The Jeff Pulver Blog: So what does the FCC VoIP Order really mean for "Real" VoIP?

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June 11, 2005

So what does the FCC VoIP Order really mean for "Real" VoIP?

As I've said before, I don't really consider many of the simple POTS-replacement services "real" VoIP. Simply using IP technology to replicate plain old telephone service is not VoIP. Not to say "I told you so," but I told you so -- if you pass yourself off as a replacement service, you better expect to be treated like a replacement service with all the responsibilities that entails. If someone picks up your phone and it looks and smells like a traditional phone, I guess the user should have some expectation that it behave like a regular phone.

That said, I have some concerns that those trying to push the limits of IP technology and experiment with cutting-edge applications might become unintended collateral damage in the regulatory zeal to impose reasonable obligations, based on reasonable consumer expectations, on alleged VoIP providers.

The FCC Order on VoIP E911, and the Notice of Proposed Rulemaking attached to that Order make this prospect increasingly likely. What is most apparent is how hard it is to tailor a definition of "Interconnected VoIP Services" that does not unintentionally subsume services for which no one would have an expectation that the device or application should perform all the identically-delivered functions of a traditional phone.

Frankly, I was somewhat relieved that the FCC is not imposing technologically impossible E911 obligations on peer-to-peer communications applications that no one could reasonable consider POTS-replacement services. I, however am concerned over the FCC's tentative conclusion in the Notice of Proposed Rulemaking attached to the VoIP E911 Order that might serve to extend traditional E911 obligations to applications that are primarily peer-to-peer, but might offer some limited access to and from the public switched telephone network. Devices and applications that a consumer should not expect to behave like a traditional phone service should not be stifled simply because they behave differently than traditional phone service.

I hope that the FCC would continue to promote IP-based innovation and entrepreneurship, and enable IP-based communications providers to improve the public welfare through by experimenting with and deploying cutting-edge IP-based applications. VoIP, by its very nature, should dramatically improve the emergency response capabilities of communications devices, and social policy should not serve to cut off the advanced capabilities that IP technology would afford. IP technology empowers a user to take her service anywhere without having to check with the application provider to verify that the application provider has an arrangement to reach the specific local emergency response center. It is one thing to impose traditional social obligations where the consumer has every right to pick up the phone and expect it to behave like a traditional phone. What logic, however, would be served by turning off the added nomadic capability and other valuable features of a Wi-Fi-enabled PDA simply because the user cannot access a local emergency response system when she connects her PDA computer with a softphone program or other IP phone to a Wi-Fi network or other broadband connection at a hotel, a coffee shop or other remote location? Certainly the Japanese tourist in America, with both an inbound and an outbound voice application downloaded to her PDA, has no expectation that the PDA offers a localized E911 capability. That same PDA, however, could be an invaluable aid during a crisis, particularly where no other wireline devices are within reach to contact emergency responders. That user should not have to turn off this functionality, which would only enhance our emergency response capability. I imagine a bizarre world in which the user of that "voice-disabled" device is forced to text (or sign or pantomime if the device is video-enabled) in order to communicate the nature of an emergency to a friend on the other end of the PDA-originated call.

During the tragedy at the World Trade Center on 9/11/2001, emergency response lines were overrun with incoming calls. What if citizens had PDAs with alternative features, functionalities and capabilities that could have allowed them another means to reach emergency responders, or simply friends or family, via text, SMS, IM, IP voice, or even IP video. Shouldn't these functions be encouraged even if the PDA with inbound and outbound voice-enabled software applications cannot offer the user the ability to reach the every local PSAP in the country?

I understand that Open Park is attempting (but beset by bureaucratic intransigence) to install Wi-Fi hotspots across the Mall in Washington, DC. Imagine how dramatically we could enhance our ability to handle an emergency situation if we could avail ourselves of such public broadband access points. Two weeks ago, Congress and many other Federal offices were evacuated because a small plane strayed off course and into DC airspace. Tens of thousands of government employees fled for the Mall. In a real crisis, 911 lines would again be overrun, as would mobile connections. If, God forbid, this were a real emergency, wouldn't it be great if we had another option - a broadband, IP-enabled public hotspot on the Mall that would allow citizens to avail themselves of the IP technology and the public Internet to obtain and transmit essential information? Frankly, wouldn't it have been great for panicked citizens to have been able to use such a public hotspot to verify that this was a real emergency.

Posted by jeff on June 11, 2005 10:25 AM | Permalink

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Posted by: Ed at September 12, 2005 02:30 AM

Jeff,

Cellular was designed around MOBILITY specifically. If the present ruling on VOIP was applied with equal parity to the cellular industry under the current cellular infrastructure, I think there would be NO cellular industry in this country. It is sad that VOIP technology is being killed by a few Americans who cannot read and understand a VOIP service agreement.

Posted by: Greg Pirie at July 31, 2005 12:13 AM

Jeff,
the POTS and cellular were specifically
designed around reliability. Nothing is
limitless, so when everyone is on the
phone, not everyone gets through. Whoever
is lucky to get through though- talks.Makes
perfect sense. You've tried VoIP over
congested pipe, havent you ? What would you
say about the experience ? Everyone is
connected and noone's voice goes through...
Zero QOS- thats one of the main problems
of VoIP as it stands today. The internet
as it exists today is NOT meant for realtime
communications- thats the sad truth. It is
meant for data. What we are trying to do is
to build reliable (voice) services over
unreliable(in time aspect) data transport.
That in my HO will succeed, but in many years,
when the internet insfrastructure slowly gets
replaced with one thats meant for that purpose.

Posted by: Dimitre Chtilianov at June 15, 2005 09:33 PM

June 11, 2005

So what does the FCC VoIP Order really mean for "Real" VoIP?

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