The Jeff Pulver Blog: It is Great to See Others Rant about the Disparate Regulatory Treatment between VoIP and Wireless and Traditional Wireline E-911

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January 27, 2006

It is Great to See Others Rant about the Disparate Regulatory Treatment between VoIP and Wireless and Traditional Wireline E-911

I saw a nice posting on E-911 for VoIP yesterday in the Michigan Telephone, VoIP and Broadband blog. I haven’t blogged too much lately on the E-911 front so, in lieu of my own E-911-specific blog, I thought I would link to a blog that definitely shares many of my views on the subject.

http://michigantelephone.mi.org/blog/2006/01/cell-phones-cant-always-provide-e911.html

“One thing that really ticks off a lot of knowledgeable VoIP users is that the Federal Communications Commission seems to want VoIP companies to do the impossible - that is, provide accurate location information on "nomadic" VoIP users. "Nomadic" users are those that don't always use their VoIP adapter at the same location, but instead move around from one location to another.

“The cell phone companies have had a couple decades to ‘get it right’ and they still can't do it. Even new phones that have GPS capability built in can't always deliver accurate location information …

So my question is, why is the FCC expecting the VoIP companies to provide exact location information, given that most VoIP adapters are located inside buildings, when even cell phones can't seem to deliver guaranteed accurate location information under those circumstances (and cell phone companies are much larger, have more resources at their disposal, and have had far longer to develop the technology)?

And people wonder why I say that sometimes it seems like the FCC is just doing the dirty work for the big incumbent phone companies!”

Well said.

All I want to add is: when will the FCC get around to reviewing my languishing Wireless E-911 Phase III Petition?

http://pulverblog.pulver.com/archives/003322.html
:
I filed a Petition with the FCC on Sept. 20, 2001 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-and-a-half years 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 residential and business users. 81 Million mobile users do not have E-911 today. And we still have not seen whether the FCC will grant another extension to the wireless industry on the inclusion of GPS chips in mobile handsets (although we expect a decision any day now). It would certainly be telling if the deep-pocketed wireless industry receives yet another extension, given the leeway the wireless industry has had over the years and the apparent reluctance to grant any latitude to the VoIP industry. Rumor has that the FCC will give them some sort of waiver, but is unlikely to impose a marketing ban on wireless consumers despite the fact that the industry has had half a decade to comply. I also do not expect the FCC to require the wireless industry to contact every user to let them know about the limitations of their 911 solutions or to require stickers on the handsets warning users.

About a million satellite phone users do not have E-911 (not to mention the millions of traditional wireline users without E-911). I have not seen any marketing restrictions imposed on any of these more established industries without E-911 capabilities.

Mobile providers do not even 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?

Posted by jeff on January 27, 2006 09:19 AM | Permalink

Additional resources: #140conf events | Watch the Jeff Pulver Show | Jeff's Qik Videos

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The new technology has these guidelines because VoIP doesn't have powerful enough lobbyists. Sure, the AT&Ts and the Verizons and the Bellsouths have their own VoIP offerings, but that's not to be competitive for consumers. That's to save themselves money in infrastructure costs. Why negotiate with another LEC for settlements when you can simply leverage their existing Internet infrastructure? It saves you money, and you can still charge consumers a pretty penny. The trick, then, is to get rid of all the little upstarts that have lower overhead and operating costs and can attract consumers with lower prices and good customer service.

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Posted by: Neil Fusillo at January 27, 2006 11:00 PM

January 27, 2006

It is Great to See Others Rant about the Disparate Regulatory Treatment between VoIP and Wireless and Traditional Wireline E-911

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