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Sources: FCC Will Force VOIP E911

Light Reading
News Analysis
Light Reading
5/17/2005
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The Federal Communications Commission (FCC) this week will require all VOIP providers doing business in the U.S. to provide basic E911 service to their customers, Light Reading has learned from sources close to the Commission.

Sources who met with the FCC in recent weeks say the ruling will come at the FCC’s Open Meeting on May 19th, and will require VOIP players to implement 911 service on a nationwide basis within 120 days of the order’s publication. They add that publication of the order will come a few weeks after the meeting, which would put the compliance deadline at late October or early November.

The implications of such an order will be a victory of sorts for the RBOCs, as their competition, the independent VOIP providers, will be forced to make arrangements with incumbent phone companies across the country for access to the emergency services infrastructure, and will be forced to pay the associated tariffs (see Citron: Some Bills Are 'Weirdly Weird' ).

What's more, sources agree that the FCC will claim it does not have the jurisdiction to compel the LECs to make the process easier.

“The issue is, fundamentally, if they put forth a mandate saying that you have to deliver the calls with automatic forwarding information, and they do so without forcing the LECs to open up their selective router interfaces, then that will be a real problem,” says Tim Lorello, chief marketing officer at third-party E911 service provider TeleCommunication Systems Inc. (TCS) (Nasdaq: TSYS). Annapolis-based TeleCommunication has been working directly with the FCC on the issue over the past several weeks.

The consumer VOIP business has to date enjoyed relatively low cost of entry, but that may change Thursday (see Does VOIP Business Add Up?). Smaller VOIP providers already faced with high competition and downward pricing pressure will encounter yet another serious economic challenge in enabling emergency service in all areas.

“This could quickly put a monkey wrench into some of these startups' plans,” says IP communications analyst Jon Arnold of Arnold & Associates.

In order to comply with the FCC E911 order, an independent VOIP provider would negotiate directly with the incumbent LEC for access to the selective routers, databases, and networking trunks necessary to connect with Public Safety Access Points (PSAPs). But the costs are high, and small VOIP providers may find it more economically feasible to partner with a third party like TCS, or even with a CLEC.

Others observe that the E911 service has been pushed to the top of the regulatory agenda at a surprisingly early stage in the development and commercialization of the technology.

“It is a legitimate issue; how legitimate I’m not exactly sure,” says Washington attorney Dana Frix, who represents VOIP providers on other issues. “Just to state the obvious -- it took the wireless guys 15 years to have this, so why domestic VOIP needs it in 30 days or 60 days I’m not sure.”

One explanation may be VOIP’s increased coverage in the mainstream media, both positive and negative. The press has given ample coverage to VOIP's potential, but has also gravitated to cases like the one in Texas where VOIP’s 911 shortcomings allegedly exacerbated the damage from a robbery.

Some observe that E911’s place atop the VOIP regulatory agenda may be due to the lobbying pressures exerted in Washington by the RBOCs, who may wish to slow down the growth of VOIP insurgents like Vonage Holdings Corp..

“For [RBOCs], pushing in this direction just buys them more time and just makes it a little more difficult for these new disruptive providers to making a big dent in their wireline business,” Arnold says. “They may make a small dent but this will slow down the momentum a bit.”

An SBC spokesman declined to comment on the company’s lobbying efforts in the Capitol, but said his company had been in conversations on the issue with the agency along with many others.

After many months of stalling, all of the RBOCs have now announced in press releases their intention to facilitate access for VOIP providers to the E911 infrastructure in their footprints (see RBOCs Change Tone on VOIP E911). The proximity of that reversal to the FCC’s regulatory action this week is probably no accident. [Ed. note: There are no accidents in Washington.]

But questions remain about the real costs and actual availability of the RBOCs’ E911 solutions for VOIP players, according to one VOIP provider's compliance officer.

“I spoke to SBC earlier in the week and they said ‘we don’t have a tariff in place and we don’t have any documents for you to look at, but don’t worry, give us a call and we’ll work something out,’” the officer said.

"It’s really easy to put out a press release; it’s not quite as simple to provision a service."

— Mark Sullivan, Reporter, Light Reading

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paolo.franzoi
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paolo.franzoi,
User Rank: Light Beer
12/5/2012 | 3:14:46 AM
re: Sources: FCC Will Force VOIP E911

I guess not recognizing the difference between what was primarily a mobile, 2nd line technology and what is a fixed, primary line technology is very hard.

Good news is that lawyers don't have to understand things, they just have to spin them.

seven
alchemy
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alchemy,
User Rank: Light Beer
12/5/2012 | 3:14:46 AM
re: Sources: FCC Will Force VOIP E911
brookseven writes:
I guess not recognizing the difference between what was primarily a mobile, 2nd line technology and what is a fixed, primary line technology is very hard.

Good news is that lawyers don't have to understand things, they just have to spin them.


The problem is that VoIP phones are mobile, or at least transportable. There's no way to map a routable IP address to a physical location so you either have to let the user tell the network where they are (with the potential of lying) or implement a network service where either the user (their SIP UA) or the network can query to find out location. The "standard" I've seen so far is to add a facility to home/hot spot routers so you can query the router. I don't see this as being viable since it's hard to imagine Starbucks risking a lawsuit by mistakenly putting the wrong physical location information in one of their routers and having somebody die because they dialed 911 and the ambulance went to the wrong Starbucks. I think the only viable way to solve this is to mandate that the ISPs provide a database that maps IP address to a physical location. You can still screw any solution up if you use VPN.
paolo.franzoi
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paolo.franzoi,
User Rank: Light Beer
12/5/2012 | 3:14:45 AM
re: Sources: FCC Will Force VOIP E911

Doesn't matter.

If you are taking over primary phone service, that is different than being a car phone.

See the point?

seven
lopetus
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lopetus,
User Rank: Light Beer
12/5/2012 | 3:14:43 AM
re: Sources: FCC Will Force VOIP E911
@seven: I at least don't see your point.

I will use VoIP when mobile as well as "transporting" the phone to locations that will be difficult to figure out where they are (unsecured home network or at friends house).
paolo.franzoi
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paolo.franzoi,
User Rank: Light Beer
12/5/2012 | 3:14:42 AM
re: Sources: FCC Will Force VOIP E911

Here is the point. The fact that something is hard does not make it not a requirement. It means there may need to be protocol changes or enhancements. If one is selling a service to repalce primary phone service, one should provide basic primary phone service support. Next up CALEA.

That is my point. It does not matter if it takes 1,000 PHDs to figure out. I can think of a way to implement this off the top of my head. It will be a lot of work, but you know what - 911 is a lot of work. Do you realize that 911 systems actually changed the way house numbering was done in rural areas? If was hard, but doable.

seven
unlimited
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unlimited,
User Rank: Light Beer
12/5/2012 | 3:14:42 AM
re: Sources: FCC Will Force VOIP E911
911 and no doubt other PSTN requirements are symptoms of playing in a mature market. It will be tough for the new VoIP players to fight the traditional operators on these terms which is what VoIP SPs appear to be doing. The emphasis has been mostly on cost/price reduction of PSTN service with other attributes such as portability more of a byproduct. The incumbents obviously want to control and arrest the rate of decline in pricing. They are forced to respond to this type of attack.

The solution could be to avoid all contact with the PSTN. Notice that you only get one grade of PSTN voice which carries a lot of baggage such as 5 9's, 911, etc. When people turn to VoIP to call long distance to friends and relatives it is assumed that they do it to save money. Of course they do, but they also don't need 911 and 5 9's reliability to do it. When else could VoIP solve non-critical telephony applications? We may just be witnessing the unbundling of voice applications from the "PSTN utility". Should we expect the FCC to force IM services to provide 911?
rjmcmahon
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rjmcmahon,
User Rank: Light Beer
12/5/2012 | 3:14:41 AM
re: Sources: FCC Will Force VOIP E911
The solution could be to avoid all contact with the PSTN.

I think there is a lot of wisdom in this statement. Unfortunately, a VoIP service provider probably can't follow this sage advice as people expect to be able to call devices attached to the legacy networks.
Green_Acres
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Green_Acres,
User Rank: Light Beer
12/5/2012 | 3:14:40 AM
re: Sources: FCC Will Force VOIP E911
In general, I applaud the decision because it will force VoIP services to transition from hobby mode to a competitive offering.

But the complication for me is what defines VoIP?

Will Skype have to comply?
How about MSN messenger?

Is there some definable separation of residential/enterprise VoIP and hobby/recreational VoIP?
PO
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PO,
User Rank: Light Beer
12/5/2012 | 3:14:37 AM
re: Sources: FCC Will Force VOIP E911
I also wonder what the definition will be of a VoIP provider "doing business" in the U.S. as a result of this ruling.

How will the FCC enforce this against foreign-based VoIP providers whose customers "happen" to physically locate themselves within the U.S.?

The FCC could have improved everyone's safety by working with the industry to create a location database (i.e. as ISPs hand out IP addresses) which could be translated to an appropriate PSAP for 911 call completion. Instead, safety may be put at risk if providers are forced offshore.
spelurker
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spelurker,
User Rank: Light Beer
12/5/2012 | 3:14:35 AM
re: Sources: FCC Will Force VOIP E911
>> The solution could be to avoid all contact with the PSTN.

That ship has already sailed.
Telephony is a well-defined service with well-known service expectations.
Expectations:
user -- I can call anyone in the PSTN
user -- I can call 911 when I need to and get equivalent service to PSTN
user -- always available if I'm connected to network
govt -- 911 location services
govt -- law enforcement wire tapping

The FCC is well within its charter to regulate this -- if it does not enforce these expectations, the service is a danger to public safety.

VoIP folks have been dodging this for a while, but Vonage, AT&T, et. al. have been marketing the service to "john q. public", and since it is effectively replacing land lines, it is starting to cause some serious havok with 911 call centers. (as mentioned in the article, they've already had problems with cell phones)

The first question a provider asks should not be "can I avoid PSTN regulation", it should be "can I provide this service without getting anyone killed". (I don't mean to be melodramatic, but these are the stakes of the game.)

As to the lawyer's complaint about the timeframe, yes, a couple of months is burdensome, but the comparison to the cell phone regulatory timeframe is inappropriate, since cell phones (in north america) did not start replacing land lines in any great number for many years.
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