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« When the FCC Gives Us Lemons, Let's Make Some Lemonade -- Silver Lining to the E911 Situation? | Main | Go See: “Star Wars Episode III: Revenge of the Sith” »

May 19, 2005

The FCC Adopts Emergency Response Obligations for VoIP Providers: Regulation of the Unregulated; Unregulation of the Regulated

Necessary Preface: I want the best emergency response system for all the world as soon as possible. I believe that IP-based emergency response could dramatically improve domestic and global emergency response.

Secondary Preface: The services that I offer, most notably Free World Dialup, are not included in the FCC E911 mandate. I, however, still feel compelled to share my views in support of my colleagues in the VoIP community who do offer two-way PSTN-connected VoIP services.

My most striking observation today: The FCC had a golden opportunity to take one positive steps to promote IP-based communications. The FCC could have prohibited “port blocking” and compelled direct access to the ILEC-controlled emergency response infrastructure. Instead, the FCC chose to regulate the previously unregulated, and declined to regulate those that it has obvious authority to regulate – the traditional telecom carriers. As it stands, unaffiliated VoIP providers are left to the mercy or goodwill of their retail rivals – the telecom carriers that control access to the emergency response network. The FCC has also given lip service to its desire to prohibit port blocking and has been looking for a vehicle to do so. A proceeding fell into its lap, and the FCC missed this opportunity. No lives should be at risk simply because a carrier refuses to allow VoIP providers and end-users fair access to the network. Prohibition on port-blocking and direct access to selective routers would have gone a long way to remove this potential threat.

Thus, the following issues stood out today:

1) At least one Commissioner (Copps) acknowledged that for 911 to work, the LECs must not block ports. The FCC finally had a vehicle to do some good in this regard, but did not seize the moment to prohibit port blocking. Again, bully the powerless VoIP new entrants, but don’t take a reasonable step to ensure VoIP customers are not blocked from reaching emergency responders through an IP-based communications network.
2) The FCC indicated that the LECs should provide selective routers to “telecom carriers.” Well, the unaffiliated VoIP providers are not generally certificated telecom carriers, nor has the FCC compelled them to become carriers. The $64,000 question is: “Is the FCC compelling every VoIP provider to become “Telecom Carriers?”

My final thought on today’s events: Amidst all the emotionally heart-wrenching anecdotes about failed Vonage 911 calls, no one ever mentioned the failures of traditional carrier emergency response services. I’m forced to wonder what would have happened if the FCC had paraded the spouses and parents of those who died when 911 failed on traditional wireline and wireless networks? I guess that wouldn’t be acceptable – that might scare consumers of traditional telecom services and antagonize the traditional communications power structure. Let’s bully the new weak kids in town but not draw attention to current emergency response failures by those that are capable of fighting back.

Posted by jeff on May 19, 2005 11:30 AM | Permalink

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The claims by Vonage that the Bells are preventing them from getting access to the 911 infrastructure are lies.

My ISP graduated into providing telephone services last year. From day 1, we had a functional 911 setup. Do you know why? Because I made an executive decision that 911 was important.

Total cost? A couple grand in setup fees. Total monthly cost to cover the whole Denver metro area for E911? $100/mo.

For all these small guys reselling some CLEC IP termination - the typical model for the "Small guys" you are so worried about - where the heck is the CLEC's concern for compliance? All the VoIP providers buy PSTN connectivity from CLECs, why haven't those CLECs set up 911 compliance?

I'll tell you why: BECAUSE THEY DON'T CARE.

There is no technical or financial reason for this to have been ignored for 3 years by the VoIP industry. None. L3, XO etc could easily have provided E911 database interfaces to their wholesale VoIP customers. They simply chose not to, *because the VoIP-service resellers did not demand it*.

The simple fact is, nobody in the VoIP industry has given a crap about 911, they figured and hoped they could get away without having to do it.

Now there are dead bodies and all of a sudden it's the fault of the RBOCs? Holy Passing the Buck, Batman.

Finally, as to failure of the landline 911 infrastructure - yes, it happens. But there is a huge difference between making a substantial effort to provide the service, and failing some of the time; and making no effort to provide the service and failing 100% of the time.

Posted by: Jawaid Bazyar at May 20, 2005 04:15 PM

The claims by Vonage that the Bells are preventing them from getting access to the 911 infrastructure are lies.

My ISP graduated into providing telephone services last year. From day 1, we had a functional 911 setup. Do you know why? Because I made an executive decision that 911 was important.

Total cost? A couple grand in setup fees. Total monthly cost to cover the whole Denver metro area for E911? $100/mo.

For all these small guys reselling some CLEC IP termination - the typical model for the "Small guys" you are so worried about - where the heck is the CLEC's concern for compliance? All the VoIP providers buy PSTN connectivity from CLECs, why haven't those CLECs set up 911 compliance?

I'll tell you why: BECAUSE THEY DON'T CARE.

There is no technical or financial reason for this to have been ignored for 3 years by the VoIP industry. None. L3, XO etc could easily have provided E911 database interfaces to their wholesale VoIP customers. They simply chose not to, *because the VoIP-service resellers did not demand it*.

The simple fact is, nobody in the VoIP industry has given a crap about 911, they figured and hoped they could get away without having to do it.

Now there are dead bodies and all of a sudden it's the fault of the RBOCs? Holy Passing the Buck, Batman.

Finally, as to failure of the landline 911 infrastructure - yes, it happens. But there is a huge difference between making a substantial effort to provide the service, and failing some of the time; and making no effort to provide the service and failing 100% of the time.

Posted by: Jawaid Bazyar at May 20, 2005 04:13 PM

Let's face it. The ruling by the FCC is a very tiny step. Our industry needs an IP capable PSAP (Public Safety Answering Point). We are now talking about phone services but we should be talking about the ability to send a "911" emergency IM and SMS. We all are using our VoIP systems for IM. And why can't I send a picture/movie to the PSAP from my mobile or WiFi enabled VoIP phone.

The Canadian solution is to put a sticker on the phone "When the lights go out, this phone is toast" ... http://www.crtc.gc.ca/eng/NEWS/RELEASES/2005/r050404.htm

The FCC ruling today did "regulate the regulated" with a mandate to Incumbent Local
Exchange Carriers to provide access to their E911 networks to any requesting
telecom carrier including access to trunks, selected routers, and E911 databases.
Just last month this access was news at Vonage/Verizon ...
http://www.vonage.com/corporate/press_index.php?PR=2005_05_04_0

Today's ruling is a call to action not just for "interconnected VoIP providers"
but for pure VoIP providers.

/PETER MACAULAY

Posted by: Peter Macaulay at May 19, 2005 07:19 PM

Is there a distinction between "interconnected VoIP service providers that are similar to traditional telephone providers" (FCC media release) and VoIP service providers like SkypeIn, LibreTel and INX that provide foreign exchange type services (a phone number in a distant city or exchange that is provided over a private line)that are tariffed as private line services by some ILECs or at least have private line service elements that associated with them? Our services are targeting international markets and end users and not as a telco replacement. My company specifically states we are not a telco replacement service and do not provide 911. I am of the opinion that we are not "similar to traditional telephone providers". I guess I will have to wait until I can read the actual order. Any comments?

Posted by: Jon at May 19, 2005 05:50 PM

Being a geek and a firefighter I know the VOIP and the 911 system. Both are not perfect, but neither are the traditional wired services. We have even seen wired calls inside the county go to the next county, and the local LEC just shrugged. I think the FCC, is just kowtowing to special interest and not letting the technology be free as it should be. I would not be surprised if this LEC started port blocking. beginning to wonder who's been talking into FCC's ear? The great question is wwmpd.. What Would Michael Powell Do?

Posted by: Greg at May 19, 2005 04:39 PM

This is typical "save your face" politics... easy way out... public off my back. Top that off with companies who have turned this decision into an advertising campaign to show-off their compliance without consideration for companies with smaller pockets.

Jeff, you're way ahead of the curve on this one. We'll have to let the good Lord pave the way on this one as He always does. I too am a firm believer in what's right, good, and best.

In Jesus Christ (Our Redeemer),
Rick

Posted by: Rick at May 19, 2005 03:57 PM

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