doublebilled for the ANI service based upon the destination the call, a PSAP."

Very strong words about a very urgent matter.

So why is 911 important to your enterprise? Sure, it will help save lives and speed public safety's response to your facility in a time of need; but as Max Ralsten from the Orange County, California County Executive Office Information Technology Telephone Services Division found out, understanding how 911 works could potentially save his departments telecommunications budget close to $30,000 annually in excessive and unneeded 911 service fees.

If you are implementing E911 or have implemented E911, make sure you closely examine the recurring charges you may be incurring. Verizon dropped their recurring charges a few years back, Quest also revamped their tarrifs, and some new carriers may offer E911 services free of charge as an incentive to entice new customers.

The bottom line is you need to use 911 to your advantage or you may get taken for an expensive ride. A user from Michigan called me just yesterday complaining that the LEC wanted nearly $4500 for the install of PS-ALI on 75 numbers, and monthly recurring tarrifs on top of that to maintain static ALI records that would never even to be updated. This is very common with zone based E911 configurations, and one of the main reasons to implement in this fashion.

Use your negotiation skills, and make E911 sevices table stakes on your contracts. It's a bargaining chip that just might save you a few dollars, as well as your life.


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