The Jeff Pulver Blog: Heads up for those of you offering "Interconnected VoIP Services" in America:

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June 29, 2005

Heads up for those of you offering "Interconnected VoIP Services" in America:

The FCC's "E911 Requirements for IP-Enabled Service Providers" Order was published in the Federal Register today. That means the clock begins to tick.

Here is a breakdown of obligations and timelines:

07/29/05 -- Effective date
07/29/05 -- Deadline for customer notification requirements
07/29/05 -- Deadline for Filing a Petition for Reconsideration
08/15/05 -- NPRM Comments due
08/29/05 -- Deadline for filing a Petition for Review with the Court of Appeals
09/12/05 -- Reply comments due
11/28/05 -- 120 day deadline for compliance

For those of you not offering what would currently satisfy the definition of an "Interconnected VoIP Service," be aware that the Notice attached to the Order asked whether the FCC should extend E911 obligations to providers of other VoIP services that are not covered by the rules adopted in the current Order. For instance, the FCC asks what E911 obligations, if any, should apply to VoIP services that are not fully interconnected to the PSTN? Specifically, should E911 obligations apply to VoIP services that enable users to terminate calls to the PSTN but do not permit users to receive calls that originate on the PSTN? Should E911 obligations apply to the converse situation in which a VoIP service enables users to receive calls from the PSTN but does not permit the user to make calls terminating to the PSTN? The FCC tentatively concluded that "a provider of a VoIP service offering that permits users generally to receive calls that originate on the PSTN and separately makes available a different offering that permits users generally to terminate calls to the PSTN should be subject to the E911 obligations if a user can combine those separate offerings or can use them simultaneously or in immediate succession." Comments are due August 15 and Reply Comments are due September 12.

Posted by jeff on June 29, 2005 12:39 PM | Permalink

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Logically, FCC has to confirm their tentative conclusion identified in the last part of your entry. Otherwise, all service providers identified in the order can artificially create two services.

Then, the next question is what if the "In" service provider is a different company from the "Out" service provider? If they are also covered, then who has to provide access to E911? If they are not covered, can't two companies be artificially created, undermining the order? This conundrum indicates the untenability of the order.

So I repeat my position that the order should require fair acces to E911 network to any VoIP provider as long as the provider meets certain interface requirements.

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June 29, 2005

Heads up for those of you offering "Interconnected VoIP Services" in America:

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