The Jeff Pulver Blog: My Languishing Wireless E-911 Phase III Petition:

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November 17, 2005

My Languishing Wireless E-911 Phase III Petition:

For those of you following my blog, you might have noticed that I have spent a lot of time criticizing the FCC for its backward-looking and anti-innovative approach to emergency response, and for singling out the VoIP industry for more onerous compliance obligations. I think I have to reiterate that my criticism of the FCC’s approach is NOT motivated by any aversion to emergency response. I want IP technology to revolutionize America and the World’s best emergency response capability as soon as possible. But I am baffled about the disparate treatment towards the nascent IP-based communications industry vis-à-vis other more established, richer and more connected industry players.

I am also forced to wonder why the FCC has never acted on a petition I filed on September 20, 2001 to the FCC to consider an E-911 Phase III initiative to improve in-building mobile coverage. I was motivated by the horror of 9/11. I worked at Cantor Fitzgerald Securities at One World Trade Center until 1996. Cantor lost seven hundred employees that day, including many very close friends and former colleagues. And I resolved to promote better emergency response capabilities in buildings. I am convinced that many of my former colleagues and friends did not know what to do when the planes struck the World Trade Center. Back in 1993, after the World Trade Center truck bombing, we were told to head to the 108th floor and go to the roof. I am sure many folks did just that and that may have contributed to their inability to evacuate the building. Sadly, the need for improved indoors tracking was clearly demonstrated during the tragic events of September 11, 2001 at the New York World Trade Center.

So, four year ago, I petitioned the FCC to consider issuing an E-911 Phase III directive aimed at reducing the response time for wireless emergency 911 calls in large buildings and similarly structured interiors. Improving emergency response time in these environments would entail new accuracy requirements for locating mobile phones in indoors settings.

Now we live in a world where only the VoIP providers are Federally-obligated to provide fully-compliant E-911 obligations to business users. Mobile providers do not have to provide full location based emergency response tracking the user to a precise floor or location. Neither are multi-line business phones that use traditional TDM or circuit-based technology. For some reason, once a traditional PBX is replaced with an IP-PBX, that phone is now subject to increased obligations.

Why is the new technology and the new provider subject to deadlines and obligations that, to date, have not been imposed upon the much more prevalent and established services and technologies that have had many more years to implement a solution? Why does the IP-PBX phone at the Commerce Department have to be E-911 compliant but the non-IP multi-line phones at the FCC do not? And what about the fate of my E-911 Phase III Petition?

Tags: voip, fcc, e911, policy

Posted by jeff on November 17, 2005 08:05 AM | Permalink

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Jeff,

We all know full well why the IP phones are required to have more stringent requirements than the non-IP phones. It's because the non-IP-based companies have considerably more lobbying power than the IP-based companies do.

My objection to the FCC mandate is not because I feel that people should be without E911 services, but that I feel that 120 days for the VoIP companies to come up with a solution is utterly impractical, and that expecting VoIP companies to remain solvent while having to shell out excessive amounts of money to the RBOC-controlled E911 ERS access points is wholly unrealistic.

ALL the recent (and, in fact, MANY of the past) FCC regulations and mandates have been very much in favour of the rich giants over the struggling rest of us. To imagine that your petition to require te mobile giants might even be looked at seriously is perhaps hoping for too much.

Of course, realistically, improving in-building coverage is both technologically daunting and politically dangerous. Cell towers themselves can't penetrate a majority of substances used in construction, so you'd be relying on invididual construction efforts to revamp signal passing, or requiring companies globally to provide boosters indoors (per floor) for perhaps 6-12 different carriers. That's expensive and wouldn't easily fly. The construction lobby is HUGE, and when you're talking about the alternative of requiring EVERY company to provide its own boosters per building (as cell companies certainly have no right of way inside the building), you're going to get pushback from EVERYone -- which would kill any mandate pretty quickly.

Of course, that I as a VoIP provider am required to know the location of Subscriber X who happens to be using his wifi SIP phone in a Starbucks in Noweheresville, UT in order for me to pass him off to the Nowheresville 911 ERS while the cellphone companies don't even have to know where he IS because he's indoors and therefore has no signal seems more than a little one-sided, don't you think?

Posted by: Neil Fusillo at November 18, 2005 10:48 AM

Jeff,

Excellent comment. I seem to recall reading that many people did exactly that, seek to go to the roof and got trapped, or people left the top floors and went down to the mid areas only to be told to go back to their offices, where many of them died. You make a very cogent argument that hopefully people will listen to before there are even worse tragedies.

Posted by: Judith Hellerstein at November 17, 2005 02:05 PM

November 17, 2005

My Languishing Wireless E-911 Phase III Petition:

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